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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

Susan M. Donohue
Secretary (Office Automation (OA))
Office of the Special Agent in Charge
Homeland Security Investigations
Immigration and Customs Enforcement
U.S. Department of Homeland Security
Detroit, Michigan
Secretary (OA)

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



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).


On November 20, 2014, OPM’s Chicago Agency Compliance and Evaluation accepted a classification appeal from Ms. Susan M. Donohue.  The appellant’s position is currently classified as Secretary (OA), GS-318-7, but she believes it should be classified as Staff Assistant, GS-301-9.  The position is assigned to the Office of the Special Agent in Charge (SAC), Homeland Security Investigations (HSI), Immigration and Customs Enforcement (ICE), U.S. Department of Homeland Security, in Detroit, Michigan.  We received the complete agency’s administrative report on December 9, 2014.  Due to program workload considerations, the appeal was transferred to Dallas Agency Compliance and Evaluation for adjudication.  We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

Background and general issues

The appellant requested a desk audit of her position through ICE’s Office of Human Capital.  Their September 19, 2014, findings determined the position is appropriately classified as Secretary (OA), GS-318-7.  The appellant subsequently filed a classification appeal with the OPM.

The appellant believes her position should be classified to a different series and higher grade, in part, because management assigned her duties and responsibilities (e.g., maintaining and controlling the SAC’s personal calendar and schedules, setting up executive meetings and travel, and updating organizational charts) previously performed by the Staff Assistant, GS-301-9.  Consequently, the appellant believes her position should also be classified the same.  She forwarded the position description (PD) for the Staff Assistant position, which is vacant since the previous occupant retired in February 2014.

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.  By law, we must classify positions solely by comparing her current duties and responsibilities to OPM position classification standards (PCS) and guidelines (5 U.S.C. 5106, 5107, and 5112).  Since comparison to PCSs is the exclusive method for classifying positions, we cannot compare the appellant’s current duties to other positions which may or may not have been classified correctly.

The appellant states in her appeal request to OPM that it is “quite implausible to expect a reasonable evaluation using Standards and Guidelines that date from 1979, 1992 and 1995.”  She does not specifically identify the “Standards and Guidelines,” but we presume her statement is in reference to the PCSs cited by the agency in its September 2014 evaluation statement including the PCS for Secretary Series, GS-318.  Implicit in her statement is that the relevant grading criteria are outdated.  However, the adequacy of grade-level criteria in OPM standards is not appealable (5 CFR 511.607).  All OPM General Schedule standards are consistent with the grade level definitions of work established by law.  These definitions are based on the difficulty and responsibility of the work at each grade level and the qualifications required to do the work.

Position information

The HSI is responsible for investigating a wide range of domestic and international activities occurring from the illegal movement of people and goods in, within, and out of the United States.  The HSI investigates incidents of immigration crime; human rights violations and human smuggling; smuggling of narcotics, weapons, and other types of contraband; and financial crimes, cybercrime, and export enforcement issues.  The HSI also oversees the agency’s international affairs operations and intelligence functions.

The appellant serves as the principal office assistant, providing support to the SAC, Deputy Special Agent in Charge (DSAC), and the Assistant Special Agent in Charge (ASAC) positions.  The DSAC (a GS-1811-15 Supervisory Criminal Investigator position) serves as her immediate supervisor.

The appellant’s duties include, but are not limited to, maintaining and controlling the SAC’s and DSAC’s personal calendars, scheduling appointments without prior approval, gathering background materials, and tracking and following up on action items.  She also makes travel, transportation, and lodging arrangements.  She receives, screens, and directs all calls and visitors, ascertaining the nature of the requests, responding to routine or non-technical inquiries personally, and referring non-routine or technical inquiries to the appropriate staff.  In addition, the appellant reviews incoming correspondence and identifies needed action, preparing replies to routine and non-technical matters and referring technical or other matters to the appropriate staff.  Outgoing correspondence and reports are reviewed for conformance with format, spelling, policy, etc.  The appellant plans and coordinates administrative arrangements for conferences, ceremonies, and other meetings.  She compiles information and briefs the SAC and others on items relevant to their participation at such functions.  She prepares memorandums, correspondence, and reports as directed.  The appellant collects and maintains data and information, which is used by the SAC and others to make program-related decisions.

As needed, the appellant provides administrative support and guidance to the approximately 150 employees assigned to the Office of the SAC and 100 employees assigned to the six subordinate Resident Agent in Charge (RAC) offices located within the area of responsibility (AOR) of Michigan and Ohio.  She coordinates the flow of information between the SAC’s immediate office and the subordinate units.  Her work includes reviewing documents for complete and accurate factual information and proper format, following up and reporting on the status of actions required by the SAC or his management staff, and compiling needed information and sharing it with the appropriate organizational units or personnel.  To accomplish her work, the appellant must use Microsoft Word, Excel, PowerPoint, and other various office automation software and law enforcement databases and be skilled in automated word processing.

The Acting DSAC certified to the accuracy of the duties described in the appellant’s official PD, number S0274a.  However, the appellant states her PD is inaccurate and submitted a document titled “Duties I Perform Above and Beyond my Job Description.”  The four-page document identifies duties including, but not limited to, responding to visitors and inquiries, serving as Executive Assistant to the SAC and others, processing travel authorizations and clearance requests, reviewing outgoing correspondence, drafting various letters, scheduling appointments, and handling housekeeping and facility issues.

We noted the appellant’s official PD identifies a number of the same duties specifically identified in the “Duties I Perform Above and Beyond my Job Description” document including screening calls and visitors, handling correspondence, extracting data, reviewing outgoing correspondence, making travel and other arrangements, and performing other duties as assigned.  A PD does not have to be a comprehensive and detailed narrative of the tasks assigned to a position.  Rather, a PD is the official record of the major duties and responsibilities assigned to a position or job by an official with the authority to assign work.  Major duties are normally those occupying a significant portion (at least 25 percent) 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.  OPM considers a PD to be accurate for classification purposes when the major duties and responsibilities of the position are listed and proper classification can be made when the description is supplemented by otherwise accurate, available, and current information on the organization’s structure, mission, and procedures.  Based on these criteria, we find the appellant’s PD is adequate for classification purposes, and we incorporate it by reference into this decision.

Regardless, classification appeal regulations permit OPM to investigate or audit a position and decide an appeal on the basis of the actual duties and responsibilities currently assigned by management and performed by the employee.  An OPM appeal decision classifies a real operating position and not simply the PD.  This decision is based on the work currently assigned to and performed by the appellant.

To help decide this appeal, we conducted a telephone audit with the appellant on February 25, 2015, and a telephone interview with the immediate supervisor on March 31, 2015.  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 standards determination

The appellant believes her work warrants classification to the GS-301 Miscellaneous Administration and Program Series.  The GS-301 series is used to classify two-grade interval administrative work for which no other series is appropriate.  Two-grade interval administrative work requires a high order of analytical ability combined with a comprehensive knowledge of the functions, theories, and principles of management and the methods of evaluation.  These criteria are not applicable to the appellant’s position.  One-grade interval administrative support work, such as that performed by the appellant, can be performed based on a practical knowledge of the purpose, operation, procedures, techniques, and guidelines of specific program areas or functions.  Support work personnel who apply a thorough (but practical) knowledge of these facets of administration typically learn to do the work on the job through what sometimes may be years of experience.

We find the appellant’s position is properly classified in the GS-318 Secretary Series.  Her position is an exact match to the series definition, as it serves as the principal clerical and administrative support position for the head of an organizational unit and the immediate staff.  The primary purpose of her work is to perform the necessary general office work that facilitates the work of the organization and to assist other organization staff members to perform their duties more effectively.  The appellant’s position requires knowledge of clerical and administrative procedures and various office skills.  Although she must possess knowledge of various administrative processes and must thoroughly understand the functions of subordinate organizational units throughout the Office of the SAC, her position does not require her to apply knowledge of any specialized subject matter area or administrative field, e.g., personnel management, financial management, or contracting.  We conclude the appellant’s position is properly classified to the GS-318 series.

Consistent with our series determination, the proper title for the appellant’s position is Secretary.  As the position requires a qualified typist and proficiency in the use of OA software, the title should include OA as a parenthetical title.  The appellant’s position is properly graded using the GS-318 PCS.

When evaluating the appellant’s position, we applied the Office Automation Grade Evaluation Guide to ensure her use of OA systems was not classifiable at a higher grade than her secretarial work.  We found her OA duties are graded at a lower level than her secretarial work.  Since the duties are not grade determining, we will not discuss them further.

Grade determination

The GS-318 PCS is written in the Factor Evaluation System (FES) format, under which factor levels and accompanying point values are assigned for each of the nine factors.  The total is converted to a grade level by use of the grade conversion table provided in the PCS.  Under the FES, each factor-level description demonstrates the minimum characteristics needed to receive credit for the described level.  If a position fails to meet the criteria in a factor-level description in any significant aspect, it must be credited at a lower level unless an equally important aspect that meets a higher level balances the deficiency.  Conversely, the position may exceed those criteria in some aspects and still not be credited at a higher level.

The appellant only disagrees with the agency’s evaluation of Factors 1, 2, and 6 in its application of the GS-318 PCS to her position.  We have reviewed the agency’s crediting of Levels 3-3, 4-3, 5-3, 7-2, 8-1, and 9-1; concur; and have credited the position accordingly.  Therefore, our evaluation will focus on the factors contested by the appellant.

Factor 1, Knowledge required by the position

This factor is expressed in terms of two elements, Knowledge Type and Work Situation.  Knowledge Type measures the nature and extent of information the employee must understand in order to do the work, as well as the skills needed to apply that knowledge.  Work Situation refers to the complexity of the organization served (e.g., the immediate office in which the secretary works and any subordinate offices) that affects the extent of office rules, procedures, operations and priorities the employee must apply to maintain a proper and smooth flow of work within the organization and between organizations.

            Knowledge Type

At Knowledge Type III, the employee must have knowledge of an extensive body of rules, procedures, or operations applied to clerical assignments; knowledge of the organization and functions of the office; and knowledge of the duties, priorities, commitments, policies, and program goals of the staff sufficient to perform non-routine assignments such as independently following up on commitments made at meetings and conferences by staff members, shifting clerical staff in subordinate offices to take care of fluctuating workloads, or locating and summarizing information from files and documents when this requires recognizing which information is or is not relevant to the problems at hand.  Secretaries at this level are fully responsible for coordinating the work of the office with other offices and for recognizing the need for such coordination in various circumstances.  This may include advising support staff in subordinate organizations concerning such matters as the information to be provided by the subordinate organizations for use in conferences or reports.

At Knowledge Type IV, in addition to the knowledge and skills required at lower levels, the employee must have a basic foundation of administrative concepts, principles, and practices sufficient to perform independently such duties as eliminating conflict and duplication in extensive office procedures, determining when new procedures are needed, and studying and recommending restructuring of clerical activities of the office and subordinate offices.  This level also requires a comprehensive knowledge of the supervisor’s policies and views on all significant matters affecting the organization.

The knowledge required by the appellant’s position fully meets Knowledge Type III.  To perform her assigned duties and responsibilities, she must apply a thorough knowledge of the Office of the SAC’s policies, procedures, operations, functions, and organization.  She must have knowledge of agency policies and functional knowledge of the HSI in order to provide information to the SAC and other management officials, subordinate staff, and other organizations through her preparation of documents, reports, and other correspondence.  Typical of Knowledge Type III, she summarizes pertinent information from building management meetings to be communicated to Office of the SAC staff; provides comments and suggestions on the use of electronic signatures and other standard operating procedures established by the DSAC and other management staff; drafts letters of acknowledgement, commendation, notification, and other informational material; and follows up on commitments made by staff at executive and other meetings, and records and prepares meeting minutes.  Similar to Knowledge Type III, the appellant must know the policies and priorities of the SAC, DSAC, and other management officials in order to handle the administrative matters that arise and to coordinate with the work of subordinate units, e.g., in arranging meetings, sending out personnel announcements, and distributing instructions in a weather emergency and other procedures.  She is also responsible for the storage and organization of a shared electronic filing system; this work requires ensuring AOR-wide employees comply with the storage and organization requirements of the shared drive, maintaining reference materials, and providing instructions and advice to employees when necessary.  In her daily duties, she must also be able to recognize problems with incomplete or missing information on administrative paperwork submitted to the Office of the SAC and in response to requests for information.

Also typical of work at this level, the appellant applies the full range of knowledge found at lower levels such as knowledge of grammar, spelling, punctuation, and required agency formats to prepare a variety of documents; prepare and submit requests for international travel authorizations in a timely manner; update organizational charts, phone listings, and duty rosters; prepare the minutes from executive and other meetings; receive and refer telephone calls and visitors; and maintain control over the calendar of meetings for the SAC and other staff.

The appellant’s position does not require the knowledge of administrative concepts, principles, and practices described at Knowledge Type IV.  While knowledgeable of the views of the SAC and other management officials, she does not have the technical knowledge to perform the scope or complexity of duties found at this level such as regularly preparing briefing materials or briefing staff or people outside the organization on management’s views on current issues facing the organization.  The appellant also does not independently apply administrative practices to eliminate either conflicts or streamline extensive office procedures since her function is primarily coordination.  She may resolve scheduling conflicts, but her work typically requires keeping the SAC informed of situations rather than resolving problems.  In addition, the appellant does not study the clerical activities of subordinate offices in order to improve processes and activities; rather, the review she conducts on internal correspondence is for correct grammar, format, errors, and adherence to administrative policy and procedures.  Further, the PCS provides that Work Situation B, as discussed below, only rarely involves the application of Knowledge Type IV.

            Work Situation

In Work Situation B, the staff is divided into subordinate segments which may be further subdivided, work direction is through intermediate supervisors, and the subordinate groups differ in function and administrative requirements in such a way that demands are placed on the secretary that are significantly greater than those described in Work Situation A.  In this situation, there is a system of formal internal procedures and administrative controls and a formal production or progress reporting system.

In Work Situation C, in addition to the conditions described at Work Situation B, staffs of organizations are augmented by various staff specialists in such fields as personnel, management analysis, and administration.  The organization is typically divided into three or more subordinate levels with several organizations found at each level.  In addition, such organizations typically have one of the following, or equivalent, conditions which increase the knowledge required by the work:  the program is interlocked on a direct and continuing basis with the program of other departments, agencies, or organizations, requiring consistent attention to extensive formal clearances and procedural controls; the program is directly affected by conditions outside the organization which vary widely in nature and intensity, and which frequently require organizational, procedural, or program adjustments in the supervisor’s organization; or there is active and extensive public interest or participation in the program which results in the supervisor spending a substantial portion of the time in personal contacts such as those with citizens groups, professional societies, the media, educational groups, officials of State or local governments, or community leaders.

The appellant’s position matches Work Situation B.  Similar to this level, her organization is organized into four subordinate divisions, each managed by an ASAC, which are further divided into groups with intermediate supervisors.  Each division involves different mission programs of the Office of the SAC.  In addition, the Office of the SAC is responsible for the six RAC offices located in the AOR.  Typical of Situation B, the appellant has frequent and substantive contact throughout the organization, coordinates numerous administrative details in support of the mission, and maintains familiarity with the internal operations of the Office of the SAC and its relationship with subordinate organizations.  In addition, she has extensive and continuing responsibility for coordinating work outside the organization through her coordination of visits and tours, satisfying the alternative criteria for Work Situation B.

The appellant’s position does not meet Work Situation C.  Organizations at this level are characterized by significantly greater complexity, such as three or more subordinate levels with several organizations at each level and with specialists in fields such as personnel, finance, and management analysis.  In contrast, the Office of the SAC, though divided into four subordinate divisions, its staff of approximately 150 is not large enough to have multiple subdivisions with support from their own full administrative staffs.  The Office of the SAC is not interlocked with other departments or agencies, is not directly affected by outside conditions, nor is there the active and extensive public interest found at Work Situation C that significantly impacts the appellant’s work by requiring additional knowledge requirements or requiring she establish formal administrative controls between her organization and outside organizations.  The PCS includes several benchmark job descriptions for positions at varying grade levels that serve as illustrative work situations.  They describe both the duties performed and the factor level assignments.  In the three benchmarks where Work Situation C is assigned, the organizations depicted include a district office with over 1,000 employees, a research and development center with approximately 1,800 employees, and a large hospital affiliated with two schools of medicine, each of which has staff providing dedicated administrative support.  Although these benchmarks are intended as general guides, the organizations supported by the appellant do not approach this organizational scale or complexity.

Work Situation B in combination with Knowledge Type III equates to Level 1-4.  Thus, Level 1-4 is credited for 550 points.

Factor 2, Supervisory Controls

This factor covers the nature and extent of direct or indirect controls exercised by the supervisor, the secretary’s responsibility, and the review of completed work.  Controls are exercised by the supervisor in the way assignments are made, instructions are given, priorities and deadlines are set, and how objectives and boundaries are defined.  The responsibility of the secretary depends upon the extent to which the supervisor expects the secretary to develop the sequence and timing of various aspects of the work, to modify or recommend modifications of instructions, and to participate in establishing priorities.

At Level 2-3, the supervisor defines the overall objectives and priorities of the work and assists the secretary with some special assignments.  The secretary plans and carries out the work of the office and handles problems and deviations in accordance with established instructions, priorities, policies, commitments and program goals of the supervisor, and accepted practices in the occupation.  Methods are almost never reviewed in detail, and completed work is evaluated for adequacy, appropriateness, and conformance to established policy.

At Level 2-4, the supervisor sets the overall objectives and the supervisor and secretary, in consultation, develop the deadlines and the work to be done.  The secretary handles a wide variety of situations and conflicts using initiative to determine the approach to be taken or the methods to be used.  Completed work is reviewed only for overall effectiveness.

The supervisory controls over the appellant’s position meet Level 2-3.  She independently plans and carries out the day-to-day administrative work of the office, handling problems and deviations based on established instructions, priorities, commitments, and program goals of the Office of the SAC.  Work examples given in the PCS at Level 2-3 are comparable to those performed by the appellant.  These include screening calls and visitors, handling many items personally, keeping the supervisor’s calendars, scheduling appointments without prior approval, making arrangements for meetings and conferences based on information concerning purpose and people to attend, screening incoming correspondence, responding personally or referring to appropriate staff, and reading outgoing correspondence for procedural and grammatical accuracy.  As at Level 2-3, she typically establishes her own daily priorities in a manner that is consistent with program goals communicated periodically by her supervisor.  Her work is evaluated for adequacy, appropriateness, and conformance with established policy.

The appellant seeks to credit her position at Level 2-4, stating in her appeal request to OPM:

….I handle visitors (including those that are irate and/or confused) as well as inquiries spanning a wide diversity of subject matters, incoming telephonic and written communications emanating from a wide variety of sources that are received for the SAC, DSAC or the office in general.  I receive complaints or requests from employees in our office or from General Services Administration (GSA) and take action on behalf of management to accomplish facility improvement and resolve issues.  I handle office-wide housekeeping and facility items on my own initiative without instruction from Upper Management and recommend new procedures or improvements that are reasonable and cost effective.  Many of my duties are undertaken on my own initiative in response to the administrative needs of our AOR.

The appellant’s supervisory controls, as described above, do not exceed Level 2-3.  At both Levels 2-3 and 2-4, the secretary works independently, using personal initiative to complete many assignments, plans and carries out the clerical work of the office, and handles problems or deviations in accordance with the program goals of the organization.  However, the appellant’s position does not meet Level 2-4 where the organization is of such size and scope that many complex office problems arise that cannot be brought to the supervisor’s attention.  Under this factor, the levels do not simply represent a progression of decreasing supervisory oversight over the work.  They also represent responsibility for carrying out progressively more complex duties with a corresponding degree of independence.  The appellant’s position does not meet Level 2-4 in that secretaries at this level must regularly and independently handle a wider variety of more difficult situations.  For example, unlike her position, secretaries at Level 2-4 must often obtain information, when resolving issues, from sources which are not initially known or subject matter that is specialized or is highly complicated because it is scattered in numerous or obscure documents.  As the organization’s Virtual University Administrator, the appellant runs queries to identify and send notices to those employees in the AOR who have yet to complete mandatory training.  When required, she also queries and gathers information from law enforcement databases for special projects.  However, while she provides information from this and other sources, the appellant is not required to perform the extensive fact gathering and review of periodicals, publications, or speeches found at Level 2-4.

The appellant drafts letters of acknowledgement, commendation, and other notices; however, this and other work (e.g., handling a variety of telephone and written inquiries and addressing staff complaints regarding facility- and/or housekeeping-related issues) do not reflect the more extensive involvement expected at Level 2-4 such as reviewing various publications for commendatory remarks requiring the preparation of such letters of acknowledgment, selecting subordinates to represent the supervisor based on a knowledge of the supervisor’s views, and obtaining information when the sources of which are not initially known and which may be available in only one of very few places.  Also at Level 2-4, many complex problems confronted by the secretary cannot be presented to the supervisor.  Although the DSAC is occasionally away from the office, the appellant typically maintains daily contact with him, the SAC, or others who are able to provide coverage and guidance as needed.  Her supervisor is usually available to exercise managerial control, establish priorities, and provide guidance to the staff on most non-routine or complicated administrative issues.  The appellant disseminates procedural instructions and notices issued by other organizations; however, the limited office staff does not present the opportunity for or the necessity of devising and installing formal office procedures or developing notices and instructions found at Level 2-4.

Level 2-3 is credited for 275 points.

Factor 6, Personal Contacts

This factor includes face-to-face and telephone contacts with persons not in the supervisory chain.  Levels described under this factor are based on what is required to make the initial contact, the difficulty of communicating with those contacted, and the setting in which the contact takes place.

At Level 6-3, personal contacts are with individuals or groups from outside the employing agency in a moderately unstructured setting, e.g., the contacts are not established on a routine basis, requiring the secretary to identify and locate the appropriate person to contact or to apply significant skill and knowledge in determining to whom a telephone call or visitor should be directed.  At this level, the purpose and extent of each contact is different, and the role and authority of each party is identified and developed during the course of contact.  Typical contacts at this level include attorneys, representatives of professional organizations, the news media, or public action groups.

At Level 6-4, personal contacts are with high-ranking officials from outside the employing agency at national or international levels in highly unstructured settings.  Typical contacts at this level might include Members of Congress, leading representatives of foreign governments, presidents of large, national or international firms, nationally recognized representatives of the news media, presidents of national unions, State governors, or mayors of large cities.

The appellant seeks to credit her position at Level 6-4, stating in her appeal request to OPM:

My contact with high-ranking members of other Federal and International Agencies, Dignitaries and VIP visitors is direct and frequent.  I am known by name and contacted often by Upper Level Management from many U.S. and Canadian Agencies who reach out to me with requests for information, documentation, verification, and so on.  Most of these contacts are Middle to Upper Management.  We also exchange reference data, such as duty rosters, organizational updates, and employee listings.  These contacts are within the Department of Homeland Security, other government Agencies and Canadian Agencies…I often independently note and follow-up on commitments made at meetings by Upper Management, often responding to Upper-Level Management of outside agencies.  I am also contacted with requests of information or solutions to issues in place of Upper Management when they are unavailable.  I must determine how best to address the questions or resolve these issues.

The appellant’s contacts and the setting in which they occur, as described above, are consistent with Level 6-3.  She serves as the point of contact for many administrative support and clerical issues and for general inquiries originating from the Office of the SAC, the subordinate offices, and the general public.  She also has substantive contact with individuals outside the organization in connection with coordinating visits and tours.  The appellant receives and screens telephone calls and visitors, handling personally those that are within her scope and referring others to the appropriate staff.  Many of her contacts occur in the moderately unstructured environment expected at Level 6-3, for example, callers requesting specific information that requires her to determine and locate the appropriate individual to handle the request.  In making contacts, the appellant must use her knowledge of the Office of the SAC’s functions, procedures, policies, and organization to provide answers and information, to direct inquiries, and resolve issues in a range of clerical and administrative support areas.

The appellant’s contacts do not meet Level 6-4 where regular contacts are with high-ranking officials at the national or international levels in a highly unstructured setting.  Examples of her regular contacts are not equivalent to those described at Level 6-4 involving Members of Congress, leading representatives of foreign governments, presidents of large national or international firms, State governors, and mayors or large cities.  In addition, her contacts typically occur in a moderately unstructured setting rather than the highly unstructured setting expected at Level 6-4.  For example, the appellant’s contacts are not normally characterized by problems such as officials may be relatively inaccessible, arrangements may have to be made for accompanying staff members, appointments may have to be made well in advance, each party may be very unclear as to the role and authority of the other, and each contact may be conducted under different ground rules.

 Level 6-3 is credited for 60 points.

Factor Level Points
1.  Knowledge Required by the Position 1-4 550
2.  Supervisory Controls 2-3 275
3.  Guidelines 3-3 275
4.  Complexity 4-3 150
5.  Scope and Effect 5-3 150
6.  Personal Contacts 6-3 60
7.  Purpose of Contacts 7-2 50
8.  Physical Demands 8-1 5
9.  Work Environment 9-1 5
Total 1,520


A total of 1,520 points falls within the GS-7 range (1,355 to 1,600) on the grade conversion table in the PCS.


The appellant’s position is properly classified as Secretary (OA), GS-318-7.


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