Washington DC

U.S. Office of Personnel Management
Classification Appeal Decision
Under section 5112 of title 5, United States Code

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Kimberly A. Steide, DPA
Principal Deputy Associate Director
Agency Compliance and Evaluation
Merit System Accountability and Compliance


02/18/2025

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Date

Finality of Decision

As provided in section 511.612 of title 5, Code of Federal Regulations (CFR), this decision constitutes a certificate that 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).

Since this decision lowers the grade of the appealed position, it is to be effective no later than the beginning of the fourth pay period after the date of this decision, as permitted by 5 CFR 511.702. The applicable provisions of parts 536 and 752 of 5 CFR must be followed in implementing the decision. If the appellant is entitled to grade retention, the two-year retention period begins on the date this decision is implemented. In addition, as stated in this decision, our findings show the discussion of several factors in the appellant’s Core Personnel Document (CPD) are overstated, thus, it does not meet the standard of adequacy described in section III.E. of the Introduction. Since Position Descriptions (PDs) must meet the standard of adequacy, the agency must correct the appellant’s CPD to reflect our findings. The servicing human resources office must submit a compliance report containing the corrected CPD 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), Merit System Accountability and Compliance, Agency Compliance and Evaluation, Washington, DC, office.

Introduction

The appellant’s position is currently classified as SAPR Program Manager, GS-0101-13, but she believes it should be classified at the GS-15 grade level.[1] The position is assigned to the Air Force District of Washington (AFDW), U.S. Department of the Air Force (AF), at Joint Base Andrews, Maryland. We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

General issues

The appellant questions the classification review practices of her agency, e.g., it failed to properly consider that her SAPR Program Manager position should be, but is not, officially supervised by the AFDW Deputy Commander or Commander in accordance with Air Force Instruction (AFI) 90-6001, SAPR Program. By law, we must classify positions solely by comparing their current duties and responsibilities to OPM position classification standards (PCS) and guidelines (5 U.S.C. 5106, 5107, and 5112). In adjudicating this appeal, our primary concern is to make our own independent decision on the proper classification of her position. Because our decision sets aside any previous agency decisions, the classification practices employed by the appellant’s agency to classify her position are not germane to our classification appeals process. Furthermore, agency management has the right, by law (5 U.S.C. 7106(a)), to establish its positions and assign their direct report relationships. Such actions are not reviewable under the classification appeals process.

The appellant states her CPD (number 8QAR7424) is inaccurate because it does not completely address her duties and responsibilities, e.g., does not cover her role for sexual harassment advocacy response and oversight. According to a document in the record, the appellant’s previous supervisor states that because the appellant’s program is in “such dynamic transition” at the agency level “it is premature to render a determination on the accuracy of the employee’s [the appellant] current PD.” In addition, during our interview, her current supervisor made no comment on the accuracy of the CPD. A PD is the official record of the 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 regulations permit OPM to investigate or audit a position and decide an appeal based on review of 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. Therefore, this decision is based on the actual work currently assigned to and performed by the appellant.

Although we find the major duties described in the appellant’s CPD are generally accurate, overall, it portrays the appellant’s duties and responsibilities as being of greater breadth, complexity, and impact than can be supported by the actual work performed. Certain aspects of her work are overstated in the factor descriptions of the PD, stating, for instance, under Factor 4 (Complexity), “Decisions regarding what needs to be done include largely unprecedented issues; ambiguous and highly complex conditions; and major areas of uncertainty resulting from gaps or conflicts in laws, regulations, or policies being studied.” Under Factor 5 (Scope and Effect), it states that her work involves analyzing and evaluating “major aspects of agency-wide [SAPR] and interpersonal violence, and training prevention programs…” Under Factor 7 (Purpose of Contacts), it states that the purpose of her contacts is to “present, justify, defend, negotiate, or settle matters involving significant or controversial issues, e.g., recommendations affecting major programs, dealing with substantial expenditures, or significantly changing the nature and scope of organizations.” These and other statements in the PD’s factor descriptions conflict with information gathered during our fact-finding, as discussed in the grade determination section of this decision. Given these PD inaccuracies, the appellant’s CPD does not meet the standard of adequacy described on pages 11-12 of the Introduction and the agency must revise the PD to reflect our findings.

The appellant asks OPM to consider the concept of impact of the person on the job in support of her rationale for the GS-15 grade level. The concept of impact of the person on the job is addressed in both the Introduction and The Classifier’s Handbook. The concept holds that an employee, by virtue of exceptional competence, may have such an impact on the duties, responsibilities, and qualification requirements of a position that it is changed to the point where its classification must also be changed. The mere fact that an individual in a position possesses higher qualifications or stands out from other individuals in comparable positions is not sufficient reason by itself to classify the position to a higher grade. When determining grade level based on this concept, it is essential that management recognizes and endorses the duties and that the work environment allows continuing performance at a different level. Because there is no evidence her work performance makes the duties of the appealed position materially different from what they otherwise would be, thus affecting the classification of the position, the impact of the person on the job concept is not applicable to the appellant’s position.

The appellant also seeks back pay if determined she is performing higher-grade level work. It is well settled that employees are statutorily barred from receiving back pay for periods of misclassification (5 U.S.C. 5596(b)(3)). See United States v. Testan, 424 U.S. 392, 400 (1976) and Erlyn D. Felder, B-202685, August 17, 1982. Further, the U.S. Comptroller General states than an “…employee is entitled only to the salary of the position to which he is actually appointed, regardless of the duties performed. When an employee performs the duties of a higher grade level, no entitlement to the salary of the higher grade exists until such time as the individual is actually promoted.” Consequently, back pay is not available as a remedy for misassignments to higher level duties or improper classifications” (Comptroller General decision B-232695, December 15, 1989).

Position information

The appellant’s position serves as SAPR Program Manager for the AFDW. The SAPR program is designed to provide comprehensive support, advocacy, and liaison services to eligible military and civilian sexual assault victims and their families in accordance with Department of Defense Instruction (DoDI) 6495.02, AFI 90-6001, and other agency policies and instructions. The primary purpose of the SAPR program is to eliminate sexual assault incidents through awareness and prevention training, education, victim advocacy, response, reporting, and accountability. The record shows that, as of August 2023, the appellant’s position reports directly to the Director of AFDW’s Manpower, Personnel, and Services Directorate.

As the senior functional advisor and expert on the SAPR program for the AFDW, the appellant is responsible for overseeing operational program direction and guidance by ensuring all legal and statutory requirements are met. She establishes and provides sexual assault prevention and response strategies, plans, and operational guidance throughout AFDW’s worldwide area of responsibility, which includes subordinate units (e.g., AF Elements, Field Operating Agencies, and Geographically Separated Units) that fall under the AFDW Commander. Specifically, the appellant provides functional oversight and guidance to the cadre of SAPR program staff assigned to Joint Base Andrews, Joint Base Anacostia Bolling, and the Pentagon.[2] A Sexual Assault Response Coordinator (SARC), a GS-0101-12, position, is assigned to each location to manage the installation-level SAPR program, serve as subject-matter expert to installation leadership, and coordinate 24/7 victim care and case management for sexual assault victims from initial reporting to legal disposition and resolution. The AFDW’s SAPR program staff includes approximately nine Victim Advocate (VA) positions (GS-0101-11), who report directly to their respective SARCs. VAs serve as the installation’s primary sexual assault victim advocate by providing support, advocacy, and liaison services to eligible military and civilian sexual assault victims. VAs assist SARCs by coordinating the services that victims receive from various agencies including medical, legal, mental health, and investigative services.

We discuss the appellant’s program guidance, oversight, inspections, and training work in more detail under our series and grade determination sections of this decision.

In reaching our classification decision, we carefully considered all information provided by the appellant and agency including her official PD which, while not completely accurate, we have incorporated by reference into this decision. In addition, we separately conducted a telephone audit with the appellant and a telephone interview with her current first-level supervisor.

Series, title, and standards determination

The agency classified the appellant’s position in the Social Science Series, 0101, which covers positions the duties of which are to advise on, administer, supervise, or perform research or other professional and scientific work in one or any combination of the social sciences when such work is not classifiable in other series of this occupational group.

The duties and responsibilities of the appellant’s position involves providing technical oversight and functional guidance to the GS-0101 SARC and VA positions assigned to the AFDW, developing prevention and training strategies and approaches, and identifying and implementing best practices. The SAPR program facilitates care by providing referrals and non-clinical support to victims of sexual assault. Because eligible military and civilian sexual assault victims and their families can report to any SAPR program staff, the appellant has regular contact with victims of sexual assault and related incidents. To serve as advocates for the victim, her position requires understanding of the responses to trauma (e.g., anxiety and depression) in order to encourage utilization of SAPR program services and customize referrals. She communicates with victims to gather information and, for example, provide information tailored to the client’s needs, facilitate referrals for services including safety and crisis intervention measures, promote the program’s victim service resources, encourage victims to seek medical care and other services, and explain reporting options available to them. In addition, she conducts internal audits of the SAPR program’s case management and other practices in order to monitor, assess policy compliance, and correct program deficiencies. She also develops, modifies, and presents training to AFDW’s senior leaders (255 general officers and 273 Senior Executive Service positions), who may serve as first responders to victims of sexual assault. She instructs them on the importance of being empathetic as they respond to and address concerns of the victim, in addition to educating them on their legal and statutory obligations. She maintains working relationships with State and local action agencies to facilitate and coordinate provision of care to meet victim needs. We thus conclude the appellant’s duties require application of specialized knowledge of the behavioral and other social sciences associated with the response to and prevention of sexual assaults. This is reinforced by the PD, which states the position requires experience in behavioral sciences and ability to address complex sexual assault response and prevention program development and management. Moreover, the appellant and her first-level supervisor confirm that her work requires application of professional knowledge of the behavioral sciences and/or fields related to sexual assault/harassment, understanding human behavior, and responses to trauma.

In addition, the appellant conducts ongoing assessments of the effectiveness of the AFDW’s SAPR program, identifies program needs and challenges, and communicates with senior leaders regarding recommendations and updates. Such work is typically covered by the Management and Program Analysis Series, 0343, which includes positions that primarily serve as analysts and advisors to management on the evaluation of the effectiveness of government programs and operations or the productivity and efficiency of the management of Federal agencies or both. Similar to 0343 positions, the appellant’s work requires knowledge of agency programs and activities, management principles and processes, and the analytical and evaluative methods and techniques for assessing program development or execution and improving organizational effectiveness and efficiency. However, as stated in the 0343 Position Classification Flysheet (PCF), dated May 2024, analytical positions which have as their paramount qualification requirement specialized subject-matter knowledge and skills equivalent to those required in a particular subject-matter occupation should be classified in the appropriate specialized series, e.g., Social Science Series, 0101. Therefore, although the appellant performs work similar to 0343 positions, because her duties and responsibilities require application of specialized professional knowledge of the behavioral and social sciences associated with sexual assault response and prevention, her position is properly classified in the 0101 series.[3]

Since OPM has not prescribed titles for positions in the 0101 series, the agency may construct a descriptive title following the guidance in the Introduction.

As instructed by the 0343 PCF, we evaluated the appellant’s program analysis work below by reference to the Administrative Analysis Grade Evaluation Guide (AAGEG). The agency’s current evaluation statement considered the appealed position solely by reference to the AAGEG. However, we also considered her 0101 covered duties. Because the 0101 series does not have grade level criteria, we evaluated the appellant’s duties by cross-series comparison to the PCS for the Social Work Series, 0185, which includes positions which require application of a professional knowledge of the principles and practices of social work (i.e., trained professionals devoted to helping vulnerable individuals, families, and communities work through challenges they face) in performing assignments such as providing direct services to individuals and facilities.

For social workers, 0185, engaged in casework there are three major phases of activity that make up their casework: (1) identifying the problem, (2) deciding appropriate action, and (3) providing indicated services. Like social workers, the appellant interviews people to establish the nature and extent of their problems, helps them work out plans for improving the situation, and refers them to community resources and other organizations. The appellant is engaged in the initial factfinding step typical of social workers involving establishing facts to identify the problem and giving advice and emotional support. Similar to the second step, based on her assessment of the client’s problem and her knowledge of agency and community resources, the appellant makes an initial decision on the appropriate action to address the client’s issues. However, unlike the third step, she is not involved in the social worker’s casework involving providing indicated services and establishing ongoing therapeutic relationships. Because the appellant’s work is characteristic of social worker positions utilizing basic interviewing skills and straightforward decision-making and commitment (dealing with clearly authorized agency services by determining client needs), we conclude after careful consideration that she is not engaged in the highly individualized services found in higher-graded social worker positions but is instead performing duties of work characteristic of GS-07 and GS-09 social worker positions. We determined such duties and responsibilities are graded significantly lower than her 0343 covered duties discussed below. Consequently, because such work is neither grade controlling nor does it serve as the basis of her classification appeal, we will not address those duties further.

Grade determination

The AAGEG is written in the Factor Evaluation System (FES) format, which employs nine factors. Each factor is evaluated separately and is assigned a point value consistent with factor-level definitions described in the guide. Under the FES, each factor-level description 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 aspects and still not be credited at a higher level.

The agency’s May 18, 2023, evaluation statement applying the grading criteria in the AAGEG assigned the following factor levels to the appellant’s position:  Levels 1-8 for Factor 1 (Knowledge Required by the Position), 2-4 for Factor 2 (Supervisory Controls), 3-4 for Factor 3 (Guidelines), 4-4 for Factor 4 (Complexity), 5-5 for Factor 5 (Scope and Effect), 3-c for Factors 6 and 7 (Personal Contacts and Purpose of Contacts), 8-1 for Factor 8 (Physical Demands), and 9-1 for Factor 9 (Work Environment). The appellant disagrees with the agency’s level assignment for Factors 2, 3, 4, 5, 6, and 7. After careful review of the record, we concur with the agency’s factor-level assignments for Factors 8 and 9 and have credited the position accordingly. However, we disagree with the agency’s assignment of Level 1-8 for Factor 1. Therefore, by application of the AAGEG we confined our analysis to Factor 1, and the factor levels disputed by the appellant (i.e., Factors 2-7).

Factor 1, Knowledge Required by the Position

This factor measures the nature and extent of information an employee must understand in order to do the work, and the skills needed to apply that knowledge.

At Level 1-7, work requires knowledge and skill in analyzing and evaluating the efficiency and effectiveness of program operations carried out by administrative or professional personnel, or substantive administrative support functions such as supply, budget, procurement, or human resources which facilitate line or program operations. This level includes knowledge of pertinent laws, regulations, policies, and precedents which affect the use of program and related support resources. Projects and studies typically require knowledge of the major issues, program goals and objectives, work processes, and administrative operations of the organization. This knowledge is used to conduct studies to evaluate and recommend ways to improve the effectiveness and efficiency of work operations in a program or support setting. Knowledge may also be used to develop new or modified work methods, records and files, management processes, staffing patterns, and procedures for automating work processes for the conduct of administrative support functions or program operations.

At Level 1-8, employees are expert analysts who have mastered the application of a wide range of qualitative and quantitative methods for the assessment and improvement of program effectiveness or the improvement of complex management processes and systems. Level 1-8 requires comprehensive knowledge of the range of administrative laws, regulations, policies, and precedents applicable to the administration of one or more important public programs. This knowledge is used to carry out such assignments as designing and conducting comprehensive management studies where the boundaries are extremely broad and difficult to determine in advance; preparing recommendations for legislation to change the way programs are carried out; or evaluating new legislation for potential program impact, and/or translating basic legislation into program goals, actions, and services. When leading studies, any proposals made to management involve substantial agency resources or require extensive changes in established procedures.

The distinction between Levels 1-7 and 1-8 lies in the breadth of knowledge and responsibility typically required to perform the work. Level 1-7 describes assignments where the employee is responsible for understanding existing programs and activities for the purpose of supporting and facilitating the line or program operations of the organization. Conversely, Level 1-8 typically requires an employee to exercise much broader staff responsibilities involved with defining and establishing programs and developing and initiating major changes to the activities or services of existing programs. Level 1-8 also requires a much broader knowledge of the “range of administrative laws, policies, regulations, and precedents applicable to the administration of one or more important public programs,” which is applied in the context of such assignments as making legislative recommendations that change the way programs are carried out or substantially alter the purpose, intent, or requirements of operational programs. In contrast, Level 1-7 requires knowledge of laws, policies, regulations, and precedents affecting specific programs and projects. Therefore, Level 1-7 is associated with the operational work of the organization while Level 1-8 is concerned with issues relating to and affecting the fundamental nature and function of agency programs (e.g., agency-level policy changes).

Within this context, the appellant’s work is characteristic of Level 1-7 in that she performs program management work in support of AFDW’s SAPR program, ensuring operations are conducted within the boundaries of existing laws, regulations, agency policies, and precedents relating to sexual assault awareness and prevention training, education, response, reporting, etc. Similar to this level, her work requires knowledge and skill in analyzing and evaluating the efficiency and effectiveness of SAPR program operations for the AFDW’s area of responsibility. The appellant provides program direction and policy guidance to SARCs, VAs, and AFDW’s senior leaders and other personnel on reporting procedures, confidentiality, program resources, etc., by communicating program rules and procedures, establishing deadlines, and answering technical questions, to ensure compliance with regulatory and procedural guidelines associated with the SAPR program. In addition, she provides case management oversight, monitoring input to the Defense Sexual Assault Incident Database to ensure timely and thorough reporting and documentation of incidents. She reviews overall quality of information entered in the program’s database to ensure sexual assault data is handled in accordance with established guidelines. Similar to Level 1-7, the appellant maintains and tracks various data and provides reports associated with program-related information and activities which may affect the efficiency and effectiveness of the SAPR program. She gathers, compiles, and shares information from various sources to identify best practices, develop strategies to promote reduction of sexual assault and associated behaviors, and implement prevention activities. Like Level 1-7, her work requires knowledge of the major issues, program goals and objectives, work processes and administrative operations of the SAPR program, and the application of a high degree of analytical ability and knowledge of the principles and processes of program management.

The agency’s current evaluation credited the appellant’s position at Level 1-8, but we find her position does not meet the description at this level. At Level 1-8, studies, decisions, and recommendations address broader program responsibilities of an organization and affect the review, assessment, and development of significant programs and policies or the improvement of complex management processes and systems. In contrast, the appellant’s work is confined to the evaluation and assessment of SAPR program operations within the AFDW, where the parameters are generally established by agency policies, rather than the comprehensive and “extremely broad” management studies where boundaries are undefined characteristic of Level 1-8. Moreover, studies, decisions, and recommendations made by the appellant do not involve substantial agency resources or directly influence the focus and/or direction of agency programs or policies as described at Level 1-8. Therefore, her work does not have the far-reaching impact or complexity envisioned at Level 1-8.

Level 1-7 is credited for 1,250 points.

Factor 2, Supervisory Controls

This factor covers the nature and extent of direct or indirect controls exercised by the supervisor, the employee’s responsibility, and the review of completed work.

At Level 2-4, within a framework of priorities, funding, and overall project objectives, the employee and supervisor develop mutually acceptable project plans including identifying the work to be done, and the scope and deadlines. Within these overall parameters, the employee is responsible for planning and organizing the work, estimating costs, coordinating with staff and management, and conducting all phases of the project. The employee keeps the supervisor informed of potential controversies or problems with widespread impact. Completed work is reviewed for compatibility with organizational goals, guidelines, and effectiveness in achieving intended objectives.

At Level 2-5, the employee is a recognized authority in the analysis and evaluation of programs and issues, subject only to administrative and policy direction concerning overall priorities and objectives. The employee is typically delegated complete responsibility and authority to plan, schedule, and carry out major projects concerned with the analysis and evaluation of programs or organizational effectiveness, and exercises discretion in determining whether to broaden or narrow studies. The employee’s analyses and recommendations are normally reviewed only for potential influence on broad agency policy objectives and program goals, and findings and recommendations are normally accepted without significant change.

The appellant’s level of responsibility and supervisory controls exercised over her work fully meet Level 2-4. This level describes work carried out with a high degree of independence and recognized competence, and is only reviewed for compatibility with organizational goals, guidelines, and achieving objectives. This fully represents the way the appellant manages the AFDW’s SAPR program. The AF-wide SAPR program office typically sets agencywide goals that each SAPR program must accomplish and are outlined in guidance issued by that office. Within that framework, the appellant develops long-range and short-term goals for the AFDW’s SAPR program. She works independently and has full responsibility for performing work to meet objectives and deadlines and completing assignments. Similar to Level 2-4, the appellant informs her supervisor, AFDW Commander or Deputy Commander, and others regarding potential controversies or problems, progress of goals, and adjusts when necessary.

The appellant’s position does not meet Level 2-5. We acknowledge she serves as the recognized authority on all SAPR program-related matters throughout the AFDW, and that she works independently in carrying out all program activities. However, Level 2-5 recognizes not only independence of action but also the degree of responsibility and authority inherent in the work as the context for the independence exercised. As the highest level described by the AAGEG, Level 2-5 is predicated on responsibility for independently planning and carrying out major program activities or projects, with only supervisory review for potential influence on broad agency policy objectives and program goals. Because the parameters of the work are not clearly defined, the employee at this level has authority to determine the most productive areas of endeavor. In contrast, the appellant carries out an ongoing set of SAPR program activities, the content and boundaries of which are generally established by DoDI 6495.02, AFI 90-6001, and other agency policies and instructions. Thus, the appellant’s managing the development and delivery of SAPR program functions in compliance with established agency program guidance as discussed later in the decision cannot be considered working within only the limited constraints of administrative and policy direction. Furthermore, her work does not involve planning and carrying out projects of the magnitude expected at Level 2-5; i.e., she oversees the effectiveness of SAPR program work performed at the AFDW rather than the effectiveness of broad organizations or programs. Therefore, although she works independently, the appellant has not been delegated the full scope of both technical and program authority required to credit Level 2-5.

Level 2-4 is credited for 450 points.

Factor 3, Guidelines

This factor covers the nature of the guidelines used and the judgment needed to apply them.

At Level 3-4, guidelines consist of general administrative policies and management and organizational theories which require considerable adaptation and/or interpretation for application to issues and problems studied. At this level, administrative policies and precedent studies provide a basic outline of the results desired, but do not go into detail as to the methods used to accomplish the project. Administrative guidelines usually cover program goals and objectives of the employing organization, such as agency controls on size of workforce, productivity targets, and similar objectives. Within the context of broad regulatory guidelines, the employee may refine or develop more specific guidelines such as implementing regulations or methods for the measurement and improvement of effectiveness and productivity in the administration of operating programs.

At Level 3-5, guidelines consist of basic administrative policy statements concerning the issue or problem being studied, and may include reference to pertinent legislative history, related court decisions, State and local laws, or policy initiatives of agency management. The employee uses judgment and discretion in determining intent, and in interpreting and revising existing policy and regulatory guidance for use by others within or outside the employing organization (e.g., other analysts, line managers, or contractors). Some employees review proposed legislation or regulations which would significantly change the basic character of agency programs, the way the agency conducts its business with the public or with private industry, or which modify important inter-agency relationships. Other employees develop study formats for use by others on a project team or at subordinate echelons in the organization. At this level, the employees are recognized as experts in the development and/or interpretation of guidance on program planning and evaluation in their area of specialization (e.g., workforce management, contingency/emergency planning, position management, work measurement, or productivity improvement).

The appellant’s guidelines fully meet Level 3-4. Like this level, she interprets and applies a broad knowledge of agency guidelines and policies (e.g., DoDI 6495.02 and AFI 90-6001), as well as relevant Federal laws and regulations to develop strategies, methods, and processes relating to AFDW’s SAPR program operations. Consistent with the description of Level 3-4, there are instances when available guidelines lack sufficient detail or specificity regarding the issue or situation she encounters. Because of the unique environment of the AFDW, available guidelines are inadequate when determining eligibility of certain individuals to utilize SAPR program services. In these instances, the appellant’s position requires considerable adaptation and/or interpretation of broadly stated guidelines and precedents to determine eligibility of individuals within the AFDW area of responsibility, which also encompasses personnel assigned to its subordinate units and Army, Navy, and other military members assigned to its joint base communities.

Characteristic of Level 3-4, the appellant analyzes the impact of proposed and/or issued policy changes from higher-echelon program offices (e.g., changes to the reporting of sexual assault/harassment incidents), advising management on their potential impact and developing a course of action to ensure program activities are fully compliant. Because she continually analyzes the effectiveness of AFDW’s SAPR programs and identifies best practices, her work involves refining existing guidelines to develop methods for measurement and improvement of program operations as expected at Level 3-4. Like this level, the appellant applies guidelines to develop detailed program plans, milestones and metrics, and long-range initiatives to ensure program goals and objectives are met. Although she cannot change the overall intent or broaden the parameters of the guidelines she adapts, her work extends beyond the interpretation of clear-cut guidelines and requires that she determine the most efficient means of organizing and accomplishing the myriad SAPR program activities and operations at the AFDW.

The appellant’s position does not meet Level 3-5. She performs operating-level administrative work rather than the staff-level policy and regulatory functions described at Level 3-5. Unlike this level, while the appellant applies general agency instructions and Federal laws and regulations occasionally requiring considerable interpretation, her guidelines do not require the degree of judgment, ingenuity, and the exercise of broad latitude to determine the intent of applicable references. She also does not review proposed legislation or regulations which would significantly change the basic character of the SAPR program or the way the agency conducts business. In contrast to Level 3-5, at her organizational level, the appellant is not responsible for developing agency policy and guidelines for specific areas of work or formulate interpretations that shape into policy statements, regulations, or agency guidelines.

Level 3-4 is credited for 450 points.

Factor 4, Complexity

This factor covers the nature, number, variety, and intricacy of tasks, steps, processes, or methods in the work performed; the difficulty in identifying what needs to be done; and the difficulty and originality involved in performing the work.

At Level 4-4, work involves gathering information, identifying and analyzing issues, and developing recommendations to resolve substantive problems of effectiveness and efficiency of work operations in a program or program support setting. This is in addition to improving conditions of a procedural nature which relate to the efficiency of organizations and workers described at the previous level. By way of contrast with Level 4-3, work at this level requires the application of qualitative and quantitative analytical techniques that frequently require modification to fit a wider range of variables. Subjects and projects assigned at this level usually consist of issues, problems, or concepts that are not always susceptible to direct observation and analysis. Difficulty is encountered in measuring effectiveness and productivity due to variations in the nature of administrative processes studied (e.g., those associated with providing support services). Information about the subject is often conflicting or incomplete, cannot readily be obtained by direct means, or is otherwise difficult to document. For example, assignments may involve compiling, reconciling, and correlating voluminous workload data from a variety of sources with different reporting requirements and formats, or the data must be carefully cross-checked, analyzed, and interpreted to obtain accurate and relevant information. Characteristic of this level is originality in refining existing work methods and techniques for application to the analysis of specific issues or resolution of problems.

At Level 4-5, work consists of projects and studies which require analysis of interrelated issues of effectiveness, efficiency, and productivity of substantive mission-oriented programs. Typical assignments require developing detailed plans, goals, and objectives for the long-range implementation and administration of the program, and/or developing criteria for evaluating the effectiveness of the program. Decisions about how to proceed in planning, organizing, and conducting studies are complicated by conflicting program goals and objectives which may derive from changes in legislative or regulatory guidelines, productivity, and/or variations in the demand for program services. Assignments are further complicated by the need to deal with subjective concepts such as value judgments; the quality and quantity of actions are measurable primarily in predictive terms; and findings and conclusions are highly subjective and not readily susceptible to verification through replication of study methods or reevaluation of results.

Options, recommendations, and conclusions developed by the employee at Level 4-5 take into account and give appropriate weight to uncertainties about the data and other variables which affect long-range program performance. For example, the employee may need to consider and assess the relative advantages and disadvantages of centralizing or decentralizing work operations in organizations with several echelons of geographically separated components. In some instances, work is complicated by the need to develop data about workload and program accomplishments which is currently unavailable. Current measurements of program effectiveness may be ambiguous and susceptible to widely varying interpretations. Under these circumstances the employee develops new information about the subject studied and establishes criteria to identify and measure program accomplishments, develops methods to improve the effectiveness with which programs are administered, or develops new approaches to program evaluation which serve as precedent for others.

The complexity of the appellant’s work meets Level 4-4. Like this level, she is responsible for managing, evaluating, coordinating, and reporting on the effectiveness of the AFDW-wide SAPR program. As SAPR Program Manager, she compiles, reconciles, correlates, and ultimately analyzes sexual assault/harassment data (to determine its relevancy and significance) from various sources so she can, e.g., identify trends, draw appropriate and defensible findings, make recommendations for improvement to organizational climate or culture, and develop effective prevention strategies. The appellant briefs the AFDW Commander and other senior leaders on a quarterly basis, identifying significant trends based on number of sexual assault/harassment incidents, victim relationships, service, units, etc.

In addition, the appellant’s work is consistent with Level 4-4 in that she develops evaluation methods and techniques to identify, predict, and resolve potential program issues and to meet the needs and requirements of the SAPR program. She develops recommendations to resolve problems and sensitive issues internal to the SAPR program, as well as improve the effectiveness and efficiency of SAPR program operations. For example, she regularly conducts inspections of installation SAPR programs (at Joint Base Andrews, Joint Base Anacostia Bolling, and the Pentagon), reviewing case management practices as well as ensuring training and reporting requirements are met and that overall SAPR program operations fully comply with DoDI 6495.02 and AFI 90-6001. Her findings, decisions, and recommendations are based on the analysis of program requirements, availability of resources, expectations of management, trend analysis, etc. To perform such work, the appellant uses qualitative analytical techniques to make independent determinations of program effectiveness and productivity. Similar to Level 4-4, the issues she encounters may not always be susceptible to direct observation and analysis and require her to apply qualitative and quantitative techniques which must be modified in order to assess the effectiveness of specific activities (e.g., she considers numerous variables to develop prevention strategies when their effectiveness may be difficult to predict).

The complexity of the appellant’s work does not meet Level 4-5. Whereas both Level 4-4 and 4-5 studies deal with issues of efficiency and effectiveness, Level 4-5 studies relate to the development of plans, goals, and objectives of “substantive mission-oriented programs,” meaning the line programs that represent the mission of the agency. This is reinforced by the first illustration provided by the AAGEG at Level 4-5:

Assignments require analysis of interrelated issues of effectiveness, efficiency, and productivity affecting major administrative programs of an agency. Studies are often complicated by the need to consider and evaluate the impact of changes in legislative and regulatory requirements; long-range program goals and objectives; political, economic, and social consequences of changes in the type or amount of services provided; or the changing nature of the program’s clients and beneficiaries. Difficulty characteristic of this level is encountered in planning and establishing the long-range (more than 5 year) program goals, objectives, and measurement criteria.

The appellant’s SAPR program work is not focused on the subjective considerations aimed at improving the overall administration of agency line programs indicative of Level 4-5. Furthermore, her work does not entail dealing with conflicting program goals and objectives which may derive from changes in legislative or regulatory guidelines, productivity, and/or variations in the demand for program services typical of Level 4-5, which would complicate her decision-making regarding how to proceed with work assignments. Instead, she determines the appropriate approach to analyze an issue or concern based on guidelines or precedents (as described at Level 4-4).

Level 4-4 is credited for 225 points.

Factor 5, Scope and Effect

This factor covers the relationship between the nature of the work and the effect of work products or services both within and outside the organization.

At Level 5-4, the purpose of the work is to assess the productivity, effectiveness, and efficiency of program operations or to analyze and resolve problems in the staffing, effectiveness, and efficiency of administrative support and staff activities. Work involves establishing criteria to measure and/or predict the attainment of program or organizational goals and objectives. Work at this level may also include developing related administrative regulations, such as those governing the allocation and distribution of personnel, supplies, equipment, and other resources, or promulgating program guidance for application across organizational lines or in varied geographic locations. Work that involves the evaluation of program effectiveness usually focuses on the delivery of program benefits or services at the operating level.

At Level 5-4, work contributes to the improvement of productivity, effectiveness, and efficiency in program operations and/or administrative support activities at different echelons and/or geographical locations within the organization. Work affects the plans, goals, and effectiveness of missions and programs at the various echelons or locations.

At Level 5-5, the purpose of the work is to analyze and evaluate major administrative aspects of substantive, mission-oriented programs. This may involve, e.g., the development of long-range program plans, goals, objectives, and milestones, or to evaluate the effectiveness of programs conducted throughout a bureau or service of an independent agency, a regional structure of equivalent scope, or a large complex multi-mission field activity. The work involves identifying and developing ways to resolve problems or cope with issues which directly affect the accomplishment of principal program goals and objectives. Study reports typically contain findings and recommendations of major significance to top management of the agency, and often serve as the basis for new administrative systems, legislation, regulations, or programs. Typical of work products prepared by employees at this level are complete decision packages, staff studies, and recommendations upon which implementation would significantly change major administrative aspects of missions and programs, or substantially affect the quality and quantity of benefits and services provided to the agency’s clients.

The appellant’s position meets Level 5-4. Like this level, the purpose of her work is to assess and manage AFDW’s SAPR program and resolve major problems impeding its effectiveness. This includes evaluating the program to ensure accomplishment of its goals and objectives and using performance measures and quality control procedures to continuously assess and review the productivity, effectiveness, and efficiency of program operations focused on the delivery of program benefits at the operating level (i.e., the AFDW and its subordinate units) as expected at Level 5-4. She is also involved in developing plans for the accomplishment of program goals and objectives and evaluating and changing the program as needed. For instance, she made recommendations to maintain continuance of 24/7 response capability despite shortage of SARCs. Consistent with this level, the appellant conducts inspections to ensure attainment of program goals and objectives, which includes determining best practices for providing victim services and enhancing public awareness of sexual assault prevention and education. She also promulgates program guidance across geographically dispersed organizations assigned or subordinate to the AFDW. The appellant provides guidance and advice to SARCs, VAs, and the AFDW Commander and other senior military and civilian leaders to ensure accomplishment of program goals. Similar to Level 5-4, she contributes to improvement of program operations at different geographical locations within her area of responsibility. Additionally, her work affects the quantity and quality of service provided to sexual assault victims and their families.

The agency’s current evaluation credited the appellant’s position at Level 5-5, but we find her position does not fully meet the description at this level. Although it encompasses development of long-range program plans, goals, and objectives, her work is normally confined to the operating level of the SAPR program at the AFDW. The scope of work identified at Level 5-5 includes programs that are conducted throughout a bureau or an organizational structure of equal scope. Therefore, the program controls constraining the scope and effect of the appellant’s work do not allow for the opportunity to deal with the range of issues and problems described at Level 5-5.

Level 5-4 is credited for 225 points.

Factor 6, Personal Contacts and Factor 7, Purpose of Contacts

These factors cover the type and level of contact made in carrying out the work and the reasons for these contacts. Each factor is evaluated separately, but a combined point credit is established by determining on the chart provided where the respective levels intersect. The relationship between factors 6 and 7 presumes that the same contacts will be evaluated under both factors.

Personal Contacts

At Level 6-3, contacts include persons outside the agency which may include consultants, contractors, or business executives in a moderately unstructured setting. This level may also include contacts with the head of the employing agency or program officials several managerial levels removed from the employee when such contacts occur on an ad-hoc basis.

At Level 6-4, contacts are with high-ranking officials such as other agency heads, top congressional staff officials, state executive or legislative leaders, mayors of major cities, or executives of comparable private sector organizations.

The appellant’s personal contacts fully meet Level 6-3. She has regular contact to discuss a host of SAPR program-related issues and activities with staff assigned or subordinate to AFDW, which is comprised of approximately 35,000 to 38,000 personnel. Similar to Level 6-3, her ad-hoc contacts include civilian program and military officials who may be several managerial levels removed from her position. Like Level 6-3, her contacts outside the agency include sexual assault victims and their family members, representatives of community organizations and advocacy groups, attorneys and law enforcement officials, and hospital staff to establish memorandums of understanding. In addition, she has contact with SAPR program peers within AF, DoD, Army, Navy, etc. The appellant’s contacts occur in moderately unstructured settings (i.e., not regularly scheduled and the roles and authorities of the parties vary depending on the person contacted). Contacts may involve issues that are sensitive or adversarial in nature.

The appellant’s contacts do not meet Level 6-4 as she does not have regular and recurring contact with persons described at this level.

            Purpose of Contacts

At Level c, the purpose of contacts is to influence managers or other officials to accept and implement findings and recommendations on organizational improvement or program effectiveness. The employee may encounter resistance due to such issues as organizational conflict, competing objectives, or resources problems.

At level d, the purpose of contacts is to justify or settle matters involving significant or controversial issues, e.g., recommendations affecting major programs, dealing with substantial expenditures, or significantly changing the nature and scope of organizations.

The purpose of the appellant’s contacts meets Level c. Consistent with Level c, she provides guidance and advice for the purpose of gaining compliance with reporting and other SAPR program requirements, as well as recommendations from inspections regarding identified discrepancies (e.g., deficiencies with written crisis response plans) and improvements to organizational climate and culture. In addition, similar to Level c, the appellant’s contacts involve persuading individuals and groups who may initially be resistant to utilizing SAPR program services.

The purpose of the appellant’s contacts does not meet Level d. Contacts of the scope and authority described at Level d are not made by the appellant but instead are made by higher-level program management officials within AF or AFDW’s senior leaders who are vested with authority to materially affect major programs or change the nature and scope of organizations.

Level 3c is credited for 180 points.

Summary

Table 1 Grade Determination

Factor	Level	Points
1. Knowledge Required by the Position	1-7	1250
2. Supervisory Controls	2-4	450
3. Guidelines	3-4	450
4. Complexity	4-4	225
5. Scope and Effect	5-4	225
6. & 7. Personal Contacts and Purpose of Contacts	3c	180
8. Physical Demands	8-1	5
9. Work Environment	9-1	5
Total Points		2790

 

A total of 2,790 points falls within the GS-12 point range (2755-3150) on the grade conversion table provided in the AAGEG.

Decision

The appellant’s position is properly classified as GS-0101-12. Selection of an appropriate title is at the agency’s discretion.

[1] The appellant’s appeal to OPM identifies the requested classification as “GS-15-Administrative Analyst Series.” However, during our interviews, she confirmed the GS-0101 series assignment.

[2] The appellant’s position provides functional oversight and guidance to SAPR program staff assigned to the AFDW, but she and her supervisor stated a proposal to designate the appealed position as official supervisor over all SAPR program staff at the AFDW is currently under review.

[3] Although the appellant has a behavioral science degree, we note the 0101 series is one of the few occupations covered by the Group Coverage Qualification Standard for “Professional and Scientific Positions” that allows applicants to possess certain kinds of experience in lieu of education. See the Individual Occupational Requirements for the GS-0101 series at https://www.opm.gov/policy-data-oversight/classification-qualifications/general-schedule-qualification-standards/0100/social-science-series-0101/.

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