Washington DC

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

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Judith A. Davis (for) Robert D. Hendler
Classification and Pay Claims Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance


09/20/2013

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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 does not meet the standard of adequacy described in section III.E. of the Introduction.  Since position descriptions must meet the standard of adequacy, the agency must revise the appellant’s position description to reflect our findings.  Also, since this decision lowers the grade of the appealed position, it is to be effective no later than the beginning of the sixth pay period after the date of this decision, as permitted by 5 CFR 511.702.  The applicable provisions of parts 351, 432, 536, and 752 of title 5 CFR must be followed in implementing this decision.  If the appellant is entitled to grade retention, the two-year retention period begins on the date this decision is implemented.  The servicing human resources office must submit a compliance report containing the corrected position description 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 OPM office which accepted the appeal. 

Introduction

On August 20, 2012, Chicago Oversight of the U.S. Office of Personnel Management (OPM) accepted a classification appeal from [name].  The appellant’s position is currently classified as Voluntary Services Officer, GS-301-12, but he believes it should be classified at the GS-13 grade level.  The position is assigned to the Voluntary Service Office, Eastern Kansas Health Care System, VISN 15, Veterans Health Administration, U.S. Department of Veteran Affairs (VA), in Leavenworth, Kansas.  We received the complete agency administrative report (AAR) on October 3, 2012, and the appellant’s comments on the report on October 9, 2012.  We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

General issues

The appellant states that his position is classified inconsistently with other similar positions nationwide and specifically in VISN 15.  He submitted information comparing the complexity levels of other facilities and comparable statistical data regarding number of volunteers, volunteer hours, donations, etc. in other VISN 15 VA facilities that have higher graded positions to support his request that his position be upgraded.  In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of the position.  By law, we must make that decision solely by comparing the appellant’s current duties and responsibilities to OPM position classification standards (PCS) and guidelines (5 U.S.C. 5106, 5107, and 5112).  Since comparison to OPM standards and guidelines is the exclusive method for classifying positions, we cannot compare the appellant’s position to others, which may or may not be classified properly, as a basis for deciding his appeal. 

Like OPM, the appellant’s agency must classify positions based on comparison to OPM standards and guidelines.  However, the agency also has primary responsibility for ensuring that its positions are classified consistently with OPM appeal decisions.  If the appellant considers his position so similar to others that they all warrant the same classification, he may pursue the matter by writing to his agency’s human resources headquarters.  In doing so, he 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 his, the agency must correct their classification to be consistent with this appeal decision.  Otherwise, the agency should explain to him the differences between his position and the others. 

The appellant was recently appointed VISN Liaison and submitted an addendum to his PD  describing his intended duties.  Implicit in the appellant’s rationale is that the increase in the workload should support the upgrading of his position.  The assigning of more work, however, does not necessarily mean that the additional work is more difficult and complex.  The newly assigned collateral duties, discussed later in the decision, are comparable to the work already assigned to the appellant, and therefore have no effect on the grade level of the position.  Further, volume of work cannot be considered in determining the grade of a position (The Classifier’s Handbook, chapter 5).

The appellant and the supervisor certified to the accuracy of the appellant’s position description (PD) number 00211-0.  A PD is the official record of the major duties and responsibilities assigned to a position or job by an official with the authority to assign work.  A position represents the work which is made up of the duties and responsibilities performed by the employee.  Classification appeal 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 the PD.  Therefore, this decision is based on the work currently assigned to and performed by the appellant.   

In reaching our classification decision, we have carefully reviewed all information of record furnished by the appellant and the agency.  Additionally, we interviewed the appellant and the appellant’s supervisor to further gather information concerning the duties and responsibilities of the position which we fully considered in this decision. Although we incorporate the appellant’s PD of record into this decision, we find it overstates the difficulty and complexity of the work he performs.  For example, the PD states that the appellant’s guidelines consist of “[a]dministrative polices and precedent studies” which “provide a basic outline of the results desired, but lack details regarding methods used to accomplish projects;” that “administrative guidelines usually cover program goals and objectives …such as agency controls on size of workforce, productivity targets, and similar objectives;” and, “[w]ithin the context of broad regulatory guidelines the incumbent may refine or develop more specific guidelines.” However, as discussed in this decision, the focus of the appellant’s work is to manage a voluntary services program, adhering to policies, methods, and specific program procedures issued by VA Central Office.  Therefore, the appellant’s PD of record does not meet the standard of adequacy addressed on pages 10-11 of the Introduction and the agency must revise the PD to reflect our findings. 

Position information

The appellant reports to the Assistant Director of the Eastern Kansas Health Care System and serves as Voluntary Services Officer for the Health Care System.  As such, he is responsible for coordinating and managing the Voluntary Service at the Leavenworth and Topeka campuses.  The mission of Voluntary Service is to provide a structured volunteer program under the management of VA employees in cooperation with community resources to serve veterans and their families with dignity and compassion.  

The appellant is responsible for recruiting, screening, placing and providing general orientation to volunteers at each campus.  He presents information about the medical center and volunteer opportunities to the media and public to encourage their participation.  The appellant presents information about the value and management of volunteers to medical center employees.  He assists the Human Resources Office with the on-boarding process of volunteers to ensure that background checks, medical tests, orientation, etc. are conducted.  The appellant ensures that each volunteer’s file is updated annually.  He resolves sensitive situations if they arise with the volunteers, veterans, and medical center employees.   

The appellant also is responsible for the management and coordination of various components of the program such as the Volunteer Transportation Network, National Salute, Recognition Program, Greeter Program, and Food Purchase Program, etc.  He manages and supervises General Post Fund accounts which include 35 accounts totaling over $800,000.  He serves on committees and subcommittees to provide information on how to coordinate and promote volunteer activities and on other matters relating to volunteerism.

The appellant’s primary responsibility as VISN Liaison includes facilitating communication between the VHA Office of Voluntary Services Central Office and the VISN 15 Voluntary Services Officers.  The liaison work is newly assigned and has not yet been performed, but the collateral duties include chairing and/or participating on council and committee meetings for the purpose of goal setting and information sharing; compiling and disseminating data for the other VISN facilities and all levels of management; and providing guidance and assistance to other VISN Voluntary Service Officers. 

Series, title, and standard determination

The appellant’s position is properly assigned to the GS-301 series, which covers nonprofessional, two grade interval work for which no other series is appropriate.  Neither the appellant nor the agency disagrees.  Since there are no prescribed titles for the GS-301 series, the position may be titled at the agency’s discretion.

The appellant believes the General Schedule Supervisory Guide (GSSG) should be used to evaluate the position’s grade level.  For coverage under the GSSG, supervisory responsibilities must accomplish work through combined technical and administrative direction of others, constitute a major duty occupying at least 25 percent of the position’s time, and meet at least the lowest level of Factor 3 identified in the GSSG.

In his response to the AAR, the appellant put forward a rationale for applying the GSSG based on supervision of program volunteers consisting of over 600 volunteers performing 36 staff years of work.  However, once volunteers are on-boarded, their day-to-day work is assigned by and overseen by the medical center components they support.  Thus, the volunteers are managed in what the GSSG in Exclusion 3 defines as a matrix environment and may not be considered as being under the appellant’s technical and administrative supervision for purposes of determining coverage of his position by the GSSG.

The appellant also puts forward a rationale for Factor 1, Scope and Effect, at Level 1-3 based on the monetary value of the services provided by the volunteers and the ensuing cost avoidance accomplished by receipt of those services.  Thus, the appellant’s rationale for Factor 1 rests on the work performed by the volunteer workforce.  However, Level 1-3 in the GSSG requires that the program segment supervised perform “technical, administrative, protective, investigative, or professional work.”  Established OPM interpretive guidance notes that since GS-9 is the first full-performance grade level for administrative, professional, and/or investigative work, Level 1-3 may only be considered for positions properly credited in Factor 5 with overseeing a base level of GS-9 or above.  As the nature of the work performed by volunteers, e.g., transporting veterans to appointments, etc., does not approach or meet the GS-9 grade level, the appellant’s reliance on such work to support the crediting of Level 1-3 is misplaced.             

The appellant supervises five employees, two GS-11 Voluntary Service Specialists and three GS-3 Health Aids.  These are the only positions that may be considered in applying the GSSG.  The Voluntary Service Specialists perform duties to ensure effective planning, operation, and evaluation of the Voluntary Service Program.  The specialists conduct reviews and appraisals of the program in order to explore new volunteer assignments and/or donation opportunities.  They present information on program components to the medical center’s staff to encourage the use of volunteers and assess the needs of various services to determine where volunteers will be best utilized.  They develop program goals based on the needs assessment, goals, and mission of the medical center.  They also recruit, screen, and place volunteers throughout the facility.  The specialists are authorized to reassign, counsel, and terminate volunteers.  They prepare and review correspondence, prepare schedules and assignment guides for volunteers, prepare training materials, etc.   They support special events such as volunteer recognition activities by determining the necessary awards, ordering gifts, awards and pins, printing tickets, etc.  They also serve on committees and subcommittees.  In fiscal year 2012, the Topeka specialist functioned as the first line supervisor of the Voluntary Service staff and ran the day-to-day operations.  The agency is planning to reorganize the office this year making the appellant the first line supervisor of all the staff.

The Voluntary Service Specialists independently plan and carry out the projects and selects the approaches and methods to be used in solving problems. These employees inform the appellant of potentially controversial findings, issues or problems with widespread impact.  Completed projects are reviewed to determine that objectives have been met and are in compliance with agency policies and regulations.  Based on the foregoing, we find these positions operate with relative independence and receive limited technical supervision.  

The Health Aids (patient greeters) direct veterans, family, and visitors to the appropriate office or service within the health care system.  The Health Aids carry on the day-to-day responsibilities without direction, intervention or assistance of a supervisor.  The employees use initiative in carrying out recurring assignments independently without specific instructions but refer deviations or problems to the supervisor. 

The appellant also claims he supervises one Voluntary Service Assistant, GS-3 position (My HealtheVet).  However, the appellant’s supervisor stated that this person is supervised by an employee outside of the Eastern Kansas Voluntary Service office and the Voluntary Service Assistant PD supports that. 

When the appellant was questioned during the telephone interview about the percentage of time spent supervising his staff he stated that he wasn’t sure what percentage of time was spent and that he works with the volunteers more.  Also, his PD, which he certified was accurate, does not indicate that he spends at least 25 percent of his time on this function.  Given this small workforce, as well as the subordinates’ degree of independence, we conclude that the appellant does not spend 25 percent or more of his time supervising these positions.  Therefore, we find the GSSG is not appropriate for grade-level determination.  

There are no published grade-level criteria for the GS-301 series.  In such instances where specific criteria are not available for the work being evaluated, a standard addressing similar or related types of work is to be used.  The agency applied the grading criteria in the Administrative Analysis Grade Evaluation Guide (AAGEG), which is designed to evaluate staff analytical, planning, and evaluative work concerned with the administrative and operational aspects of agency programs and management.  After careful review of the record, we concur with the agency’s application of the AAGEG.  We also referred to the grading criteria in the GS-1035 Public Affairs PCS for cross-series confirmation of the level credited for Factors 1, 2, 3, and 4.  The GS-1035 standard covers work involving administering, supervising, or performing work involved in establishing and maintaining mutual communication between Federal agencies and the general public and various other internal or external audiences.  This work is sufficiently similar to the appellant’s public affairs effort to recruit volunteers for the medical center to warrant its use in evaluating the grade level of the appellant’s work. 

Grade determination

The AAGEG and GS-1035 PCS are written in the Factor Evaluation (FES) format, under which factor levels and accompanying point values are assigned for each of the nine factors.  The total is converted to a grade level by use of the grade conversion table provided in the PCS.  Under the FES, each factor-level description demonstrates the minimum characteristics needed to receive credit for the described level.  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 credited the position at Levels 1-7, 2-5, 3-4, 4-4, 5-4, 6/7-3C, 8-2, and 9-1.  In the original response to the agency’s AAR, the appellant disagreed with the agency’s evaluation of Factors 1, 2, 4, 5, 8, and 9, even though the agency credited Factors 2 and 8 with the highest levels available in the AAGEG.  In the appellant’s October 4, 2012 written response, he only disagreed with factors 4, and 7.  Our analysis of all factors follows.  

Factor 1, Knowledge Required by the Position

This factor measures the nature and extent of information or facts the employee must understand to do acceptable work (e.g., steps, procedures, practices, rules, policies, regulations, and principles) and the nature and extent of the skills needed to apply the knowledge.

At Level 1-7 in the AAGEG, the position requires knowledge and skill in applying analytical and evaluative methods and techniques to issues or studies concerning the efficiency and effectiveness of program operations carried out by administrative or professional personnel, or by substantive administrative support functions (i.e., internal activities or functions such as supply, budget, procurement, or personnel which service to facilitate line or program operations).  This level includes knowledge of pertinent laws, regulations, policies, and precedents affecting the use of program and related support resources (people, money, or equipment) in the area studied.  Projects and studies typically require knowledge of the major issues, program goals and objectives, work processes, and administrative operations of the organization. Knowledge is used to plan, schedule, and conduct projects and studies to evaluation and recommend ways to improve the effectiveness and efficiency of work operations in a program or support setting.  The assignments require knowledge and skill in adapting analytical techniques and/or organizational productivity.  Knowledge is applied in developing new or modified work methods, organizational structures, management processes, procedures for administering program services, guidelines, and procedures, etc.

At Level 1-7 in the GS-1035 PCS, work requires knowledge applicable to a wide range of duties involving oral and written communication principles, practices, techniques and methods, analytical methods; and interpersonal relations practices.  Skill is required in applying such knowledge in the modification of standard methods and adaptation of approaches in developing new information materials aimed at enhancing the understanding of groups or individuals of the significant issues of an agency’s program.  Knowledge applicable to and skill in assessing public reaction and identifying extent of understanding achieved to evaluate effectiveness of information programs.  Knowledge and skill to explain significant issues to generally responsive groups or individuals interested in the agency’s programs. Illustrative examples of this level include: 

• Knowledge and skill sufficient for conducting workshops, seminars and other meetings with non-profit organizations, schools, State and local government agencies and cooperating industries to stimulate interest in such efforts with constituents of their groups;
• Knowledge and skill sufficient for determining the appropriateness of elements of an internal information program recommended by higher headquarters and suggesting ways for improving future materials or adapting current materials to meet current needs more effectively.  

As is typical of Level 1-7, the appellant’s position requires knowledge of the concept of volunteerism to develop, coordinate, and oversee an effective voluntary service program for the medical center.   The appellant recruits, selects, and places volunteers in all areas of the hospital.  He participates on committees and subcommittees to further promote the voluntary service program.  The position requires knowledge of the mission, program activities, and needs of the medical center in order to effectively communicate them to external and internal stakeholders.  The appellant presents information about the medical center and volunteer opportunities to the media and public, and briefs medical center personnel on the use of volunteers.  He is also responsible for assessing public reaction to various events to advise management of possible modifications to make future events more successful.  The position requires knowledge of VHA Handbooks which govern the operation of a structured voluntary services program and provide procedures for securing funding legally through gifts and donations.  The appellant uses his knowledge to plan, schedule, and conduct projects and studies to evaluate and recommend ways to increase the awareness and visibility of volunteering and increase monetary and in-kind resources for the medical center to ensure that it meets the facility’s needs.  The new VISN Liaison duties require the same knowledge, which includes knowledge of volunteerism, knowledge of the mission and needs of the medical centers, and knowledge of VHA guidelines.

At Level 1-8 in the AAGEG, the employee operates as an expert analyst who has mastered the application of a wide range of qualitative and/or quantitative methods for the assessment and improvement of program effectiveness or the improvement of complex management processes and systems.  This level also requires comprehensive knowledge of the range of administrative laws, policies, regulations, and precedents applicable to the administration of one or more important public programs.  This typically includes knowledge of agency program goals and objectives, the sequence and timing of key program events and milestones, and methods of evaluating the worth of program accomplishments.  Work requires knowledge of relationships with other programs and key administrative support functions within the employing agency or in other agencies. 

Knowledge characteristic of Level 1-8 is applied in a variety of ways.  For example, knowledge may be applied in preparing recommendations for legislation to change the way programs are carried out; in evaluating the content of new or modified legislation for projected impact upon agency programs and resources; and/or in translating basic legislation into program goals, actions, and services.  Comprehensive management studies conducted at Level 1-8 are extremely broad and so difficult to determine in advance that the actual limits of the project are developed as the study proceeds.  Study objectives deal with management problems characterized by their breadth, importance and severity for which previous studies and established management techniques are frequently inadequate.  Illustrative of such work is applying expert knowledge of analytical and evaluative methods plus a thorough understanding of how regulatory or enforcement programs are administered to select and apply program evaluation and measurement techniques in determining the extent of compliance with rules and regulations issued by the agency, or in measuring and evaluating program accomplishments.  This may include evaluating the content of new or modified legislation for projected impact upon the agency’s programs or resources.

At Level 1-8 in the GS-1035 PCS, work requires the use of a mastery of communication principles, methods, practices and techniques; analytical methods; and interpersonal relations practices.  Such skill is used in developing and applying new approaches to the most difficult and complex public affairs problems of an agency by developing or evaluating information programs enhancing understanding among publics opposed or indifferent to agency programs.  Level 1-8 employees may typically analyze public reaction to agency programs and policies and develop recommendations that significantly modify an agency’s major programs or policies.  They integrate diverse points of view in comprehensive communications plans designed to establish and maintain mutual understanding with various agency publics.  Illustrative examples of this level include: 

• Knowledge and skill sufficient for presenting ideas in written materials in new ways that will increase understanding among publics with varying levels of comprehension of agency programs and policies, or opposition or indifference to the agency’s program objectives;  
• Knowledge and skill sufficient for establishing and maintaining effective working relationships with individuals having opposed points of view and conflicting interests and explaining a position while not criticizing other views or arousing damaging hostility.

The position does not meet Level 1-8 in either PCS.  Level 1-8 is creditable to positions with much broader program responsibilities than those assigned to and performed by the appellant.  While the position is viewed as the local expert in voluntary service and is responsible for guiding the Eastern Kansas VA facilities in voluntary service functions, the position does not deal with the broader program responsibilities of an agency program such as preparing recommendations for legislation, evaluating the content of new or modified legislation for impact on agency programs or resources, or making proposals that affect substantial agency resources.  Rather, the appellant works at the program-delivery level carrying out the program formulated and controlled by the VHA Office of Voluntary Service in VA Central Office.  It is this VA component which translates basic legislation into program goals, actions, and services found at Level 1-8.  Also, the knowledge required of the appellant’s position does not meet Level 1-8, as it does not require him to analyze public reaction to agency programs or policies to develop recommendations that significantly modify the agency’s major programs or policies.  Instead, as at Level 1-7, the appellant advises management on modifications to the methods utilized in carrying out agency programs or policies.  Any major adjustments to programs and/or policies would be made at the VA headquarters level.  

While the appellant has meetings with various organizations and internal stakeholders, these groups are usually neither opposed nor indifferent to the voluntary service program as is typical of Level 1-8.  The mission and activities of the medical center as they relate to voluntary services are not inherently controversial, nor does the medical center normally generate any significant negative publicity with regard to voluntary services.  The appellant does not deal with sensitive issues, such that he would have to deal with public hostility or mistrust, where he would have to devise a different approach for explaining the agency’s actions or, if necessary, working with agency management to bring about program or policy changes that will satisfy public concerns.  Therefore, the appellant’s regular and recurring work provides neither the opportunity nor the necessity for the appellant to have to examine existing approaches or devise new and more effective ways of presenting information of a controversial nature as discussed in the GS-1035 PCS.

Level 1-7 is credited for 1250 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.  The agency credited Level 2-5, the highest level in the PCS and the highest level provided for in the FES.  However, the appellant asks that a higher level be assigned.

At Level 2-4 in the AAGEG, within a framework of priorities, funding, and overall objectives, the employee and supervisor develop overall work plans covering requirements, 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 work.  The employee keeps the supervisor informed of potential controversies or problems with widespread impact.  Completed work is reviewed for compatibility with organizational goals and effectiveness in achieving objectives. 

At Level 2-4 in the GS-1035 PCS, the supervisor determines the overall objectives and resources available to perform the work.  The employee and supervisor jointly develop deadlines, projects, and the nature of planned assignments.  The employee is responsible for planning and carrying out the assignments, resolving most problems, coordinating the work with others, interpreting policy, and determining the approach to be taken, and the methods and techniques to be employed.  The employee keeps the supervisor informed of progress, potential controversies, or wide-ranging implications.  Completed work is reviewed in terms of achieving expected results, responsiveness, and conformance with agency policy.  Completed work may also be subject to clearance procedures from higher levels in the agency.

The appellant’s level of responsibility and the supervisory controls exercised over his work are consistent with Level 2-4 in both PCSs.  This level describes work carried out with a high degree of independence and recognized competence and as such fully represents the manner in which the appellant operates.  VA Central Office Voluntary Service program office sets nationwide goals that each volunteer services program must accomplish and are outlined in guidance issued by that office.  Within the framework of the nationwide goals, the appellant develops long-range and short-term goals for the medical center’s voluntary service program.   He works independently and has full responsibility for scheduling work to meet deadlines and objectives and completing assignments and informs his supervisor monthly of the progress of the goals and makes adjustments as necessary.   

At Level 2-5 in the AAGEG, 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. 

At Level 2-5 in the GS-1035 PCS, the supervisor provides administrative direction to the employee by making assignments in terms of the broadly defined mission or function of the organization’s program.  The employee is responsible for independently planning, designing, and carrying out programs, campaigns, projects, studies or major program functions, informing the supervisor of progress as appropriate.  Results achieved are considered technically authoritative and are normally accepted without significant change.  Work involving particularly sensitive or controversial issues may be reviewed by officials at headquarters levels.  If the work is reviewed, the review concerns such matters as fulfillment of program objectives or the effect of the employee’s advice in facilitating achievement of the functional program’s objectives.  Recommendations for new projects and shifts in public affairs program objectives are evaluated in terms of resources available, program goals, or agency-wide priorities.

Level 2-5 is not met in either PCS.  This level 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.  Level 2-5 is predicated on responsibility for independently planning and carrying out major program activities or projects, with only broad administrative and policy discretion.  Because the parameters of the work are not clearly defined, the employee at this level has the authority to determine the most productive areas of endeavor.  In contrast, the appellant carries out an ongoing set of activities, the content and boundaries of which are well-established.  His work does not involve planning and carrying out projects of the magnitude expected at this level; i.e., he oversees the effectiveness of work performed in Voluntary Service rather than the effectiveness of broad organizations or programs (meaning the line operating programs or major administrative functions of the agency).  

Unlike Level 2-5, the appellant’s administrative and other program functions are controlled by the VA Central Office staff.  It is this office which controls the implementation of new systems or projects and who directly affect the broad VA programs as contemplated at Level 2-5.  Thus, managing the development and delivery of medical center voluntary service program functions in compliance with detailed VA Central Office program guidance as discussed later in this decision cannot be considered working within the limited constraints of administrative and policy direction.  Therefore, although the appellant works independently, he has not been delegated the full scope of both technical and program authority required to credit Level 2-5. Further, the appellant functions under technical control as is evident in the appellant’s appeal rationale in which he states “substantive review of the work is done on a periodic basis by the supervisor.”  

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 3-3 in the AAGEG, guidelines consist of standard reference material, texts, and manuals covering the application of analytical methods and techniques and instructions and manuals covering subjects involved (e.g. procedures, policies, and regulations).  Analytical methods contained in the guidelines are not always directly applicable to specific work assignments.  However, precedent studies of similar subjects are available for reference.  The employee uses judgment in choosing, interpreting, or adapting available guidelines to specific issues or subjects studied.  Level 3-3 includes work assignments in which the subject studied is covered by a wide variety of administrative regulations and procedural guidelines.  In such circumstances, the employee must use judgment in researching regulations and in determining the relationship between guidelines and organizational efficiency or program effectiveness.

At Level 3-3 in the GS-1035 PCS, guidelines consist of operating instructions, public affairs manuals, agency or local policies and regulations, and standard agency public affairs practices and precedents are readily available and generally applicable to situations encountered, although some gaps exist in specific areas.  For routine work situations, the employee independently selects, interprets, and applies the guides, modifying and adapting them to suit specific situations not directly covered by the guidelines.

The guidelines used by the appellant, and the latitude he has in working within them, match Level 3-3 in both PCSs.  The appellant’s work involves assignments for which established procedures and guidelines exist, including agency policies, regulations, and directives.  This guidance includes VHA Voluntary Service Procedures, General Post Fund Procedures, Volunteer Transportation Network Procedures, local hospital policies, etc. that drive requirements, such as the parameters for providing transportation to the veterans or the required training volunteers must have in order to complete tasks within the hospital, such as privacy act training.  These manuals provide the instructions and methods by which the volunteer service program must operate.  The appellant selects proper alternatives to efficiently carry out the work.  The appellant is responsible for being familiar with these policies and ensuring that all appropriate manuals/policies are referenced when completing a work assignment or project.  The appellant is also responsible for making recommendations to establish or modify local standard operating procedures to outline how the medical center will implement various tasks within their volunteer service program.  These procedures supplement the guidelines established in the VHA handbooks.  Guidelines are available for most situations and are generally applicable.  The same guidelines exist for his duties as VISN Liaison.

At Level 3-4 in the AAGEG, the employee uses very general guidelines and precedents.  Guidelines specific to assignments are often scarce, inapplicable, or have gaps in specificity that require considerable interpretation and/or adaptation for application to issues and problems.  The employee develops new methods and criteria, proposes new policies and practices, researches trends and patterns, and modifies, adapts, and/or refines broader guidelines.

At Level 3-4 in the GS-1035 PCS, guidelines are agency policy statements or broad precedents and are applicable in establishing a general program direction or setting a tone but not totally sufficient for dealing specifically with the more complex, intricate or unusual situations, issues or problems encountered on a recurring basis.  The employee is required to deviate from standard approaches in developing new ways to communicate the agency’s message on controversial and sensitive issues where public reaction has been negative or indifferent and understanding by agency publics of information programs is essential to success of agency mission.

Level 3-4 is not met under either PCS.  The guidelines used by the appellant are not general administrative policies with management and organizational theories requiring considerable adaptation or deviation from standard approaches to develop new ways to communicate sensitive or controversial topics.  Rather, the guidelines are fairly specific in regard to the responsibilities of the voluntary service programs and the intent of the VA Central Office regarding how the program will be implemented locally.  The guidelines provide detailed instructions for dealing with most situations, issues, or problems.  Level 3-4 contemplates substantially deviating from, or significantly changing and extending established approaches and methods.  The organizational level at which the appellant works and specificity of program goals, methods, and procedures issued from VA Central Office does not afford him the opportunity to develop new policies, practices, or guidelines, or deviate from standard approaches or methods to the extent envisioned at Level 3-4.     

Level 3-3 is credited for 275 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 in the AAGEG, work involves gathering information, identifying and analyzing issues, and developing recommendations to resolve problems with the 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 Level 4-3.  In contrast, Level 4-4 requires the application of qualitative and quantitative techniques that frequently require modification to fit a wider range of variables.  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 4-4 in the GS-1035 PCS, the work requires the application of advanced communication and analytical practices and techniques to the solution of complex public affairs problems, such as developing and presenting information material to achieve understanding of various points of view or concepts from publics with varying levels of understanding and different interests and perspectives on the subjects; employing a number of information gathering techniques in collecting and analyzing public reaction to information programs; and developing information for management in improving the agency’s communication with the general public and specialized groups.

As is typical of Level 4-4 in both PCSs, the appellant is responsible for coordinating, managing, evaluating and reporting on the effectiveness of the facility’s voluntary service program.  The appellant identifies and develops recommendations to resolve problems and sensitive issues internal to facility, such as terminating a volunteer or resolving a dispute between a volunteer and a medical center employee and/or veteran.  His decisions are based on the analysis of program requirements, expectations of customers and management, and the availability of resources.  The appellant’s work requires that he develop resolutions that are mutually beneficial to internal and external customers.  Whether it is to satisfy the information needs of the medical center employees, veteran service organizations or other community interests, or to solicit funds and volunteers, he must adapt his specific activities to meet the expectations of each group and the objectives of his presentation.  While receiving objectives from VA Central Office, he still must analyze his expected audience to determine the best approach to effect the most desirous results, and then to design and make the presentation accordingly.  He uses qualitative analytical techniques to make independent determinations of program effectiveness or productivity which information is used in annual reports on program workload, developments, and trends.  As VISN Liaison, the appellant will be responsible for compiling, reconciling, and correlating large amounts of workload data from a variety of sources and the data must be carefully cross-checked, analyzed, and interpreted to obtain accurate and relevant information.  

At Level 4-5 in the AAGEG, work consists of projects and studies requiring 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 take into account and give appropriate weight to uncertainties about the data and other variables which affect long-range program performance.

At Level 4-5 in the GS-1035 PCS, work includes the development of new methods, strategies and communication plans covering the complete spectrum of the organization’s programs.  Decisions regarding what needs to be done include evaluating the appropriateness of existing strategies and plans in the light of changes in program emphasis or content, including statutory or technological changes, and shifts in public reaction to or understanding of the programs.  The work requires developing new ways of gathering input from a variety of individuals and groups with conflicting views and interests, and developing and initiating varied approaches and strategies in communicating the agency’s objectives to groups opposed or indifferent to agency programs.

The appellant does not perform work of the complexity of Level 4-5 under either PCS. Unlike Level 4-5, his work does not require developing detailed plans, goals, and objectives for the study or the development of new analytical methods as expected of Level 4-5 work.  Rather, like Level 4-4, he determines the appropriate approach to analyze an issue or concern based on previous experience or guidelines.  Unlike Level 4-5, he does not develop new methods, strategies and communication plans covering the complete spectrum of the organization’s program.  These functions are performed in VA Central Office which is responsible for overall development of communication methods and strategies that are implemented by the medical center voluntary service programs.  Furthermore, his work does not entail dealing with the 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 the appellant’s decisions regarding how to proceed with work assignments.  Also unlike Level 4-5, the appellant does not work in an environment complicated by actions being measurable primarily in predicative terms or where findings and conclusions are highly subjective and are not readily susceptible to verification through replication of study methods or reevaluation of results.  Instead, the appellant deals with work operations within the Eastern Kansas facility and VISN 15 within the confines of program plans made at higher echelons within the VA.  Also, where this level is identified with positions which make presentations with groups opposed or indifferent to agency’s programs, the appellant’s presentations are almost always made to groups sympathetic to or which have limited knowledge of the organizations operations, goals and objectives and are open to learning about the agency’s programs.

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 that involves the evaluation of program effectiveness usually focuses on the delivery of program benefits or services at the operating level.  At this level, 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 these various echelons or locations.

Comparable to Level 5-4, the purpose of the appellant’s work is to manage the voluntary services program.  He is responsible for developing local short- and long- range plans for the accomplishment of program goals and objectives, evaluating the program, and expanding or changing the program as necessary.  He is responsible for continuously reviewing the program to ensure accomplishment of objectives, which include enhancing public awareness of volunteerism; enhancing patient care through the use of volunteers and exploring new donation opportunities.  Typical of Level 5-4, he is responsible for coordination with and participation in program work external to the VAMC and its affiliated locations.  In his new role as VISN Liaison, his intended duties are described as providing assistance and guidance to other voluntary services officers to help them accomplish their program goals.  His work affects the quantity and quality of service provided to patients, local community participation, working conditions of employees, the public image of the Eastern Kansas facility and VISN 15. 

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, for example, the development of long-range program plans, goals, objectives, and milestones, or to evaluating 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 a basis for new administrative systems, legislation, regulations, or programs.   

The appellant’s position does not meet the Level 5-5.  The appellant’s work within the Eastern Kansas facility does encompass long-range program plans, goals, and objectives.  However, the scope of this work is limited to the operating level of the voluntary service program within VA.   The scope of work identified at this level includes programs that are conducted throughout a bureau, such as the VHA, or a structure of equivalent scope.  While the VAMC is a large, complex field activity, VAMC voluntary service program controls constrain the scope and effect of the appellant’s work and do not provide the appellant the opportunity, on a regular and recurring basis, to deal with the range of issues and problems found 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.  Under the standard, each factor is evaluated separately, but a combined point credit is established by determining 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

Under personal contacts, the appellant’s contacts match Level 3, where contacts include persons outside the agency in a moderately unstructured setting.  Contacts outside the agency include business individuals and groups, educational leaders, Veteran service organizations, city officials, etc. who are interested in volunteer opportunities.

Level 4 is not met, where contacts are with high-ranking officials, such as the heads of other agencies, top Congressional staff, mayors of large cities, or executives of comparable private sector organizations.  The appellant has no contacts of this nature.

Purpose of Contacts

Under purpose of contacts, Level c is met, where contacts are to influence, motivate, and persuade individuals and groups (both internal and external) to participate in the voluntary services program.

Level d is not met, where contacts are 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.  That the appellant attends high level conferences is not determinative for this factor as contacts of the scope and authority required at Level d are not made by the appellant, but instead are made by higher level management officials within the agency.

Level 3c is credited for 180 points. 

Factor 8, Physical Demands

This factor covers the requirements and physical demands placed on the employee by the work situation.

The appellant’s position meets Level 8-1 where the work is primarily sedentary, although some light physical effort may be required.

Level 8-2 covers assignments that involve long periods of standing, bending, and stooping and also considers work operations in an industrial or comparable work area, which are not descriptive of the physical demands of the appellant’s position.  While the appellant’s position requires prolonged standing when giving presentations, such work does not occur with the frequency required for crediting Level 8-2.  Further, walking throughout the medical center, occasional lifting of items when receiving donations,  and setting up presentation equipment/peripherals does not meet the substantially greater physical demands encompassed at Level 8-2. 

Level 8-1 is credited for 5 points.

Factor 9, Work Environment

This factor considers the risks and discomforts that may be imposed on an employee in this position. 

The appellant’s position meets Level 9-1, which covers work typically performed in an adequately lighted and climate controlled office and may require occasional travel.

Level 9-2 is not met.  This level entails assignments that regularly require visits to manufacturing, storage, or other industrial areas, and involve moderate risks or discomforts.  Protective clothing, gear and observance of safety precautions are required.  The appellant’s position does not involve this type of work environment or hazards.  The appellant points to his regular travel beyond the immediate community to attend meetings, presentations, and conferences in support of a higher level for this factor.  However, occasional travel is directly addressed at Level 9-1, and more frequent travel does not match the moderate risks or discomforts described at Level 9-2.  Assuming travel between the two campuses is by automobile, the driving of a car is not properly evaluated under this factor; instead, the physical demands of driving a car are addressed under Factor 8 and properly credited at Level 8-1 in the Primary Standard.

Level 9-1 is credited for 5 points.

Summary

Factor	Level	Points
1. Knowledge Required by the Position	1-7	1250
2. Supervisory Controls	2-4	450
3. Guidelines	3-3	275
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		2615

 

The total of 2615 points falls within the GS-11 grade level point range (2355-2750 points) on the grade conversion table provided in the guide.

Decision

The appealed position is classified as GS-301-11, with the title at the discretion of the agency.

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