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Classification & Qualifications Appeal Decisions

Washington, DC

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

Kimberly A. Obranovich
Program Operations Assistant (OA)
GS-0303-6
Health Communication, Surveillance
and Research Support Branch
Pittsburgh Mining Research Division
National Institute for Occupational
Safety and Health
Centers for Disease Control and
Prevention
Department of Health and
Human Services
Bruceton, Pennsylvania
GS-0303-5
(Title at agency discretion without “OA”)
C-0303-05-29

Lakshmi Bouchard
Classification Appeals and FLSA Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance

07/12/2018


Date

As provided in section 511.612 of title 5, Code of Federal Regulations (CFR), this decision constitutes a certificate that is mandatory and binding on all administrative, certifying, payroll, disbursing, and accounting officials of the Government. The agency is responsible for reviewing its classification decisions for identical, similar, or related positions to ensure consistency with this decision.  There is no right of further appeal.  This decision is subject to discretionary review only under conditions and time limits specified in the Introduction to the Position Classification Standards (Introduction), appendix 4, section G (address provided in appendix 4, section H).

Since this decision lowers the grade of the appealed position, it is to be effective no later than the beginning of the fourth pay period after the date of this decision, as permitted by 5 CFR 511.702.  The applicable provisions of parts 351, 432, 536, and 752 of title 5 CFR must be followed in implementing the decision.  If the appellant is entitled to grade retention, the two-year retention period begins on the date this decision is implemented.  The servicing human resources office must submit a compliance report containing the corrected standard position description (SPD) reflecting the actual work assigned to and performed by the appellant and the change in the title of the appealed position as discussed in this decision and a Standard Form 50 showing the personnel actions taken.  The report must be submitted within 30 days from the effective date of the personnel actions to the Office of Personnel Management (OPM), Agency Compliance and Evaluation (ACE), Washington, DC, office.

Introduction

The appellant’s position is currently classified as Program Operations Assistant (OA), GS-0303-6.  The appellant believes the duties and responsibilities warrant upgrading to the GS-7 or reclassified to the GS-301-5/7 grade level.  The position is located in the Health Communications, Surveillance and Research Support Branch, Pittsburgh Mining Research Division (PMRD), National Institute for Occupational Safety and Health (NIOSH), Centers for Disease Control and Prevention (CDC), Department of Health and Human Services, (HHS) in Bruceton, Pennsylvania.  We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

General issues

The appellant raises concerns about the agency’s classification review process.  She alludes to classification inconsistency by stating in her appeal that most of the duties she performs are either misclassified or should be upgraded to the GS-7 grade level.  The appellant also compares her duties to a higher graded GS-7 Program Operations Assistant position at the agency.  By law, we must classify positions solely by comparing their duties and responsibilities to OPM position classification standards (PCS) and guidelines (5 U.S.C. 5106, 5107, and 5112).  In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of her position.  Because our decision sets aside all previous agency decisions, the agency’s classification review process is not germane to this decision.

Like OPM, the appellant’s agency must classify positions based on comparison to OPM standards and guidelines.  The agency also has primary responsibility for ensuring that its positions are classified consistently with OPM appeal decisions.  If the appellant considers her position so similar to higher graded positions at other CDC facilities that they all warrant the same classification, she may pursue the matter by writing to her headquarters agency human resources office.  In doing so, she should specify the precise organizational location, classification, duties, and responsibilities of the positions in question.  If the positions are found to be basically the same as hers, the agency must correct their classification to be consistent with this appeal decision.  Otherwise, the agency should explain to her the differences between her position and the others.  

The appellant believes her current SPD of record (number 08SP101564) is not completely accurate but her supervisor certified to the accuracy of the duties described in the SPD.  The appellant stated during her interview that her SPD does not describe her eClearance coordinator and NIH Manuscript Submission (NIHMS) system duties.  A SPD is the official record of the major duties and responsibilities assigned to a position by an official with the authority to assign work.  A position is the duties and responsibilities that make up the work performed by the employee.  Classification appeal regulations permit OPM to investigate or audit a position and decide an appeal based on the actual duties and responsibilities currently assigned by management and performed by the employee.  An OPM appeal decision classifies a real operating position and not simply a SPD.  This decision is based on the work currently assigned to and performed by the appellant.  

Our review disclosed the appellant’s SPD is not completely accurate in that it describes duties the appellant does not perform.  Specifically, the SPD states the incumbent provides programmatic and operational support associated with the planning and development of strategies for major projects.  However, we found the position provides only limited program support to positions that plan and develop strategies.  The SPD states the incumbent provides advice and guidance on the requirements and options for implementing projects efficiently.  However, we found that the appellant does not provide advice and guidance on the requirements and options for implementing projects efficiently. The SPD states the incumbent tracks projects and program budget proposals and documents. However, we found that the position does not maintain and track project and program budget proposals and documents. In addition, the SPD states that the incumbent assists with tracking and monitoring policy and program planning documents, operating budget and cooperative agreements and grants. On further review, we found that the incumbent does not assist with tracking and monitoring policy and program planning documents, operating budget, and cooperative agreements and grants.  Other duties such as receiving and reviewing all correspondence or draft responses to certain requests, coordinating the calendar of senior staff members, planning and arranging travel including national and international, for staff members, consultants, contractors or other special needs were not performed by the incumbent. The SPD states the incumbent plans and arranges meetings, conferences, and other gatherings that require scheduling and logistical arrangements within CDC and in off-site private or leased facilities consistent with CDC regulations and standards.  However, we found the position makes on-site logistical arrangements for gatherings as needed.  In contrast to the SPD, the position does not type a variety of documents, letters, or reports in final form and the skills of a qualified typist are not required.  The SPD states the incumbent utilizes advanced functions of several types of software to accomplish a variety of special office needs, but we note the position utilizes only the basic functions of Microsoft Excel and Word.  The position does not create data bases.  The SPD states the incumbent makes backup copies of stored data but our review disclosed it is now an automated process.  Therefore, the appellant’s SPD of record does not meet the standard of adequacy addressed on pages 11-12 of the Introduction, and the agency must revise the SPD to reflect our findings.  

Position information

Pittsburgh Mining Research Division (PMRD) focuses on mine safety and health issues such as dust monitoring and control, mine ventilation, hearing loss prevention and engineering noise controls, mine ground control, electrical safety, explosives safety, surveillance, and technology transfer.  The mission of the Health Communications, Surveillance and Research Support Branch includes collecting and analyzing health and safety data related to mining occupations and reporting on the occupational safety and health problems in mining.  Their mission also includes conducting surveillance on the use of new technology, engineering controls, and protective equipment in the mining sector; and supporting mining research through the development and application of computational tools and techniques that advance the understanding and mitigation of mining health and safety problems.

The appellant ensures the peer reviewed journal articles written by PMRD and Spokane Mining Research Division (SMRD) lead authors complete the required review processes in a timely manner and the articles become available to the general public.  After completing the research, the lead author accesses the Output Approval Process (OAP) on the Branch Management Website (BMW), which is located on their intranet’s Share Point site.  After the lead author completes the Output Data Form, the 13 step OAP begins.  The appellant receives an email notifying her of a lead author starting the OAP and tracks the progress of the article.  The steps include management officials granting approval to prepare the article, the authors drafting the article, technical editors and management officials within the division reviewing and commenting on the article, the Associate Director for Science (ADS) reviewing the approved article, technical editors from the journal in which the article will appear reviewing and commenting on the article, formatting the article, and posting the article on the NIOSH web site.  The appellant is an “owner” for two of the steps and can advance the article to the next step as needed to keep it moving through the process.  The appellant provides recommendations for improving any inefficiency in the process to the OAP coordinator as needed.

When the article completes the internal review step in the OAP, the appellant receives an email from the lead author with the article and the completed required documentation attached for her review and acceptance.  If she cannot locate missing information, she contacts the lead author and provides assistance as needed.  After she receives all of the required information, the appellant uploads it in the eClearance system and tracks the progress of the article.  The ADS reviews the article and either makes comments/revisions or approves it.  If comments/revisions are made, the ADS emails the article to the lead author, who makes the needed changes and emails the edited article to the appellant for uploading in eClearance.  After the ADS approves the article, she/he sends an email to the lead author to submit the article to the journal in which it will appear.  When it is accepted, the lead author sends a copy of the final version of the journal approved article to the appellant.  She uploads the final version of the journal approved article in eClearance, which links up to NIHMS.  The appellant adds the lead author’s name, email address, and funding information to NIHMS and tracks the progress of the article.  The lead author receives an email from NIHMS to approve the article.  The lead author confirms the funding and reviews and either approves or rejects the article for NIHMS processing.  NIHMS staff members review the article and convert the completed article to archival XML.  The lead author receives another email from NIHMS to perform a review of the article and either requests corrections or approves the article for inclusion in Pub Med Central (PMC), which is the final approval that is required to complete the NIHMS process.  After the article is finalized in NIHMS, it is cleared from eClearance and is made available in PMC following any applicable publisher required embargo period.  

The appellant serves as the eClearance and NIHMS liaison for PMRD and SMRD personnel.  She disseminates requested, updated, and new information and responds to questions from system users.  Each month the eClearance coordinator forwards the appellant a listing of eClearance submissions that are close to being over standard.  The appellant contacts the lead author for the article’s status in the process, provides assistance as needed, and responds back to the eClearance coordinator.  When an article is delayed at some point in the NIHMS process, the appellant contacts the NIHMS help desk for assistance.

The appellant is a credit card purchase holder and submits purchase requests for three of the branch’s teams, i.e., Health Communications Team, Surveillance and Statistics Team and Training Intervention Team.  Examples of purchases include office supplies, approved training costs, conference registration fees, computers and panels for exhibit displays, and tools and bolts for exhibit display assembly.  Team members submit purchase requests in the BMW and provide information such as the item to be purchased and the vendor name, address, and telephone number.  An email notification is forwarded to the team leader to review and approve the request and then the branch chief to review and approve it.  The appellant receives an email notification and reviews the request for completeness and looks up missing information as needed.  If the vendor is not on the list of approved vendors, the appellant lets the requestor know the similar items available from an approved vendor.  If the requestor insists on the non-approved vendor, he or she provides a justification to the appellant, who requests approval from the branch chief for non-routine purchases.  The appellant then inputs the required information in the Managing Accounting Credit Card System (MACCS) 1350 and an email is sent to the approver, which is based on the administrative code input by the appellant.  After she receives approval, the information in MACCS 1350 flows to MACCS and the appellant makes the purchase.  The appellant tracks the purchase until it is received by her or the requestor and reconciles her monthly credit card purchases.  

The appellant submits travel requests for the same branch teams stated above.  Team members submit their requests in the BMW and provide information based on whether or not the traveler is a Government travel card holder.  An email notification is forwarded to the appellant and she reviews the request for completeness and adherence to agency travel regulations.  If she questions something, e.g., staying at a non-Government rate hotel, the appellant discusses it with the traveler and requests a justification if needed.  After the appellant has all of the required information, she inputs it in the CONCUR system, which is the CDC’s travel approval system.  An email notification is forwarded to the branch chief to approve the request and then the Office of the Director for final approval.  The appellant accesses the system to monitor the approval process.  After the appellant receives an email notification regarding final approval, she prints a copy of the travel authorization for her files and emails a copy to the traveler.  Once the traveler returns, she or he has five days to provide the appellant all receipts and a completed travel work sheet so she can input the information in CONCUR.  An email notification is forwarded to the traveler to review the input information for accuracy before electronically signing the voucher.  An email notification is then forwarded to the budget analyst to review the information before approving the voucher.  The appellant and traveler are notified after the voucher processes through CONCUR and reaches paid status.  She prints a copy of the approved voucher for her files and emails a copy to the traveler.

The branch has hard copy and electronic filing systems.  For hard copy files, the appellant retains, makes additions, destroys, and revises files in accordance with the CDC’s records management guidelines.  For the electronic filing system, the appellant reviews, consolidates, deletes, and archives files in accordance with the standard operating procedure developed by her supervisor.

The appellant updates PMRD’s intranet Share Point site.  For example, she adds information about what to include in a travel or purchase request, updates to the OAP to include new forms or templates to use, and eClearance system updates.  The appellant also updates the Share Point calendar.  For example, she posts information on upcoming training opportunities, upcoming onsite visitors and speakers, and special events PMRD employees wish to share.  The appellant also serves as a backup for the branch’s GS-7 Program Operations Assistant who regularly performs timekeeping for branch employees and inputting travel and purchase requests for the remaining branch team employees.  However, as stipulated in the Introduction duties performed in the absence of another employee may not control the classification of a position.  

In reaching our classification decision, we carefully considered all information provided by the appellant and her agency including her official SPD which, although not completely accurate, we have incorporated by reference into this decision.  In addition, to gain more information about the actual work performed and help decide the appeal, we conducted separate telephone interviews with the appellant and the appellant’s supervisor.   

Series, title, and standard determination

The agency has classified the appellant’s position in the Miscellaneous Clerk and Assistant Series, GS-0303, but the appellant requested the position remain in the same series with an upgrade to the 7 or be reclassified to the Miscellaneous Administration and Program Series, GS-0301.  The GS-0301 series covers non-professional two-grade interval administrative positions involved in supervising or performing work for which no other series is appropriate.  The work requires analytical ability, judgment, discretion, and knowledge of a substantial body of administrative or program principles, concepts, policies, and objectives.  The one-grade interval GS-0303 series covers positions supervising or performing clerical, assistant, or technician work for which no other series is appropriate.  The work requires knowledge of the procedures and techniques involved in carrying out the work of an organization, including application of procedures and practices within the framework of established guidelines.

To decide the proper series, we must first determine whether the work performed by the appellant is one-grade interval clerical and assistance (0303) or two-grade interval administrative in nature (0301).  

Clerical work often involves 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 functional programs.

Administrative work, on the other hand, involves the exercise of analytical ability, judgment, discretion, and personal responsibility, and the application of a substantial body of knowledge of principles, concepts, and practices applicable to one or more fields of administration or management.  While these positions do not require specialized education, they do involve the type of skills (analytical, research, writing, judgment) typically gained through a college level education, or through progressively responsible experience. Administrative work may be performed as a part of the principal mission or program of an agency or subcomponent, or it can be performed as a service function which supports the agency’s mission or program.  Employees engaged in administrative work are concerned with analyzing, evaluating, modifying, and developing the basic programs, policies, and procedures which facilitate the work of Federal agencies and their programs. They apply a knowledge of administrative analysis, theory, and principles in adapting practice to the unique requirements of a particular program.

The appellants duties are consistent with one-grade interval support work as her duties involve carrying out established processes and procedures based on practical knowledge of the requirements associated with discrete functional assignments.  The appellant does this by responding to questions about the eClearance and NIHMS systems, ensuring the timely completion of articles through the various review processes, and reviewing purchase and travel requests for adherence to agency requirements.  Her work neither requires nor permits the exercise of a high order of analytical ability, comprehensive knowledge of management principles and processes, or skill in problem solving or written communication.  These responsibilities are vested in other offices within the PMRD and higher levels within the agency, e.g., those that define the requirements for the systems used for reviewing peer reviewed journal articles and issue the policies and procedures used by the appellant to review purchase and travel requests for completeness and adherence to agency regulations.  The appellant’s work does not involve analyzing cases to ascertain facts and determine the actions required, conducting research and identifying options, or preparing written products with findings and conclusions.  In contrast, her work involves the application of a limited set of methods and procedures that do not vary significantly from assignment to assignment, consistent with one-grade interval support work.

The appellant’s position is properly classified in the one-grade interval Miscellaneous Clerk and Assistant Series, GS-0303, described above.  Correspondingly, her work involves recommending improvements to the OAP coordinator to improve the efficiency of the process, requesting missing documentation, and providing information about eClearance and NIHMS to PMRD and SMRD system users.  There are no titles specified for positions in the GS-0303 series.  Agencies may construct titles for positions in this series following guidance provided in the Introduction.  Positions classified to the GS-0303 series that involve the performance of clerical or assistant work are evaluated by use of the Grade Level Guide for Clerical and Assistance Work (Guide).

The parenthetical title Office Automation (OA) used by the agency in its classification of the position is added to a title when the position requires a fully qualified typist to perform word processing duties and requires significant knowledge of office automation systems.  Our fact-finding disclosed the appellant inputs data into existing databases, but does not perform duties requiring the skills of a fully qualified typist nor requires significant knowledge of office automation systems.  Therefore, the parenthetical (OA) may not be included in the title.

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 providing information about eClearance and NIHMS to system users, updating databases, requesting missing documentation from lead authors, and compiling data from BMW for use in reports.  Her work does not involve performing the technical work of an administrative field to support the programs of the organization.  Thus, only the grade level evaluation criteria for clerical work are addressed below.

             GS-5

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.

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 adapting 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.  Often, the employee must determine which of several alternative guidelines to use.  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.

The appellant’s work assignments are consistent with the GS-5 level criteria.  Similar to this level, under general supervision she performs clerical work requiring training and a broad working knowledge of the rules, procedures, and operations of the specific programs to which she is assigned, e.g., credit card purchase holder, eClearance and NIHMS liaison, travel and training request processing, and providing OAP recommendations.  Her work includes a variety of assignments involving different and unrelated processes, such as purchasing exhibit display assembly equipment and office supplies, updating databases, tracking articles through the various review processes, providing recommendations to improve OAP efficiency, and inputting travel.  Her work involves performing a full range of both standard and non-standard clerical assignments where she must understand the issues involved and determine the steps and procedures to be followed.  For example, her credit card purchases of exhibit display assembly equipment and office supplies is a standard clerical assignment because the work is basically repetitive and involves carrying out the same steps without variation, e.g., creating a requisition in the MACCS 1350 and waiting for a purchase approval.  However, the work does require working knowledge of the MACCS system used by credit card purchase holders to be able to perform such non-standard clerical assignments as running a query in MACCS on a previous months’ purchases to reconcile them against those on her list of credit card purchases for that month.  The appellant’s work trying to improve the OAP requires a working knowledge of the OAP in order to recommend improvements to the efficiency of its required steps.  For example, all peer reviewed journal articles require an ADS review through the eClearance system before being reviewed by technical editors for the journal to which the article will be published.  However, the appellant found out the ADS review was not being performed and she recommended a step be added to the OAP requiring an ADS review through eClearance.  The OAP coordinator approved the recommendation and added a step 5 to the OAP.

The appellant’s level of responsibility is likewise comparable to the GS-5 criteria in that the objectives, priorities, and deadlines of the work are established.  The appellant works in accordance with established procedures for recurring work, such as creating requisitions in MACCS 1350 and CONCUR.  Her work requires the use of a variety of guides such as standard operating procedures for the OAP, eClearance, and NIHMS, PMRD procedures, CDC records management guidelines, HHS Travel Policy Manual, HHS Purchase Card Program Guide, CDC Purchase Card Manual, and the General Services Administration Government purchase card policy.  Like this level, the number and similarity of the guidelines require the appellant to select the most appropriate guidelines for application and adaptation to the matter at hand, e.g., she researches questions on per diem rates or reimbursable expenses in HHS’ travel policy and tracks peer reviewed journal articles to ensure they complete the review processes in a timely manner.  She has direct contact with the staff she supports as well as purchase vendors for the purpose of receiving and/or providing work related information, e.g., providing the procedures for requesting travel and purchases, updates to the OAP to include new forms or templates to use, and following up on the status of purchase requests.

             GS-6

At this grade level, the guide provides separate evaluation criteria for clerical and assistance work as defined earlier.  The appellant’s work is clerical in nature because, corresponding to the definition for clerical work, it primarily involves such work as creating requisitions in MACCS and CONCUR; retaining required documents on file; and updating PMRD’s intranet Share Point site.  It does not involve performing technical work within an administrative field to support the programs of the organization.  Thus, only the grade level criteria for clerical work are addressed below.

Nature of Assignment

GS-6 level clerical 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, knowledge of which 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.  

Level of Responsibility

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 where there are no clear precedents, usually extending beyond the immediate office to 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 on short notice.  Guidelines for 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.  They often do not apply directly so the employee must adapt guidelines as needed to cover new and unusual work situations and deviate from established procedures to process transactions which cannot be completed through regular channels.  Contacts are with employees in the agency, in other agencies, or with management or users or provides of agency services.  The employee provides information, explains the application of regulations, or resolves problems relating to the assignment.

The appellant’s assignments do not meet the GS-6 level.  While the appellant uses different procedures to process standard and nonstandard assignments including creating requisitions in MACCS and CONCUR, updating PMRD’s intranet Share Point site, and serving as a liaison between the eClearance coordinator and NIHMS help desk personnel and PMRD and SMRD lead authors, unlike the GS-6 level this work does not require comprehensive knowledge of rules and regulations which are usually attained through practical experience and training in the subject matter field.  Instead, it involves applying established procedures to process standard and nonstandard transactions and update data bases.

In terms of the level of responsibility associated with this work, the appellant is considered the subject matter expert on the eClearance and NIHMS systems.  However, unlike the GS-6 level, her assignments do not routinely require dealing with complicated transactions that are often without precedent.  While she communicates with vendors and PMRD and SMRD personnel, it is to exchange information as opposed to providing advice on regulatory requirements as discussed at the GS-6 grade level.  Unlike the GS-6 level, her work is repetitive and issues can be resolved by locating and applying the most appropriate guideline to the circumstances of the specific case.  Her work does not routinely require or permit her to deviate from established procedures or deal with actions where guidelines are conflicting or unusable.  Problems of this nature are discussed with her supervisor or Director’s Office personnel for resolution. Further, the appellants’ work does not require her to be an expert source of information on regulatory requirements to process transactions, nor does it involve selecting from numerous guidelines the most appropriate one for application and adaptation to the matter at hand.  

Decision

The proper series and grade of the appellant’s position is GS-0303-5.  Selection of an appropriate title is at the agency’s discretion.

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