Washington, DC
U.S. Office of Personnel Management
Classification Appeal Decision
Under section 5112 of title 5, United States Code
Dental Health Activity, Leonard Wood
U.S. Army Dental Command Central
U.S. Department of the Army
Fort Leonard Wood, Missouri
Damon B. Ford
Classification Appeals and FLSA Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance
07/19/2022
Date
As provided in section 511.612 of title 5, Code of Federal Regulations (CFR), this decision constitutes a certificate which is mandatory and binding on all administrative, certifying, payroll, disbursing, and accounting officials of the Government. The agency is responsible for reviewing its classification decisions for identical, similar, or related positions to ensure consistency with this decision. There is no right of further appeal. This decision is subject to discretionary review only under conditions and time limits specified in the Introduction to the Position Classification Standards (Introduction), appendix 4, section G (address provided in appendix 4, section H).
As indicated in this decision, our findings show the appellant’s official position description (PD) does not meet the standard of adequacy described in section III.E. of the Introduction. Since PDs must meet the standard of adequacy, the agency must revise the appellant’s PD to reflect our findings. The servicing human resources office must submit a compliance report containing the corrected PD and a Standard Form 50 showing the personnel action taken. The report must be submitted within 30 days from the effective date of the personnel action to the Office of Personnel Management (OPM), Agency Compliance and Evaluation (ACE), Washington, DC, office.
Introduction
The appellant’s position is currently classified as a Dental Assistant, GS-0681-04, but she believes it should be graded at the GS-05 level. The position is assigned to the Boak Dental Clinic, Dental Health Activity, Leonard Wood, U.S. Army Dental Command Central, U.S. Department of the Army, at Fort Leonard Wood, Missouri. We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).
General issues
The appellant states she performs work similar to higher-graded Dental Assistants assigned to the U.S. Army Dental Command Central. In adjudicating this appeal, our responsibility is to make an independent decision on the proper classification of her position. By law, we must make that decision solely by comparing her current duties and responsibilities to OPM standards and guidelines (5 U.S.C. 5106, 5107, and 5112). Since comparison to standards is the exclusive method for classifying positions, we cannot compare the appellant’s position to others, which may or may not be classified correctly, as a basis for deciding her appeal.
Like OPM, the appellant’s agency must classify positions based on comparison to OPM standards and guidelines. The agency also has primary responsibility for ensuring that its positions are classified consistently with OPM appeal decisions. If the appellant considers her position so similar to others in her agency that they all warrant the same classification, she may pursue the matter by writing to her headquarters human resources office. In doing so, she should specify the precise organizational location, classification, duties and responsibilities of the positions in question. If the positions are found to be basically the same as hers, the agency must correct their classification to be consistent with this appeal decision. Otherwise, the agency should explain to her the differences between her position and the others.
Although the appellant’s supervisor certified to the accuracy of the appellant’s official PD number #KADC334260, the appellant believes the major duties listed in the PD do not accurately reflect all the daily tasks she performs. The appellant states she assists in specialty dental treatments such as endodontics, complicated oral surgeries, prosthodontics, and periodontics. She believes these recurring dental procedures should be included under the major duties section of her PD.
We find the appellant frequently assists in pulpectomies, a basic endodontic procedure that involves the removal of infected pulp from tooth canals. However, a pulpectomy does not constitute full endodontic treatment, such as a complete root canal. The procedure is strictly performed to relieve pain in patients and enable their deployment. Patients are referred to an endodontist to complete the root canal after deployment. The appellant also states she assists in oral surgical extractions such as the removal of impacted wisdom teeth. However, her work is limited to simple extractions of fully erupted teeth although sometimes the dentist may have to make gum incisions to fully expose the tooth. She does not assist in the performance of prosthodontics (e.g., crowns, bridges, and denture placement) as these are not done at her clinic.
Based on our review we find certain sections of the appellant’s PD inaccurate including statements in the “Overview”, “Patient Care”, and “Knowledge…” (Factor 1) portions. The appellant does not take impressions for study models, pour and trim models, or construct custom impression trays. She does not place or remove sutures. She is not required to have knowledge of prosthodontics, nor all phases of oral surgery and endodontics. She does not assist in performing periodontal procedures as these are not regularly done at her clinic. Rather, she is required to have basic practical knowledge of some aspects of oral surgery and endodontics typical of chairside assistants, but the emphasis is on providing restorative dental procedures, e.g., placement of resin fillings. Based on this information we find the appellant’s PD of record does not meet the standard of adequacy addressed on pages 11-12 of the Introduction and the agency must revise the PD to reflect our findings.
A PD is the official record of the major duties and responsibilities assigned to a position by an official with the authority to assign work. A position is the duties and responsibilities that make up the work performed by the employee. Classification appeal statutes and regulations permit OPM to investigate or audit a position and decide an appeal based on the actual duties and responsibilities currently assigned by management and performed by the employee. An OPM appeal decision classifies a real operating position, and not simply a PD. This decision is based on the work currently assigned and performed by the appellant.
Position information
The appellant’s clinic serves Class 3 military patients attending basic training to prepare them for deployment by providing treatment of dental health problems or diseases that could develop into emergencies within the next twelve months. All patients seen have grossly decayed and/or destroyed teeth that require immediate treatment or extraction. The clinic has 30 dental chairs with a staff consisting of 15 dentists and 13 dental assistants who are tasked with treating approximately 33,000 troops annually.
The appellant’s major duties include the performance of chairside assistance in restorative dental treatments, basic endodontics, and oral surgery. She also receives and schedules patients for treatment; obtains and records the medical history of patients through the Dental Universal Protocol Checklist; and charts examinations and treatment information. Most of her time is spent chairside assisting the dentist with patients but she is occasionally tasked with taking radiographs in a different area of the clinic. She independently selects and arranges all dental instruments and materials required for specific treatments and prepares the patient. After treatment the appellant instructs patients on proper dental techniques to prevent future dental decay.
She assists in dental treatments including rinsing and air procedures and passes and retrieves instruments and materials to and from the dentist. She also assists the dentist in placing rubber dams and ensures patient safety by monitoring them for signs of fainting, shock, and other distress signals.
She maintains dental equipment in a clean and operational condition and ensures her workspace is properly supplied and replenished as necessary. She uses a variety of dental equipment and material in the course of her work including occlusion papers, curing lights, wedges, matrix bands, apex locator, vortex blue files, rubber dams, rubber clamps, filling materials, oral kit set, 150 forceps, 151 forceps, surgical handpieces, scissors, isolite and fluoride.
When assigned, the appellant operates dental x-ray equipment to take intra and extra oral radiographs. She retrieves the digital images and/or develops and finishes film. She is responsible for maintaining, cleaning, and making minor repairs on x-ray equipment and materials. The appellant also takes panoramic radiographs.
The position is supervised by a military Non-Commissioned Officer who serves as the clinic’s Practice Manager. The appellant’s PD and record material provide much more information about her duties and responsibilities and how they are performed.
In reaching our classification decision, we carefully considered all information provided by the appellant and her agency including her official PD which, although not completely accurate, we have incorporated by reference into this decision. In addition, to gain more information about her work, we conducted a telephone audit with the appellant, and interviewed her first-line supervisor and the military General Dental Officer she regularly works with.
Series, title, and standard determination
The agency has classified the appellant’s position in the Dental Assistant Series, GS-0681, and the appellant does not disagree, and we concur. Positions in the GS-0681 Series include duties to receive and prepare patients for dental treatment; prepare materials and equipment for use by the dentist; to assist a dentist at chairside or bedside in the treatment of patients; to perform reversible intra-oral procedures under the supervision of the dentist; perform dental radiography work; and to keep records of appointments, examinations, treatments and supplies. The work requires a practical knowledge of standardized procedures and methods used in dentistry, and skill in the techniques and procedures of dental assistance. Because the appellant primarily performs chairside assistance to a dentist rather than performing reversible intra-oral procedures (Expanded Function), we agree with the agency’s title of Dental Assistant for the position. The grade of positions classified in the GS-0681 series is determined by application of the grading criteria in the position classification standard (PCS) for that series which follows.
Grade determination
The GS-0681 PCS uses the Factor Evaluation System (FES), which employs nine factors. Under the FES, each factor-level description in the PCS describes the minimum characteristics needed to receive credit for the described level. Therefore, if a position fails to meet the criteria in a factor-level description in any significant aspect, it must be credited at a lower level, unless an equally important aspect that meets a higher level balances the deficiency. Conversely, the position may exceed those criteria in some respects and still not be credited at a higher level. Each factor-level has a corresponding point value. The total points assigned are converted to a grade by use of the grade conversion table in the PCS.
The agency credited Level 1-3 for Factor 1, Knowledge Required by the Position; Level 2-2 for Factor 2, Supervisory Controls; Level 3-1 for Factor 3, Guidelines; Level 4-2 for Factor 4, Complexity; Level 5-2 for Factor 5, Scope and Effect; Level 6-2 for Personal Contacts; Level 7-2 for Purpose of Contacts; Level 8-2 for Physical Demands; and Level 9-2 for Work Environment. The appellant disagrees only with her agency’s assignment of Level 3-1 for Factor 3, stating it meets Level 3-2. After careful review, we concur with the agency’s factor level assignments for Factors 1, 2, 4, 5, 6, 7, 8, and 9. Therefore, our analysis focuses on evaluation of Factor 3.
Factor 3, Guidelines
This factor covers the nature of the guidelines used and the judgment needed to apply
them.
At Level 3-1, specific and detailed guidelines covering all important aspects of assignments are provided to the assistant. The assistant works in strict adherence to the guidelines; deviations must be authorized. Little or no judgment is required in selecting guidelines for application to individual cases. The standard indicates that most dental assistant positions are at this level.
At Level 3-2, procedures for doing the work have been well established and a number of specific guidelines are available. The number and similarity of guidelines and work situations, such as those encountered in assisting the dentist in the more difficult treatments (usually provided only in specialty practices), require the employee to use judgement in locating and selecting the most appropriate guidelines and procedures for application and in making minor deviations to adapt the guidelines to specific cases. At this level the employee may also determine which of several established alternatives to use. For example, in completing the more complex and intricate intra-oral assignments, such as restoring grossly destroyed teeth and constructing and placing temporary crowns and bridges, the assistant may select from well-established instruments and techniques. Situations to which existing guidelines cannot be applied or significant proposed deviations from the guidelines are referred to the dentist.
The appellant’s position meets Level 3-1. While we recognize that the number of guidelines used is limited (e.g., Dental Universal Protocol Checklist, manufacturer’s instructions on new instruments and equipment), the regular and recurring dental procedures performed (including treating grossly decayed teeth) at the Boak Clinic consist of basic restorative, simple extraction, and endodontic treatments requiring few guidelines and little judgment in carrying out typical daily chairside assistant procedures including dealing with dental emergencies. This is demonstrated by the fact that the initial training provided to new employees is sufficient to prepare them to perform the daily assisting tasks at the clinic without reference to procedural guidelines. Within this context of few guidelines and repetitive treatments, the opportunity to apply judgment in selecting, deviating from, and applying guidelines for various work situations and dental protocols is absent and unnecessary in the appellant’s position. The fact that she independently selects the appropriate instruments and materials for each dental procedure without referring to guidelines is typical of the repetitive nature of chairside dental assistance.
Level 3-2 is not met. As discussed above, given the basic nature of the recurring dental procedures and treatments performed at the clinic not requiring judgment in applying a number of similar guidelines the appellant’s position does not exceed Level 3-1. Unlike Level 3-2, she does not work in a specialty practice where such guidelines are referenced to carry out the types of more complex and intricate intra-oral assignments described at this level.
This factor is evaluated at Level 3-1 and 25 points are credited
Summary of FES factors
| Summary | ||
| Factor | Level | Points |
| 1. Knowledge Required by the Position | 1-3 | 350 |
| 2. Supervisory Controls | 2-2 | 125 |
| 3. Guidelines | 3-1 | 25 |
| 4. Complexity | 4-2 | 75 |
| 5. Scope and Effect | 5-2 | 75 |
| 6. Personal Contacts | 6-2 | 25 |
| 7. Purpose of Contacts | 7-2 | 50 |
| 8. Physical Demands | 8-2 | 20 |
| 9. Work Environment | 9-2 | 20 |
| Total | 765 |
A total of 765 points falls within the GS-04 range (655-850) on the grade conversion table provided in the GS-0681 PCS.
Decision
The appellant’s position is properly classified as Dental Assistant, GS-0681-04.