Washington, DC

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

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Robert D. Hendler
Classification and Pay Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance


12/30/2014

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Date

Introduction

On July 28, 2014, OPM’s Dallas Agency Compliance and Evaluation accepted a classification appeal from Ms. Donna J. Berry.  The appellant’s position is currently classified as Program Support Assistant (OA), GS-303-6, but she believes it should be classified at the GS-7 grade level.  The position is assigned to the Soil and Moisture Conservation Unit (Unit); Natural Resources Branch; Deputy Superintendent, Trust Services; Anadarko Agency (Agency); Southern Plains Region; Bureau of Indian Affairs; U.S. Department of the Interior; in Anadarko, Oklahoma.  We received the complete agency’s administrative report on August 29, 2014.  We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

Background and general issues

On June 11, 2014, the servicing human resources (HR) office reviewed the work performed under the appellant’s official PD, number 4600059.  The HR office determined the position was appropriately classified as GS-303-6.

The appellant subsequently filed a classification appeal with OPM, communicating various concerns regarding the agency’s evaluation.  For example, she said the agency classifier conducted what she considers an “investigation” as various staff members were interviewed as part of the position evaluation.  In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of the appellant’s position.  Because our decision sets aside all previous agency decisions, any concerns regarding how the agency evaluated the classification of her position are not germane to this decision.

Regarding the appellant’s assertions that she had been assigned higher-graded duties by previous management officials, the HR office’s June 11, 2014, position evaluation states:

In my opinion the incumbent’s extra duties are a result of her own independent initiative.  She was not directed by any Realty staff to perform these extra duties, and a lack of oversight by the Soil Conservation management has resulted in [the appellant] performing inherently Realty, and Soil Conservation Technician duties in the absence of senior staff on her own without being directly instructed to do so.

The appellant disagrees with the agency’s statements, explaining in her appeal request to OPM:

…I have had numerous (Acting) Supervisors, as well as the previous “Superintendent” who is no longer at the facility, whose name is [name], and Vice Superintendent, [name], also no longer at the facility, who each gave me some of these higher level assignments.  Therefore, I don’t remember which of my Previous Supervisors, Acting supervisors, Superintendent or Vice Superintendent, specifically assigned to me, in regards to higher level duties.  I usually perform my assignments to the best of my ability without questioning or documenting who or why it was assigned to me….I just did the assignments that I was given so that I would not be deemed insubordinate.

By law (5 U.S.C. 302 and 5102(a)(3)), agency management has the right to establish positions and determine the work assignable to each position.  Also see 5 U.S.C. 7106 with regard to organizational situations under chapter 71 of title 5, U.S.C.  Actions concerning the assignment and removal of work, which the appellant said occurred subsequent to the HR office’s classification evaluation, are not reviewable under the classification appeals process.

The appellant, through interviews and written responses provided by her to OPM, states she performs a variety of duties that we are unable to confirm by a review of her official PD or by interviews with her first-level supervisor, who has occupied the supervisory position since August 2014 but has been assigned to the appellant’s Unit since 2007.  For example, the appellant mentions she works with landowners to develop, implement, maintain, and revise conservation plans; however, the first-level supervisor confirms this responsibility rests solely with the Unit’s soil conservationists.

The appellant states she performs realty-related duties, also unsupportable by a review of her official PD or statements by her first-level supervisor.  Since the Agency’s Deputy Superintendent position (the second-level supervisor) is vacant and the individual occupying the Superintendent position (the third-level supervisor) is currently serving in an acting capacity, we interviewed the Realty Officer of the Agency’s Realty Branch for additional information.  Although occupying the position since September 2014, the Realty Officer said she served intermittently for the past two years in an acting capacity for the position she now encumbers.  The Realty Officer verified the appellant currently performs the realty-related support work we considered for classification purposes and detailed under the PD section of this decision.

The appellant specifically states she prepares cancellation clauses for contracts, proceeds with advertisement of tracts, negotiates for leasing activity, and calculates the fee and estate interest on lease contracts.  According to the Realty Officer, this work is the Realty Branch’s responsibility and specifically she, not the appellant, prepares cancellation letters for contracts and also that the fee and estate interest for a lease contract is automatically generated by the land lease database.

In addition, the appellant mentions she assisted the Realty Branch with mailing out 90-day notices of renewal.  The Realty Officer said that since an estimated 9,000 renewal notices were issued earlier this year, the branch requested Agency-wide volunteers, like the appellant, to assist for two to three days by preparing letters to be mailed.  The appellant also states she “encodes” lease contracts.  The Realty Officer said this work, spanning a three- to four-day period, entailed entering fields into the land lease database from advertised bid sales sheets to include the lease number provided by the Realty Branch, name, address, contract date, and bonding information.  However, this and other duties mentioned by the appellant (e.g., preparing the first-level supervisor’s travel orders to attend supervisory training) that are not regular and recurring cannot affect the grade of a position (Introduction, section III.F.2).  Only duties occupying at least 25 percent of an employee’s time can affect the grade of a position (Introduction, section III.J).  Therefore, we will not evaluate the appellant’s past, minor, and/or volunteer duties in this decision.

Under 5 U.S.C. 5112, we can only consider current duties and responsibilities in classifying positions.  Our analysis will focus on the current work performed by the appellant based on the entire record, including information obtained from telephone interviews with the appellant and immediate supervisor.  Regardless, the assigning of more or different work does not necessarily mean that the additional work is more difficult and complex.  Each grade level represents a band of difficulty and responsibility.  Performing more difficult work than previously performed may still continue to fit within and support the same grade level previously credited to the position.

The appellant states her position has been assigned to various performance appraisal plans indicating assignment on the cover page to a position classification different from her official position; for example, her recent performance plan shows assignment to an (OA) GS-318-7 position.  Thus, she concludes she is performing duties similar to positions classifiable to the grade specified on her performance plan.  However, performance appraisal plans are not official classification documents and are not germane to the position classification process.  By law, we must make our own classification decisions 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).  Therefore, we may not classify the appellant’s position by comparison to other positions which may or may not be classified properly.  Consequently, we based this appeal decision on the current duties and responsibilities assigned by management to the appellant’s position and performed by her.

Position information

The mission of the Agency is to provide services to American Indian tribes and individuals while managing and protecting trust resources, enhancing the quality of life and supporting tribal sovereignty, and promoting self-determination and economic development opportunities.  The Agency provides services to an estimated 29,000 members of the seven Federally-recognized tribes under its jurisdiction, i.e., the Apache Tribe, Fort Sill Apache Tribe, Wichita and affiliated Tribes, Caddo Nation, Comanche Nation, Delaware Nation, and Kiowa Nation.

The Natural Resources Branch provides technical assistance and advice to the American Indian people and Bureau officials in the development and implementation of resource management programs designed to produce income for American Indian landowners while protecting resources against waste and deterioration.  According to the first-level supervisor, the Unit is expected to fill numerous vacancies in the near future but is currently staffed with, in addition to his (a GS-457-12 Supervisory Soil Conservationist) and the appellant’s positions, two GS-457 soil conservationist positions and one GS-817 survey technician position.  The Unit is responsible for the management of an estimated 4,000 properties.

The appellant’s position performs clerical and administrative support work for the Unit in the form of taking messages, reviewing correspondence and requests for services, communicating readily available information, data encoding, maintaining databases, records maintenance, and mail routing.

The appellant is often the only individual physically in the office as the goal of the other Unit staff, according to the first-level supervisor, is to perform field work four days out of the workweek.  Her work includes performing receptionist duties by receiving incoming telephone calls, walk-in clients and customers, and requests for Unit services from Agency staff assigned to other branches, landowners, and others.  When screening incoming inquiries, telephone calls, and requests, the appellant obtains subject matter information in sufficient detail to direct the call, individual, or correspondence to the appropriate office or individual.  She receives, reviews, and forwards requests for inspections, surveys, trespass, and other services from the Unit.  Requests regularly do not include the legal description which is used to fix or identify the boundary and placement of the property.  To obtain the legal description, the appellant queries the requestor to identify the property by county, section, township, and range.  She also reviews requests to ensure the requestor has the legal right to request the service and that the request and supplemental documentation are accurate and complete prior to retrieving the property file to accompany the request and forwarding the request to the appropriate Unit staff.  She communicates with landowners, lessees, beneficiaries, and others regarding the requests for services, documentation required when making such requests, the range of value (appraisals), and other general questions.

In addition, the appellant performs records and database maintenance work.  For example, she scans and saves completed farm plans and other documents to a shared drive and files the hard copy to the appropriate property folder.  She utilizes and maintains the Trust Asset and Accounting Management System (TAAMS), the Department’s land lease database to establish, track, and manage leases of Indian assets.  She maintains a spreadsheet of the status of an estimated 1,900 current leases, tracking and identifying the properties up for renewal.

The appellant performs work in support of the bid sales of properties, which are conducted a minimum of twice annually by staff of the Realty Branch.  This work includes, but is not limited to, identifying and preparing the list of tracts up for lease, scanning farm plans and appraisals to a shared drive accessible to both Unit and realty staff, and attending sales to record bidder and sale information for the Unit’s internal records.

The first-level supervisor certified to the accuracy of the duties described in the appellant’s official PD.  In the appeal request to OPM, the appellant asserts her current PD does not describe the duties she performs accurately and instead provides a revised PD.  Her rationale points to the description of work in the modified PD, which suggests the official PD be changed to:  (1) state the position supports the Agency’s Realty Branch; (2) add generic narratives regarding how work is performed, complexity of the work, and the discretion in which the position operates (e.g., the revised PD states the position performs work of “considerable difficulty and responsibility along specialized technical lines in office and business administration requiring considerable specialized training or experience and a comprehensive working knowledge of special and complex subject matter, procedures, and practice,” that the “[w]ork consists of technical duties with continuing responsibility for projects, questions, or problems that arise within the program,” and “[w]ork assignments involve a wide variety of problems or situations for which the incumbent is responsible.”); (3) detail the identification of properties by legal description, reviewing requests for completeness of documentation, and other duties; and (4) cite duties such as making recommendations for contract approval or disapproval for renewals and working with land titles and records offices to determine ownership to authorize distribution of funds.

We find the proposed changes to the content of the official PD are not warranted.  For example, the organizational charts and our interviews confirm the appellant’s position, although performing bid sales work in support of the Realty Branch, is officially assigned to the Unit as noted by the PD.  Moreover, a PD does not have to be a comprehensive and detailed narrative of the position’s duties and responsibilities; thus, her official PD does not require the addition of generic narratives concerning the complexity, the supervision provided, and other aspects of the work to be considered accurate.  The modified PD also details her review of service requests for accuracy and completeness, identification of legal description, and other duties; however, we find the official PD already describes duties such as providing accurate information or assistance, screening incoming correspondence, assembling required supplemental material, and other such work relating to that detailed by the revised PD.  Furthermore, our interviews confirm the appellant’s position is not responsible for making recommendations for contract approval or disapproval or authorizing the distribution of funds as suggested by the revised PD.

Under the General Schedule position classification system, major duties are those occupying a significant portion of the employee’s time.  They should be only those duties currently assigned, observable, identified with the position’s purpose and organization, and expected to continue or recur on a regular basis over a period of time.  Overall, we find the appellant’s PD is adequate for classification purposes, and we incorporate it by reference into this decision.  However, the PD includes duties such as making purchases for the Unit, ensuring the requests, documents, and accounting information are proper and accurately maintained.  Though she completed training, the appellant is not yet, but expected to soon be, performing purchasing work.  If she does not perform the purchasing work as anticipated, the PD should be rewritten to remove the duties not being performed to meet the standards of PD accuracy for classification purposes.

To help decide this appeal, we conducted telephone audits with the appellant on October 9 and November 20, 2014, and telephone interviews with the immediate supervisor on October 15 and November 18, 2014.  In addition, we conducted a telephone interview with the Agency’s Realty Officer on November 20, 2014.  In reaching our classification decision, we carefully considered all of the information gained from these interviews, as well as the written information furnished by the appellant and her agency.

Series, title, and standard determination

The agency assigned the appellant’s position to the GS-303 Miscellaneous Clerk and Assistant Series and applied the grading criteria in the Grade Level Guide for Clerical and Assistance Work (Guide).  The appellant does not disagree and, after careful review of the record, we concur.

The GS-303 series does not have published titles, and the agency may assign a title following the guidance in the Introduction.  The agency added the OA parenthetical to the basic title.  This designation is appropriate when positions require (1) knowledge of general automation software, practices, and procedures; (2) competitive level proficiency in typing; and (3) ability to apply the knowledge and skills in the performance of general office support work.  Although the appellant certifies to having competitive-level typing proficiency, the first-level supervisor states the appealed position does not require the incumbent to type 40 words per minute.  The record and our interviews confirm her work requires typing skills sufficient to prepare email correspondence, populate data into Excel-based spreadsheets and logs, create file labels, and other such office support work which do not reflect the need for or application of the skill to type 40 words per minute.  Thus, the addition of the OA parenthetical to the basic title determined by the agency is not warranted.

Grade determination

The Guide provides general criteria for use in determining the grade level of nonsupervisory clerical and assistance work.  Administrative support work of the kind described in the Guide is performed in the offices, hospitals, and numerous other settings in Federal agencies.  The Guide describes the general characteristics of each grade level from GS-1 through GS-7, and uses the following two criteria for grading purposes:  Nature of Assignment (which includes knowledge required and complexity of the work) and Level of Responsibility (which includes supervisory controls, guidelines, and contacts).

The Guide provides separate evaluation criteria for clerical and assistance work.  The term “clerical” is defined as performing work such as preparing, receiving, reviewing, and verifying documents; maintaining office records; locating and compiling data or information from files; compiling information for reports; keeping a calendar and informing others of deadlines and other important dates; and similar clerical support work within an organization.  This work requires knowledge of the clerical requirements and processes involved in maintaining the functional programs of the unit.  “Assistance” is defined as performing technical work to support the administration or operation of the programs of an organizational unit.  This work requires working knowledge of the work processes and procedures of an administrative field (e.g., office administration, communications, and security) and the missions and operational requirements of the unit.

For the purpose of applying the Guide, the appellant’s work is clerical in nature involving such work as filing and retaining required documents on file, maintaining and retrieving information from databases, and receiving and reviewing documents.  Her work does not involve performing the technical work of an administrative field to support the programs of an organization.  Thus, only the grade level criteria for clerical work will be addressed below.

Nature of Assignment

At the GS-5 level, work consists of performing a full range of standard and non-standard clerical assignments and resolving a variety of non-recurring problems.  Work includes a variety of assignments involving different and unrelated steps, processes, or methods.  The employee must identify and understand the issues involved in each assignment and determine what steps and procedures are necessary and the order of their performance.  Completion of each transaction typically involves selecting a course of action from a number of possibilities.  The work requires extensive knowledge of an organization’s rules, procedures, operations, or business practices to perform the more complex, interrelated, or one-of-a-kind clerical processing procedures.

At the GS-6 level, work typically entails processing a wide variety of transactions for more than one type of assigned activity or functional specialization. Assignments are subject to different sets of rules, regulations, and procedures.  Such issues must be examined that a course of action has substantive impact on the outcome of the assignment.  Work requires comprehensive knowledge of rules, regulations, and other guidelines relating to completing assignments in the program area assigned.  This knowledge is usually attained through extensive, increasingly difficult, and practical experience and training in the subject matter field.  The work also requires ability to interpret and apply regulatory and procedural requirements to process unusually difficult and complicated transactions.

The appellant’s work assignments meet the GS-5 level criteria.  Similar to this level, she performs, under general supervision, responsible standard and non-standard clerical assignments which require applying a broad working knowledge of the rules, procedures, and operations of the Unit.  Her work includes a variety of assignments involving different and unrelated processes such as updating logs and spreadsheets, maintaining databases, receiving and reviewing service requests, and filing and retaining records.  Each transaction involves selecting a course of action from a number of possibilities.  As at the GS-5 level, the appellant’s work involves performing a full range of clerical assignments where she must understand the issues involved and determine the steps and procedures to be followed.  For example, the filing and disposing of records would be considered standard clerical assignments as the work is basically repetitive and involves carrying out the same steps without variation, e.g., she ensures the property folder contains appropriate documents and in the proper order; the folder is maintained in the drawer by allotment number, name, and other descriptors; and records are properly identified and disposed of when necessary or prepared for transfer to the records repository if necessary.

Similar to the GS-5 level, the appellant’s assignments require working knowledge of TAAMS to perform nonstandard clerical assignments such as querying the system to respond to landowner, lessee, and other customer requests for information on land description, agreed upon property improvements, acreage, etc.  She reviews farm plans and other reports to ensure accuracy of data, for example, that the acreage of crop land, pasture, roads, highways, and other features add up appropriately to the total acreage reported.  The appellant receives, reviews, and forwards survey, inspection, trespass, and other requests for services to the appropriate Unit staff within established timeframes.  Each request differs in terms of its information or documentation requirements, and she must understand requests sufficiently to ensure completeness and accuracy of legal description and other information and also to confirm the purpose of the request (e.g., a survey request must identify whether the landowner is requesting a gift deed application, survey boundary for fencing, or the marking of boundary lines).  The appellant’s work requires extensive knowledge of the Unit’s rules, procedures, operations, or business practices to perform the more complex, interrelated, or one-of-a-kind clerical processing procedures characteristic of the GS-5 level.

A GS-5 work example provided in the Guide describes an Inspectional Aid who provides specialized clerical assistance by controlling inbound manifests for air and sea cargo and inbound storage and performs such duties as:  controlling manifested cargo by posting a variety of entry permits and other clearance documents against corresponding bills of lading; examining documents for completeness, discrepancies, sampling requirements, prohibited cargo, and other special requirements and identifying entries that may involve fraud, smuggling, etc., based on available intelligence data; authorizing lay order extensions, obtaining general order control numbers, resolving manifest and entry discrepancies, and preparing official and office workload reports for the inspection facility; and maintaining office files, inventorying nonexpendable equipment, preparing supply requisitions, accepting cash, and preparing daily cash transmittals.  The employee independently plans and carries out successive steps according to specific requirements of each case.  Contacts are to exchange information and resolve problems.

The appellant’s position is analogous to the GS-5 work example described in terms of the procedural and processing functions she carries out.  Equivalent to this example, she receives incoming documents, examines them for completeness and discrepancies, and maintains paper and electronic files.  The appellant extracts data from TAAMS and other sources to meet reporting requirements.  She supports the Unit’s planning for conduct of inspections, farm plans, and other activities by compiling and/or providing weekly, quarterly, or as needed reports on properties.  She tracks the current leasing status for a five-year cycle, recording the number of properties negotiated and advertised, the money generated by tribes, total acres, crop acres, pastured acres, and allotment number.  She assists realty staff by confirming the list of properties identified for bid sales.  The appellant reviews service requests to ensure documents include complete and accurate information.  Requests often require she identify a property’s legal description based on minimal information provided by the requestor.  Typical of GS-5 level procedural functions, the appellant also retires inactive records by the end of the year and ensures the appropriate disposal of reference materials, duplicate documents, and other non-records materials.

The appellant’s work assignments do not meet the GS-6 level criteria.  She performs clerical, receptionist, and office support activities for the Unit and its staff, which do not require the considerable evaluative judgment found at the GS-6 level.  Assignments at the GS-6 level involve processing a wide variety of transactions using different rules, regulations, and procedures where the work requires extensive practical experience and training in the subject matter field and the ability to interpret and apply regulatory and procedural requirements to process unusually difficult and complicated transactions.  The appellant’s work, in considering the evaluative judgment required, does not involve or permit her to examine the issues involved in a given transaction or task to determine the best course of action.  Instead, the work involves carrying out the same or similar basic steps for each task as governed by established procedures.  Her work involves applying established policies and procedures to receive and review requests for services, control the filing system and storage, manage incoming and outgoing mail services, and resolve other issues arising during the course of daily operations.  The appellant’s work requires, in addition to proficiency with Excel spreadsheets, knowledge of program functions and requirements, the Bureau’s records management systems and policies including file maintenance and disposition, and effective filing systems for records.  The narrow range of the appellant’s work does not require either a comprehensive knowledge of rules, regulations, and other guidelines relating to completing assignments in the assigned program or that she interpret the rules, regulations, and procedures for the purpose of seeking alternative solutions to issues as found at the GS-6 level.

Furthermore, most of the appellant’s work involves recurring processes and procedures with her actions repetitive in terms of the procedures to be applied and problems to be handled with each task.  For example, her work involves ensuring property files include notations of significant events; contain current and previous approved contracts, farm plans, inspections, conservation work prescriptions, drawings, and correspondence; and follow the established instructions and order prescribed for records maintenance.  After reviewing farm plans and appraisals, the appellant scans and saves documents to the shared drive for use by Unit and realty staff.  Her work also requires using standard database software to complete reporting-related tasks and mapping software to retrieve aerial photos of a property if requested by the landowner or others.  Unlike the GS-6 level where deciding on a course of action has substantive impact on the outcome of the work, her assignments affect the completeness and accuracy of service requests, reporting and records maintenance requirements, and the Unit’s other procedural-related issues.  The decisions she makes associated with this work are based on records, databases, instructions, and other readily available information.  In contrast to the GS-6 level, precedents and operating procedures are available, and the appellant’s assignments usually involve problems or situations following either precedents or operating procedures where there is only one correct solution (e.g., receive and review service requests, maintain files, manage incoming and outgoing mail, and track current leasing status by applying established procedures).

A GS-6 work example provided in the Guide describes a Reports and Financial Assistant who runs a statistical reporting and record system for a major division of a regional office, which includes analyzing feeder reports from various branches and units; preparing division-wide reports; designing detailed charts and graphs; and conducting special management studies requiring written presentation of findings, recommendations, forecasts, and justifications.  The employee also reviews work measurement functions for the division to ensure that basic reporting requirements and procedures are being followed and that reports provide clear and concise information; analyzes data to determine and evaluate results, trends, and developments; and writes instructions as needed to implement changes in reporting procedures.  The appellant’s work is not analogous to the GS-6 work example of running a statistical reporting and records system in that the processes she is involved in are considerably more limited.  In the example, the incoming documents are not merely input into a system and tracked; they are reviewed and analyzed for results, trends, inaccuracies, or anomalies and used to generate consolidated reports, charts, and graphs.  In other words, the employee in this example has a substantive role in reviewing and analyzing the documents rather than the appellant’s transactional role in reviewing and forwarding requests to the appropriate Unit staff.

This factor is properly evaluated at the GS-5 level.

Level of Responsibility

At the GS-5 level, the supervisor assigns work by defining objectives, priorities, and deadlines and provides guidance on assignments which do not have clear precedents.  The employee works in accordance with accepted practices and completed work is evaluated for technical soundness, appropriateness, and effectiveness in meeting goals.  Extensive guides in the form of instructions, manuals, regulations, and precedents apply to the work.  The number and similarity of guidelines and work situations require the employee to use judgment in locating and selecting the most appropriate guidelines for application and updating them according to circumstances of the specific case or transaction.  A number of procedural problems may arise which also require interpretation and adaptation of established guides.  Contacts are with a variety of persons within and outside the agency for the purpose of receiving or providing information relating to the work or resolving operating problems in connection with recurring responsibilities.

At the GS-6 level, the supervisor reviews completed work for conformance with policy and requirements.  The employee is recognized as an authority on processing transactions or completing assignments within a complicated framework of established procedures and guidelines, often when there are no clear precedents.  This recognition typically extends beyond the immediate office or work unit to the overall organization or, in some cases, outside the organization.  The employee is regarded as an expert source of information on regulatory requirements for the various transactions, and is frequently called upon to provide accurate information rapidly on short notice.  Guidelines for the work are numerous and varied, making it difficult for the employee to choose the most appropriate instruction and decide how the various transactions are to be completed.  Guidelines often do not apply directly, requiring the employee to make adaptations to cover new and unusual work situations.  This may involve deviating from established procedures to process transactions which cannot be completed through regular channels or involve actions where guidelines are conflicting or unusable.  Contacts are with employees in the agency, in other agencies, or with management or users or providers of agency services.  The employee provides information, explains the application of regulations, or resolves problems relating to the assignment.

The appellant’s level of responsibility is characteristic of the GS-5 level in that the objectives, priorities, and deadlines of her work are established.  She independently manages and carries out successive steps of the day-to-day activities according to established policies or procedures for maintenance and disposal of records, receipt and review of requests for services, and other recurring work.  Her work requires applying TAAMS, legal description, and other handbooks, in addition to the procedural-related Federal, State, and tribal guidelines on farming, grazing, trespass, and other Unit-related issues.  The guidelines require selecting the most appropriate one for application and adaptation to the matter at hand.  The appellant is expected to respond, within one to two days, to requests and inquiries from landowners, tenants, and the general public made by phone, face-to-face, email, or formal correspondence.  She has direct contact with the Unit and Agency’s realty staff, the general public, and others for the purpose of exchanging work-related information, requesting missing documentation, providing status of service requests, and resolving problems associated with the Unit’s day-to-day operations.  Similar to the GS-5 level, the supervisor confirms he reviews the appellant’s completed work in terms of customer service, timeliness, accuracy (e.g., the files are labeled, maintained, and organized correctly), and accomplishment of work objectives.

In terms of the level of responsibility associated with the work, the appellant is not recognized as an authority on processing transactions within a complicated framework of established procedures, nor is she regarded as an expert source of information on the regulatory requirements governing the work.  Unlike the GS-6 level, the processes she carries out are relatively uncomplicated and are governed by a limited set of administrative procedures rather than by regulatory requirements that she must interpret and apply (e.g., she reviews the Unit’s service requests for the limited purpose of ensuring the format is followed and includes required information prior to forwarding to the appropriate staff).  She verifies the legal description, landowner name, allotment number, and other information when reviewing inspection, survey, trespass, and other requests.  In addition, the appellant’s work requires updating records regarding the current leasing status for the purpose of the Unit staff’s planning of annual inspections, farm plans, and other work.  She updates files with the completed inspection form, farm plan, correspondence, photo, and other required documents.  This work represents a limited portion of the Unit’s overall functions.  Carrying out these limited processes does not provide the framework wherein the appellant would be providing authoritative information or expertise to others on how the work must be accomplished, e.g., explaining how a particular transaction must be handled or what regulations apply to a given situation, as expected at the GS-6 level.

In contrast to the GS-6 level, the appellant does not work with numerous and varied guidelines from which it is difficult to choose the most appropriate instruction and decide how the various requests and other actions are to be completed.  The parameters of her work are well defined in that she is not authorized to deviate from established procedures unless instructed.  Although she works independently, the appellant carries out a structured set of processes with limited opportunity for the application of any independent judgment or action.  Her work does not routinely require or permit her to deviate from established procedures or deal with actions where guidelines are unusable or conflicting.  Problems of this nature would be referred to the supervisor for resolution, who provides guidance on issues without clear precedent; for example, she refers questions to him and others if she is unable to respond to an inquiry after reviewing TAAMS, the property file, and other readily available resources.  Thus, the appellant’s position does not involve the range of case actions and advisory issues intended at the GS-6 level.

This factor is properly evaluated at the GS-5 level.

Summary

Since both factors are evaluated at the GS-5 level, the position is properly evaluated at the GS-5 level.

Decision

The appellant’s position is properly classified as GS-303-5.  The position title is at the agency’s discretion.

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