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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

[appellant's name]
Administrative Support Technician
GS-303-7
[Appellant’s organization/work location]
National Guard Bureau
Department of Defense
GS-303-6
(Title at agency discretion)
C-0303-06-17

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

07/25/2013


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, Code of Federal Regulations, 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 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 Agency Compliance and Evaluation, San Francisco Office. 

Decision sent to:

[Mailing address of appellant’s representative]

[Address of appellant’s servicing human resources office]

 

Chief, Office of Technician Personnel

National Guard Bureau

NGB-J1-TN

1411 Jefferson Davis Highway, Suite 9100

Arlington, VA 22202-3231

 

Chief, Position Management and Classification Branch

National Guard Bureau

NGB-JI-TN

1411 Jefferson Davis Highway, Suite 9100

Arlington, VA  22202-3231

 

Chief, Classification Appeals Adjudication Section

Department of Defense

Defense Civilian Personnel Advisory Service

4800 Mark Center Drive, Suite 05G21

Alexandria, VA  22311

Introduction

On June 27, 2012, the U.S. Office of Personnel Management’s (OPM) Atlanta Oversight accepted a classification appeal from [name of appellant].  On October 24, 2012, we received the complete agency administrative report (AAR).  On November 13, 2012, the appeal was transferred to San Francisco Oversight (now Agency Compliance and Evaluation, San Francisco) for adjudication.  The appellant’s position is currently classified as an Administrative Support Technician, GS-303-7.  However, he believes it should be classified as a Support Services Specialist, GS-342-9.  The appellant works for the [appellant’s organization/work location], National Guard Bureau (NGB), Department of Defense (DOD).  We have accepted and decided this appeal under section 5112(b) of title 5, United States Code (U.S.C.).

General issues

The appellant makes various statements about the classification review process conducted by his agency, the staffing and classification of his position when announced, and compares his duties to higher graded positions classified as Support Services Specialist, GS-342-9, at other locations in his agency.  In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of his position.  By law, we must make that decision solely by comparing his current duties and responsibilities to OPM standards and guidelines (5 U.S.C. 5106, 5107, and 5112).  Since comparison to standards is the exclusive method for classifying positions, we cannot compare the appellant’s position to others that may or may not be properly classified, as a basis for deciding his appeal.  Because our decision sets aside any previous agency decision, the classification practices used by the appellant’s agency in classifying his position, as well as how his position was staffed, are not germane to the classification appeal process.  

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. 

Position information

Both the appellant and his immediate supervisor (Supervisory Management Analyst, GS-343-12) have certified to the accuracy of the appellant’s official position description (PD) [number].  However, our review disclosed the appellant’s PD incorrectly identifies his work location and describes duties he no longer performs or has never performed.  The appellant’s position is not located in the Base Systems Flight of an Air National Guard Combat Communications Squadron, and he no longer provides master-task training to all unit information management personnel as stated in the first paragraph of his PD.  In addition, the appellant does not perform the following functions described in various paragraphs of his PD.  He does not (1) serve as Unit Web Master or liaison; (2) monitor the training programs for all assigned support services personnel; (3) assist in a variety of military transactions including appointments, enlistments, separations, etc.; (4) perform work related to unit mobility requirements; (5) generate complex queries and reports; (6) serve as unit Security Manager or alternate; (7) prepare correspondence, reports and requests for full time personnel actions; (8) establish and maintain a records staging area for the base; (9) plan, organize, direct, and coordinate Customer Support functions; (10) serve as a point-of-contact for services (food, billeting); (11) perform duties as unit awards monitor or alternate; (12) coordinate physical exams, immunizations and mobility medical requirements with support medical facilities; or (13) procure, store, and issue office supplies and equipment through well established sources.  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. 

The appellant supports the [appellant’s unit] by performing administrative support activities for the organization and the Commander.  The mission of the [appellant’s unit] is to provide planning, reconnaissance of targets, weapons selection and the final control of an air strike to neutralize the target without friendly casualties.  The appellant’s duties and responsibilities primarily fall into two main areas:  computer systems support, and records and information management. 

The appellant is assigned as Work Group Manager (WGM) and acts as liaison for computer related needs between his unit and the Host Base Network Control Center (BNCC) located at the Host Communication Flight squadron.  He is responsible for setting up computers including installing/deleting user software, and configuring user software to establish individual profiles and permissions after ensuring the user has the proper clearances.  He also backs-up files, handles computer lock-outs, computer failures and troubleshoots problems.  He provides support and guidance to end-users regarding office automated tools (e.g., SharePoint) and security policies and procedures, and verifies end-users have completed required training, e.g., Cyberspace and Privacy Act.  He is the designated Unit Software License Manager (USLM) which entails making certain that all software licenses are renewed and up to date.  He is also the Information Technology Equipment (ITE) Custodian responsible for safeguarding all equipment and performing annual inventory of all IT equipment in the unit.  Furthermore, he serves as one of two Top Level Site Owners (TLSO) for Microsoft Office SharePoint, a “Collaboration Portal” selected for use by the ANG that promotes data, information and knowledge sharing.  As TLSO, the appellant has access to and control of the site, thus the ability to add, edit, approve/reject, delete content, modify page layouts and set permissions.  In addition, he provides training to end users as needed.

The appellant also serves as the Functional Area Records Manager (FARM).  As such, he is the point-of-contact for and monitors the Records Management Program of his unit and serves as liaison with the Base Record Manager (BRM) for his functional area.  He ensures record custodians are aware of policies, procedures and practices as they relate to records management, and conducts staff assistance visits (SAV) to provide technical guidance on the proper application of policies and procedures governing disposition of records, e.g., retention or disposal of records.  During SAVs he identifies areas requiring corrective action, makes recommendations for improvement and follows-up to ensure deficiencies have been corrected.  He also serves as the focal point for Intranet and electronic mail (e-mail) management and use policies, ensures all correspondence is properly routed and all appointment letters are updated, and is the mail point-of-contact for the unit.

The appellant is the Unit Publishing Manager.  In this capacity, he provides guidance to ensure publications and forms meet prescribed style, format, and legal and statutory requirements.  He is the primary Telephone Control Officer (TCO) for his unit authorizing and controlling long distance toll calls, DSN access authorization, and acts as the focal point for reviewing all unit communication requirements and requests for service.  In addition, he sets up telephones, fax machines and acquires numbers.  The appellant also acts as Commander Operational Representative (COR) for the Air Force Personnel Accountability and Assessment System (AFPAAS).  In case of a crisis/disasters or exercises, he is responsible for accountability of personnel and their families on behalf of the Commander by acquiring information from the AFPAAS.  The appellant is the Unit Defense Travel System (DTS) Coordinator responsible for submitting travel orders into the DTS for approval.

In reaching our classification decision, we have carefully reviewed all information provided by the appellant and his agency, including his official PD which, although not completely accurate, we have incorporated by reference into this decision.  In addition, to help decide the appeal we conducted separate telephone interviews with the appellant and his immediate supervisor. 

Series, title, and standard determination

The appellant disagrees with the agency’s assignment of his position to the Miscellaneous Clerk and Assistant Series, GS-303.  This series includes positions the duties of which are to perform or supervise clerical, assistant or technician work for which no other series is appropriate.  The work requires knowledge of the procedures and techniques for carrying out the work of an organization, and involves application of procedures and practices within the framework of established guidelines.  The appellant believes his position should be classified in the Support Services Administration Series, GS-342.  The GS-342 series includes all positions the primary duties of which involve supervising, directing, or planning and coordinating a variety of services functions that are principally work supporting, i.e., those functions without which the operations of an organization or services to the public would be impaired, curtailed, or stopped.  Such service functions include (but are not limited to) communications, procurement of administrative supplies and equipment, printing, reproduction, property management, space management, records management, mail service, facilities and equipment maintenance, and transportation. 

Although the appellant performs a variety of administrative support functions, we find his primary duties do not involve those typical of positions classified in the Support Services Administration Series, GS-342.  Unlike this series, his duties do not consist of services functions that are principally work supporting characteristic of positions in the GS-342 series.  Rather, they involve performing a variety of specialized technical tasks supporting the administration or operation of the programs of his unit typical of positions in the GS-303 series.  Like positions in this series, his duties require knowledge of the procedures and techniques involved in performing the work of his organization, including application of procedures and practices within the framework of established guidelines, which are not classifiable in any other series.  These tasks include identifying, maintaining and protecting official records, acquiring and distributing publications and forms using manual or electronic means, and operating and supporting automated information systems. 

Because the appellant performs computer support related functions, we also examined the Computer Clerk and Assistant Series, GS-335.  This series covers positions involving performance or supervision of data processing support and services functions for users of digital computer systems including such work as: (1) receiving, maintaining, and issuing data storage media for computer operations; (2) collecting and sequentially stating input media with associated programs instructions for processing; (3) scheduling the use of computer time for program processing; (4) collecting, maintaining, and distributing program and systems documentation; and (5) collecting raw information, preparing flow charts, and coding in program language; or (6) other support function.  This work requires knowledge of external data processing sequences, controls, procedures, or user and programming languages, rather than in-depth knowledge of computer requirements or techniques associated with development and design of data processing systems.  Employees in this occupation support or assist other employees who design, operate, or use automatic data processing systems applications and products.  Most positions involve work in one or a mix of functional areas typically including tape library, productions control, scheduling or direct support to subject-matter or computer specialists. 

Although the appellant performs some basic computer related support functions for his unit, his duties do not include those typical of positions classified in the GS-335 series and do not require knowledge of data processing, controls, and program languages needed in such positions.  Additionally, the GS-335 position classification standard (PCS) specifically excludes from coverage positions like the appellant’s which involve operation of computer connected equipment but do not require knowledge of data processing methods, procedures, or languages as the paramount qualification requirement.

Although as discussed above the appellant also performs records management duties and conducts SAVs to provide technical guidance to unit staff, this work does not meet the requirements for classification to the Management and Program Clerical and Assistance Series, GS-344.  Unlike positions in this series, his duties are not performed in support of management and program analysis functions, and do not require a practical knowledge of the purposes, methods, and techniques of management and/or program analysis.  The appellant’s duties are performed solely in direct support of his unit to ensure staff compliance with agency records management and disposition procedures. 

As discussed above, the appellant’s position is best classified in the GS-303 series.  However, there are no titles specified for positions in that series, so the agency may construct a title in keeping with the nature of the support work performed.  In doing so, the agency should adhere to the titling guidance in section III.H.2 of the Introduction.  Because the PCS for the GS-303 series contains no grade-level criteria, we have applied the criteria in the Grade Level Guide for Clerical and Assistance Work (hereafter referred to as the Guide) to grade the appellant’s technical support work. 

Grade determination

The Guide provides grade-level criteria for administrative support work.  Clerical work is defined in the Guide by examples of preparing, receiving, reviewing, and verifying documents; maintaining office records; and compiling information for reports.  Assistance work is defined as technical work that supports the administration or operation of the program of an organizational unit, and requires a working knowledge of the work processes and procedures of an administrative field and the mission and operational requirements of the unit.  The record shows the appellant primarily performs assistance work.  The Guide uses two classification factors to evaluate the work of a position:  (1) Nature of Assignment which includes knowledge required and complexity of the work, and (2) Level of Responsibility which includes supervisory controls, guidelines, and contacts.  Our evaluation by application of the two classification factors in the Guide follows. 

Nature of assignment

At the GS-6 level technical or assistance work requires considerable evaluative judgment within well-defined, commonly occurring aspects of an administrative program or function.  The work may involve providing direct assistance to specialists or analysts by performing a segment of their work, or it may involve responsibility for a stream of products or continuing processes based on direct application of established policies, practices, and criteria.  Assignments involve a relatively narrow range of case situations that occur in a broad administrative program or function.  This work typically involves identifying issues, problems, or conditions and seeking alternative solutions based on evaluation of the intent of applicable rules, regulations, and procedures.

Assignments requiring evaluative judgment are narrowly focused, address a single product or action, and are relatively clear cut.  The employee usually deals with problems or situations that remain stable, and resemble past problems or situations.  Assignments often involve problems or situations where there is not one absolutely correct solution, only a best or most appropriate one.  Work requires practical knowledge of guidelines and precedent case actions relating to a particular program area equal to that acquired through considerable work experience or specialized training.  The work also requires skill to recognize the dimensions of a problem and express ideas in writing. 

At the GS-7 level, which is the highest level for this factor described in the Guide, the work consists of specialized duties with continuing responsibility for projects, questions, or problems that arise within an area of a program as defined by management.  Work assignments involve a wide variety of problems or situations common to the segment of the program or function for which the employee is responsible.  Each assignment typically consists of a series of related actions or decisions prior to final completion.  Decisions or recommendations are based on the development and evaluation of information that comes from various sources.  The work involves identifying and studying factors or conditions and determining their interrelationships as appropriate to the defined area of work.  The employee must be concerned about taking or recommending actions that are consistent with the objectives and requirements of the program. 

At the GS-7 level, the work requires knowledge and skill to recognize the dimensions of the problems involved, collect the necessary information, establish the facts, and take or recommend action based upon application or interpretation of established guidelines.  The work also requires practical knowledge, developed through increasingly difficult, on-the-job experience dealing with the operations, regulations, principles, and peculiarities of the assigned program, function, or activity.

An illustrative work example of GS-7 level assignments in the Guide describes a position that advises the manager of a single-function field office on the practical and technical aspects of office administration, to include budgeting, purchasing, supply management, personnel administration, data processing and files management, and performs staff support work in each of these areas.  The employee collects data for the office operating budget, reviews submissions  of office staff assistants for proper format and compliance with agency budget requirements, and consolidates material into an annual office budget; sets up controls to monitor expenses during the year; and recommends budget adjustments including restructuring budget allocations or work plans to deal with changing situations such as varying costs for equipment parts, or services, and changes in availability of funds.  The employee purchases office supplies through various methods and tracks purchase documents; completes requests for personnel actions and writes position descriptions; and distributes forms and instructions for annual performance ratings and ensures timely, proper completion.  The employee conducts local recruitment, holds new employee orientation sessions, and maintains the office filing system.  In the GS-7 work example the work involves initiating personnel actions as needed, and tracking virtually all financial, personnel, supply, and other administrative transactions as the documentation flows through the office.

The appellant’s position meets the GS-6 level.  Like this level, his work includes directly providing technical assistance to staff of the [appellant’s unit] on matters primarily relating to records and information management and computer system support.  In doing so, he applies considerable evaluative judgment and specialized training from the Computing Technology Industry Association (e.g., CompTIA A+ certification) within well-defined, commonly occurring aspects of the unit’s administrative program.  Like the GS-6 level, he performs continuing processes based on direct application of established policies, practices and criteria.  For instance, he conducts SAVs on each Office of Record at least every 24 months using the Air Force Records Information Management System (AFRIMS) Staff Visit module.  The questions in the module are based on Air Force Instructions (AFI) and Air Force Manuals (AFMAN) applicable to the Air Force Records Management Program.  Other processes include include setting up computers, configuring user software, moving files from one media to another, submitting travel orders in the DTS for approval, submitting updates to the squadron’s personnel directory to the Host Wing, and overseeing record creation, maintenance and destruction procedures.  Like the GS-6 level, these assignments are performed based on direct application of agency established policies and practices, and are limited to a narrow range of case situations involving the administrative activities described above.  

Similar to the GS-6 level, the appellant’s work includes identifying issues and problems and seeking solutions based on reviewing and interpreting the intent of applicable rules and regulations.  For instance, as the FARM, the appellant conducts SAVs to ensure proper application of the Air Forces’ Records Management Program policies and procedures.  During these visits, he analyzes information collected to identify causes for deficiencies and corrective action needed based on his interpretation of appropriate governing regulations.  Furthermore, he provides training to record custodians and makes recommendations based on applicable Air Force instructions relating to the Records Management Program, Privacy Act Program, Management of Records, Records Disposition Procedures and Responsibilities and Record Disposition Schedules for improvement. 

Comparable to the GS-6 level, the appellant’s assignments are focused on a narrow range of administrative support activities primarily covering functions within the areas of record management, information management, and computer system support.  In carrying out those duties he ensures technicians are aware of policies, procedures and practices related to the administrative work of the unit.  His tasks and actions are straight forward and stable (resembling past issues), but sometimes involve research to determine the best solution.  For instance, although an SAV module is used to assess if the required criterion for satisfactory record management is met, he may need to conduct additional fact-finding through personal interviews and observation to understand causes of deficiencies and develop the best recommendations for improvement. 

The appellant’s position does not meet the GS-7 level.  Unlike this level, his assignments do not involve the variety of office administration elements and programs, multiple and varied administrative problems and situations, and increasingly difficult transactions described at the higher level and illustrative work example.  His work is limited to coordinating and monitoring administrative activities and answering questions on issues related to maintenance and management of publications, records and forms, acquisition of telephone services and long distance calling authorizations, drafting duty letters, distributing mail to staff, and providing guidance on computer systems and automated tools.  These tasks are more repetitive in terms of problems to be handled and regulations and procedures to be applied than those described at the GS-7 level.  Although the appellant determines the approach and makes decisions on how to accomplish his work, his assignments are also significantly more limited than those described at the GS-7 level.  For example, while he advises the Commander and staff on all unit information management support functions and performs computer system support activities, he does not advise them on the technical aspects of other administrative activities including supply management, personnel administration and data processing.  Although he is involved in records management, it is limited to his functional area.  The BRM administers the installation records management program.  The record shows that unlike the GS-7 level, the appellant does not perform the range and scope of technical work requiring a comprehensive knowledge of special and complex subjects as required at the GS-7 level. 

This factor is evaluated at the GS-6 level.

Level of responsibility

At the GS-6 level, the supervisor assists with precedent assignments by providing an interpretation of policy or the concepts and theories of the occupation.  Completed work is evaluated for appropriateness and effectiveness in meeting goals.  Guidelines such as regulations, instructions, evaluation criteria, and prior case or action files are available, but they are often not completely applicable to the assignment or have gaps in specificity.  The employee uses judgment in interpreting and adapting guidelines for application to specific cases or problems.  The employee bases decisions and recommendations on facts and conventional interpretations of guidelines rather than on theory or opinion.  The employee contacts others to provide, receive, or develop information in order to identify problems, needs or issues, and/or to coordinate work efforts or resolve problems.

At the GS-7 level, the supervisor makes assignments in terms of objectives, priorities, and deadlines.  The employee independently completes assignments in accordance with accepted practices, resolving most conflicts that arise.  Completed work is evaluated for appropriateness and conformance to policy.  Guidelines for the work are more complex than at the next lower grade because the employee encounters a wider variety of problems and situations which require choosing alternative responses.  Guides such as regulations, policy statements, and precedent cases, tend to be general and descriptive of intent, but do not specifically cover all aspects of the assignments.  Guidelines apply less to specific actions and more to the operational characteristics and procedural requirements of the program or function.  Employees must use significant judgment and interpretation to apply the guides to specific cases and adapt or improvise procedures to accommodate unusual or one-of-a-kind situations.  Although personal contacts for GS-7 employees are often the same as those for GS-6 employees, GS-7 employees serve as a central point of contact to provide authoritative explanations of requirements, regulations, and procedures, and to resolve operational problems or disagreements affecting assigned areas.

The appellant’s position meets the GS-6 level.  Like this level, the supervisor assists with precedent assignments by interpreting Air Force administrative support policies.  The appellant independently carries out his duties based on experience and normal work practices.  Completed work is evaluated for adequacy and appropriateness in meeting the administrative tasks and goals of the unit.  Comparable to the GS-6 level, the appellant’s guidelines include Air Force Instructions, memoranda and directives.  He uses judgment in interpreting and adapting these guidelines for application to specific record management situations and to resolve operational computer problems.  His decisions are based on the facts of a given situation, and on straight forward interpretation of guidelines rather than on theory or opinion.  Like the GS-6 level, the appellant’s contacts are with employees of the [appellant’s unit], staff at the Host Wing (i.e., managers, supervisor, and specialists), military and civilian officials.  The purpose of his contacts is to coordinate work efforts and resolve immediate problems within his functional areas. 

The appellant’s position does not meet the GS-7 level.  Although he works independently in performing his daily work assignments, any technical work conflicts are resolved with guidance from the supervisor or Commander.  Unlike the GS-7 level, his guidelines are less complex because he is not required to choose from alternative responses to resolve issues.  The guides, regulations, and instructions utilized specifically cover most aspects of his actions and assignments.  In contrast to the GS-7 level, given the specific nature of his work tasks he is not required to use significant judgment and interpretation to apply guidelines, and is not faced with adapting or improvising procedures to deal with unusual situations.  When such situations occur, he consults with his supervisor or Commander.  Unlike the GS-7 level, in making work contacts the appellant does not serve as the primary contact to furnish authoritative explanations and interpretations on information technology requirements and regulations.  Such matters are referred to specialists located at the BNCC.  Moreover, any significant operational problems or disagreements on matters involving records management are referred to and resolved by the BMR or higher level agency staff. 

This factor is evaluated at the GS-6 level.

Summary

By application of the grading criteria in the Guide, we find the nature of the appellant’s assignments and his level of responsibility meets the GS-6 level.  Therefore, the position is graded at that level. 

Decision

The proper series and grade of the appellant’s position is GS-303-6.  Selection of an appropriate title is at the discretion of the agency. 

 

 

 

 

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