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).

Introduction

On October 9, 2014, the U.S. Office of Personnel Management’s (OPM) Agency Compliance and Evaluation (ACE) Atlanta office accepted a classification appeal from Ms. Debra S. Dunleavy.  The appellant’s position is currently classified as Secretary (OA), GS-318-8, and is located in the Special Operations for Financial Management (SOFM), Headquarters, United States Special Operations Command (USSOCOM), Department of the Air Force (AF), MacDill Air Force Base (AFB), in Tampa, Florida.  The appellant believes her position should be classified at the GS-9 grade level or higher in the GS-318 series.  On November 13, 2014, we received the agency administrative report (AAR).  We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

Background

In June 2013, the appellant’s immediate supervisor submitted a request for an encumbered position review (EPR) with the Air Force Personnel Center (AFPC) requesting the appellant’s position be classified as an Executive Assistant, GS-301-9.  This request was based on “additional responsibilities, increased scope and complexity, and higher level of contacts required to successfully accomplish the revised duties and objectives of the position.”  On October 23, 2013, the AFPC issued a position evaluation statement sustaining the current classification.  On November 4, 2013, SOFM submitted a position evaluation “reclama” to AFPC which declined to alter its determination.  In June 2014, the appellant submitted a classification review request to AFPC, but because she indicated her CPD [core personnel document] was not accurate, she was directed to resolve this matter with her supervisor through applicable procedures. However, because the agency’s internal policy is to conduct no more than one EPR every two years, the appellant’s supervisor was advised another review would not be made.  The appellant subsequently filed a classification appeal with OPM. 

General Issues

The appellant makes various statements about her agency’s evaluation of her position and compares her duties to higher-graded executive assistant positions, one resource advisor position, and an administrative manager position (all classified in GS-301 series) from other components of the USSOCOM.  In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of her position.  By law, we must make that decision 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 position to others that may or may not be properly classified, as a basis for deciding her appeal.  Because our decision sets aside all previous agency decisions, the appellant’s concerns regarding her agency’s classification review process are not germane to this decision.

Although the aforementioned positions are classified in the Miscellaneous Administration and Program Series, GS-301, the appellant states “we all basically have the ‘same job’” and she “is seeking my CPD to be in line with the others at this command.”  The appellant submitted position descriptions (PD) or portions of PDs for these positions.  Although the PDs are similar in some aspects to the appellant’s, there are also clear differences in the scope of duties and responsibilities assigned.  For instance, one position includes responsibility for “conduct[ing] studies of administrative procedures and work processes within the Division to identify, analyze, plan, and coordinate the overall administrative efforts of the Division and to provide effective recommendations for solutions to issues and problems” and for “providing program guidance to the staff on the on implementation of the…Management Internal Control Plan (MICP), identification and determination of Material Weakness and corrective action plans….”  Another position “formulates general policies, procedures, and regulations for management of [the organization’s] administrative programs.”  Still another position “[d]evelops comprehensive plans and strategies for internal and external integration of the day-to-day and long-range calendar, assignments, actions and activities requiring the involvement [of the organization]” and “[e]xtrapolates existing methods and procedures for future requirements in developing timely and executable plans of action.”  These programmatic functions are materially different from the overall nature and purpose of the appellant’s work as discussed in this decision.

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 her position so similar to others that they all warrant the same classification, she may pursue the matter by writing to her agency’s human resources headquarters.  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 indicates she has been tasked with additional duties causing an increase in her workload and scope of responsibilities. She indicates she is responsible for scheduling and approving the use of two large conference rooms (seating 16-40 people) not only by the Chief Financial Officer (CFO) and Deputy CFO (DCFO) but by the staff of the subordinate directorates and describes this work as “time consuming and cumbersome.”  However, volume of work cannot be considered in determining the grade of a position (The Classifier’s Handbook, chapter 5).

Neither the appellant nor her immediate supervisor, CFO (comptroller), ES-0505-2, certified to the accuracy of the appellant’s official CPD (number 51R14663).  The appellant indicates that her CPD “does not accurately reflect the major duties, knowledge, skills, and responsibilities required/needed of [her] position.” The supervisor’s statement regarding the accuracy of the appellant’s CPD refers to the same reasoning.  

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 PD.  This decision is based on the work currently assigned and performed by the appellant. 

Our review disclosed the appellant’s CPD is not completely accurate.  The CPD describes duties the appellant does not perform.  Specifically, under duty #2 of her CPD, although she reviews her supervisor’s outgoing correspondence for grammatical and procedural correctness, she does not review it for clarity or completeness.  Under duty #3, she does not manage or administer the operating budget for the organization’s security funds, track expenses, or coordinate contracts.  The Resource Advisor is responsible for all budget-related duties of the organization.  Also, she does not review or route personnel actions (i.e., HR-related actions) for supervisory signature or recommendations.  Under duty #4, she does not conduct information management systems analysis to determine automation requirements or resolve incompatibility problems in software and develop and apply solutions.  These responsibilities are vested in the Information Technology (IT) staff.   Therefore, the appellant’s PD of record does not meet the standard of adequacy addressed on pages 10-11 of the Introduction, and the agency must revise the PD to reflect our findings.

Position information

The appellant serves as the principal “executive assistant” to the CFO and the DCFO by performing general office work auxiliary to the work of the organization.  The CFO, who is the appellant’s immediate supervisor, is the principal financial advisor to the USSOCOM Commander.  His office is composed of five directorates (Accounting, Budget, Investment, Integration, and Special Programs) and provides fiscal direction and guidance to four USSOCOM component commands and a sub-unified command.  The staff is composed of civilian, military and contractor personnel totaling 140 people.  Support staff includes two military support positions (currently vacant), the appellant’s position supporting the SOFM front office, and two GS-318-7 positions that support the five directorates (two other secretary positions are currently vacant).  The appellant asserts she is “responsible to oversee, train and direct four GS-0318-6/7’s and two military personnel assigned to the directorate.”  The record shows the appellant assists two lower-graded secretaries as needed to provide the CFO and DCFO with accurate reports and information needed to do their work.  While she provides informal direction to clarify office procedures, she is not responsible for overseeing their work or providing feedback used to appraise their performance.

The appellant is responsible for maintaining the CFO’s and the DCFO’s short- and long-range personal calendars, scheduling meetings and appointments (without prior approval), gathering background materials and ensuring time schedules are followed or adjusted as needed.  She coordinates with designated individuals; e.g., executive officer, action officer or financial management specialist, who brief or prepare the CFO and DCFO on the subject matter as needed before meetings, briefings or conferences.  She provides a full range of travel support services to her supervisor, preparing travel documents and itineraries and processing travel orders and vouchers.  She screens incoming telephone calls, mail and email for her supervisor, responds to non-technical inquiries and forwards others to him or the appropriate staff member.  She administers the HQ standard suspense tracking system, maintains a suspense file on correspondence, and follows up to ensure timely reply by her supervisor.  The appellant organizes all social, ceremonial, and special events and arranges VIP visits to include making logistical arrangements and preparing agendas and itineraries.  She orders and tracks office supplies for the front office and serves as the main point of contact for equipment maintenance and repair requests.  She uses Microsoft software to create, modify and process a variety of documents. 

The appellant coordinates the flow of communication between the front office (i.e., CFO's office) and the five subordinate directorates.  She prepares non-technical correspondence and reviews documents for grammar, punctuation, typographical errors and proper formats before forwarding to her supervisor.  As needed, she assists or advises lower-graded secretaries and military support staff from the subordinate directorates concerning appropriate procedures to use and information to be provided by the subordinate directorates in preparing reports to be submitted to the CFO.  She is responsible for scheduling and establishing all video teleconferences (VTC), handling and safeguarding sensitive and classified information in accordance with security policies and procedures. 

In reaching our classification decision, we have carefully reviewed all of the information provided by the appellant and her agency including her 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 CFO who, although deployed since October 2014, was available for an interview at the time of our request, and with the DCFO, currently acting as CFO. 

Series, title, and standard determination

The agency has classified the appellant’s position in the Secretary Series, GS-318, titling it Secretary (OA), and the appellant does not disagree.  We concur with the agency's title and series determination.  The PCS which covers positions in the GS-318 series specifies that the title Secretary applies to all nonsupervisory positions in this occupation.  The parenthetical title (OA) is appropriate, as the position requires a qualified typist and knowledge of office automation systems.  The grades of positions in the GS-318 series must be evaluated by reference to the grading criteria in the GS-318 PCS.  Our evaluation of the grade of the appellant’s position follows.

Grade determination

The GS-318 PCS is in Factor Evaluation System (FES) format.  Under the FES, positions are evaluated by comparing the duties, responsibilities, and qualifications required with nine factors common to nonsupervisory General Schedule positions.  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 total points assigned for the nine factors are converted to a grade by reference to the grade conversion table in the PCS.

The appellant indicates that in July 2013 when she returned from a nine-month deployment, her workload involved not only assisting the CFO but also his deputy.  Therefore, she believes she should be higher graded.  The GS-318 PCS notes that depending on the size and structure of the organization supported, secretary positions may assist the head of a unit or may additionally provide varying degrees of assistance to several senior staff members or the entire staff.  Regardless, the grade of a secretary position is based exclusively on the duties performed, not on the number of individuals supported as the appellant appears to believe. 

The appellant disagrees with her agency’s crediting of Factor Levels 1-4, 5-2 and 6-3, but concurs with the agency’s assignment of Factor Levels 2-4, 3-3, 4-3, 8-1, and 9-1.  After careful review, we concur with the agency’s assignment of Factor Levels 2-4, 3-3, 4-3, 7-2, 8-1, and 9-1 which, except for factor Level 2-4, we have not addressed further in our decision.  Even though the appellant does not challenge the assignment of Level 2-4 and agrees with the agency’s analysis, we will address this factor to respond to the issues the appellant raised in support of her appeal. 

Factor 1, Knowledge Required by the Position

This factor is expressed in terms of two elements, Work Situation and Knowledge Type.  Work Situation refers to the complexity of the organization served which 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 measures the nature and extent of information the employee must understand in order to do the work, and the skills needed to apply that knowledge.

          Work Situation

In Work Situation B, the staff is organized into subordinate segments which may in turn be further divided.  Work direction of the staff is exercised through intermediate supervisors, and the subordinate groups differ from each other in such aspects as subject matter, functions, relationships with other organizations, and administrative requirements in ways that place demands upon the secretary that are significantly greater than those described in Work Situation A.  There is a system of formal internal procedures and administrative controls, and a formal production or progress reporting system.  Coordination among subordinate units is sufficiently complex to require continuous attention. 

In Work Situation C, in addition to the conditions described in Work Situation B, the staff is 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 at each level.  In addition, the organization typically has one of the following conditions which increase the knowledge required by the work:  (1) the program is interlocked on a direct and continuing basis with the programs of other agencies or organizations, requiring constant attention to extensive formal clearances and procedural controls; (2) the program is directly affected by conditions outside the organization which vary widely in nature and intensity and require frequent organizational, procedural, or program adjustments in the organization; (3) 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 work situation matches Work Situation B.  SOFM is organized into five subordinate directorates; i.e., SOFM-A, B, M, I, S, each managed by a Director (GS-15), which are further divided into groups with intermediate supervisors (i.e., Division Chiefs).  Each directorate has different functions, external relationships, and administrative needs comparable to a typical Work Situation B organization.  The appellant coordinates administrative actions in support of the internal operations of the SOFM and its connection with its subordinate directorates.  Further, like in this Work Situation, the appellant has extensive and continuing responsibility for coordinating work outside the organization particularly through the coordination of VIP visits and tours, satisfying the alternate criteria for Work Situation B.

The appellant’s work situation does not meet Work Situation C.  The GS-318 standard includes several benchmark PDs for positions at varying grade levels that serve to illustrate 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.  All are augmented by various staff specialists.  Although these benchmarks are intended as general guides, the organization supported by the appellant does not approach the size or reflect the operational complexities found in Work Situation C.  The appellant’s organization, comprised of about 140 people, is not large enough to have the multiple subdivisions found at Work Situation C, and the staff is not augmented by various staff specialists.  Further, the organization is not impacted by any of the operational complexities described in that Work Situation.

           Knowledge Type

At Knowledge Type III, in addition to Type II knowledges, the employee must have knowledge of  the duties, priorities, commitments, policies, and program goals of the staff sufficient to perform non-routine assignments such as independently noting and 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 problem at hand.  At this level, the secretary is fully responsible for coordinating the work of the office with the work of other offices, and for recognizing the need for such coordination in various circumstances.  This may include advising secretaries in subordinate organizations concerning such matters as the information to be provided by the subordinate organizations for use in conferences and reports. 

At Knowledge Type IV, in addition to the knowledge and skills required at the lower levels, employees must have as a continuing requirement 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; systematically studying and evaluating new office machines and recommending acceptance or rejection of their use; and studying the clerical activities of the office and subordinate offices and recommending a specific restructuring of the way activities are carried out.  This level also requires a comprehensive knowledge of the supervisor’s policies and views on all significant matters affecting the organization that would enable the secretary to perform duties such as developing material for the supervisor’s use in public speaking engagements by developing background information, preparing and submitting an outline for the speech for final writing; and briefing or advising staff members or persons outside the organization on the supervisor’s views on current issues facing the organization. 

The knowledge required by the appellant’s position matches Knowledge Type III.  In addition to  applying knowledge of clerical rules, procedures and office protocols so as to be able to perform the procedural work of the office found indicative of Knowledge Type II, she applies knowledge of the CFO’s and DCFO’s duties, priorities, commitments and program goals  to independently note and follow-up on commitments made at meetings by the CFO or DCFO.  For instance, if the CFO needs to assign a staff member to review an audit report, the appellant determines the responsible staff member (i.e., action officer) and forwards documentation to that person.  Similar to this level, the appellant is responsible for coordinating the work of the front office with the work of its subordinate offices when arranging meetings, and conveying information through the distribution of office instructions and procedures. 

The position does not meet Knowledge Type IV.  The appellant’s position does not require the knowledge of administrative concepts, principles, and practices described at this level.  While the appellant must know the priorities and commitments of the CFO and DCFO, she does not  develop material for her supervisor’s use in public engagements or brief and advise staff members outside the organization on her supervisor’s views on current issues facing the organization.  This function is performed by directorate staff members (e.g., financial analysts or accountants) who possess technical knowledge of the issues at hand.  Unlike this level, the appellant also does not independently apply administrative practices to eliminate either conflicts or duplication in extensive office procedures.  Her work is limited to resolving conflicts involving scheduling and keeping the CFO informed of conflicting or controversial situations rather than resolving conflicts herself.  The appellant indicates she identified how to streamline an office procedure when she suggested that a writer’s supervisor must first review a document before submitting to the CFO and DCFO for final review.  Her recommendation was accepted, she created a standard operating procedure, and the document review system was adjusted to include this step.  However, this did not require her to study the clerical activities of subordinate offices in order to improve processes and activities.  Rather, this process is illustrative of her primary function of coordinating work flow between her office and that of other offices in her organization. 

Work Situation B in combination with Knowledge Type III equates to Level 1-4.  Therefore, Level 1-4 is credited and 550 points are assigned.

Factor 2, Supervisory Controls

This factor covers the nature and extent of direct or indirect controls exercised by the supervisor, the employee’s responsibility, and the review of completed work.

The record shows that both the appellant and her supervisor note specific functions in support of a higher grade.  For example, these functions include coordinating with the SOCOM protocol office for VIP visits, managing the tracking system for all actions and providing periodic status reports to the CFO and DCFO, advising action officers on procedures for VTC award ceremonies, and assisting with chain of command ceremonies and formal social events.  The appellant is also responsible for ensuring staff actions are completed in a timely manner and maintaining her supervisor’s calendar, mail and messages and maintaining office files.  We find these functions are directly addressed in Factor 2, Supervisory Controls, thus we discuss them below. 

The level of responsibility under which the appellant works is comparable to Level 2-4 (the highest level described under this factor.)  At this level, the supervisor sets the overall objectives of the work, and the secretary and the supervisor develop the deadlines and work to be done.  Completed work is reviewed only for overall effectiveness.  Typical duties performed at this level include the following:  noting commitments made by the supervisor during meetings and arranging for the staff to implement them; in addition to independently arranging conferences, also arranging for subordinates of the supervisor to represent the organization; ensuring that official obligations are met, such as arranging luncheons, issuing invitations, and providing for protocol requirements; obtaining information on specialized subject matter that is scattered in numerous documents or must be obtained orally from several sources; and preparing administrative or procedural notices or instructions to the staff on his/her own initiative. 

Like this level, the appellant assumes a considerable degree of responsibility in handling virtually all administrative matters affecting her office and has the additional responsibility of coordinating VIP visits to her organization. Analogous to the above Level 2-4 assignments, the appellant performs the following duties:  scheduling meetings for the supervisor independently, including other staff as appropriate; reading all of the supervisor’s emails; handling administrative issues on her own initiative; forwarding program matters to the appropriate staff and following up with them on required actions; and obtaining relevant materials from the technical staff and noting subsequent action items.  In coordinating VIP visits, the appellant is responsible for scheduling and arranging all aspects of the visit, including developing the agenda, assembling material packages, setting up meeting rooms and equipment, arranging transportation when necessary, and making luncheon arrangements.  The appellant carries out these duties very independently based on her understanding of program objectives and requirements.  As previously described, she identifies areas for improvement in the work flow between her office and that of other offices in her organization and implements process changes as approved by her supervisor.  

Level 2-4 is credited and 450 points are assigned.

Factor 5, Scope and Effect

This factor covers the relationship between the nature of the work; i.e., the purpose, breadth, and depth of the assignment, and the effect of the work products or services both within and outside the organization. 

At Level 5-2, the purpose of the work is to carry out specific procedures.  The work affects the accuracy and reliability of further processes.  Typical duties frequently appearing at this level include serving as liaison between the supervisor and subordinate units, consolidating reports submitted by subordinate units, and arranging meetings involving staff from outside the immediate office.  As discussed in applicable benchmarks in the GS-318 PCS, the purpose of the work at Level 5-2 is to ensure the clerical and administrative portions of the supervisor’s work are accomplished effectively, allowing the supervisor to concentrate on managerial duties.

At Level 5-3, secretaries serve offices that clearly and directly affect a wide range of agency activities, operations in other agencies, or a large segment of the public or business community.  The secretary at this level modifies and devises methods and procedures that significantly and consistently affect the accomplishment of the mission of the office.  The secretary also identifies and resolves various problems and situations that affect the orderly and efficient flow of work in transactions with parties outside the organization. 

The appellant’s position meets Level 5-2.  Like this level, the purpose of her work is to carry out specific procedures to provide support work essential to the smooth operation of her organization.  Similar to this level, she is the liaison between her supervisor, his deputy and subordinate supervisors.  For instance, she is responsible for collecting, monitoring and coordinating the submission of various types of information needed by her supervisor and his deputy to carry out their responsibilities.  The appellant is also the point of contact for arranging meetings to include creating official agendas or itineraries for use by visitors and participants and schedules, tracks and submits requested information for the set-up of VTC equipment.  Further, she is responsible for scheduling the use of two separate large conference rooms by her office and those in the five directorates.  Meetings involve visitors from government agencies, the private sector and high-ranking military officials from outside the organization to include Army, Navy, Air Force, and the Marine Corps.  Like at this level, the appellant’s work directly affects the accuracy and reliability of internal office processes and in turn contributes to the accuracy of the work performed by the CFO and DCFO. 

The appellant’s position does not meet Level 5-3.  Unlike this level, the appellant’s position does not directly affect a wide range of agency activities, operations in other agencies, or a large segment of the public or business community.  While the mission of the SOFM is to provide fiscal direction and guidance to the four USSOCOM commands and a sub-unified command, the record does not show that the appellant modifies and devises methods and procedures that significantly and consistently affect the accomplishment of the mission of the office.  Rather, as previously discussed, she performs a wide variety of administrative processes required to ensure smooth and efficient operations for her immediate organization. Moreover, she is not responsible for identifying or resolving problems and situations that affect the flow of work in transactions with parties outside her organization.  

 Level 5-2 is credited and 75 points are assigned.

Factor 6, Personal Contacts

This factor includes face-to-face and telephone contacts with persons not in the supervisory chain.  The relationship between Factors 6 and 7 presumes that the same contacts will be evaluated under both factors.  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 the 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’s contacts meet Level 6-3.  Like at this level, the appellant’s contacts are with individuals or groups from outside her employing agency in a moderately unstructured setting requiring her to identify and locate the appropriate person to contact.  For instance, the appellant receives telephone calls, ascertains the nature of the requests, responds to routine and non-technical inquiries personally, and refers technical matters to the appropriate staff member.   Further, like at this level, she uses knowledge of her office’s functions, procedures, policies and organization to provide answers and information, direct inquiries and resolve issues concerning clerical and administrative support areas.  Also, she has contact with individuals outside the organization in connection with coordinating VIP visits (i.e., aides and executive officers of high-ranking DOD officials). Comparable to this level, the appellant’s typical contacts include military and civilians from defense agencies, individuals from the private sector (i.e., corporate leaders), congressional staffers, and State and local officials.  

The appellant’s contacts do not meet Level 6-4.  Unlike this level, the appellant does not have regular contact with high-ranking officials at national or international levels in highly unstructured settings.  Examples provided of her regular and recurring contacts are not equivalent to those described at Level 6-4.  Although the appellant stated that she has contact with high-ranking officials (i.e., dignitaries, Members of Congress), fact-finding shows the contacts as previously stated are with the support staff of those officials (i.e., aides, congressional staffers and other administrative personnel) rather with the high-ranking officials themselves.

 Level 6-3 is credited and 60 points are assigned.

Summary

The total of 1620 points falls within the GS-8 range (1605-1850 points) on the grade conversion table provided in the PCS.    

 Decision

 The appealed position is properly classified as Secretary (OA), GS-318-8.