Washington, DC

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

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


10/25/2013

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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 CFR must be followed in implementing this 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 OPM office which accepted the appeal.  

Introduction

The U.S. Office of Personnel Management (OPM), Agency Compliance and Evaluation- [City], accepted this position classification appeal on May 24, 2012.  The appellant occupies the position of Passport Operations Officer, GS-301-11, in the [City] Passport Agency (office), Passport Services Directorate (Directorate), Bureau of Consular Affairs (Bureau), U.S. Department of State (agency), in [City, State].  He requests reclassification of his position to the GS-12 level.  We received the agency’s administrative report (AAR) on August 21, 2012, and the appellant’s final comments on the AAR on January 31, 2013.  We accepted and decided this appeal under the provisions of section 5112 of title 5, United States Code (U.S.C.)

Background

The appellant served as a Passport Specialist from 1995 to 2005, after which he accepted his current position working for the Assistant Regional Director.  In May 2006, the appellant requested a review of this position.  On October 23, 2006, the agency provided him with a memorandum summarizing the results of the review as determined by a contract classifier.  The review sustained the agency's decision that his position was properly classified as Passport Operations Officer, GS-301-11.  The agency required Bureau management to revise the appellant’s standard position description (SPD) to include the additional duties and responsibilities he raised during the review.

General issues

The appellant compares his position to higher-graded positions in other Bureau offices.  In the conclusion to his response to the AAR , the appellant states he believes the proper grade for this longstanding PD should be GS-301-12 in conformity with the other approximately 16 passport operations officers working at U.S. State Department Passport Agencies using the same PD and performing identical duties.  Specifically, he believes his work is comparable to the duties described in SPD #[######], classified as Passport Operations Officer, GS-301-12, which he states is identical to his GS-301-11 SPD (#[######-##]).  However, the record shows the PDs submitted by the appellant in his original request for appeal are outdated.  The current PDs for the two positions are clearly different in that the GS-12 position is for use only at the National Passport Centers. Furthermore, in reviewing this PD and the appellant’s PD, we note significant differences.  Factor 2 in the GS-12 PD states the incumbent advises on “complex technical issues related to passport adjudication” in addition to advising on organization planning and resource requirements listed in the appellant’s PD.  Factor 3 in the GS-12 PD similarly addresses using guidelines, including laws, rules, regulations, procedural manuals, court decisions, and precedents “as they relate to passport adjudication and issuance.”  The appellant’s PD does not include such guidelines.  We find similar significant differences in other factor level descriptions in the two PDs.  Thus, we conclude the GS-12 PD describes duties and responsibilities materially different from those performed by the appellant and, thus, may support a different classification.

In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of the appellant’s position.  By law, we must classify positions solely by comparing the work currently assigned by management and performed by the appellant to OPM’s position classification standards (PCS) 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 other positions which may or may not be classified correctly as a basis for deciding his appeal.  Thus, those aspects of the appellant’s appeal rationale that rely on comparing his position to the GS-12 SPD are barred by statute.  Therefore, we have considered the appellant’s statements only insofar as they are relevant to our comparison of his work to OPM’s PCSs and guidelines.

Like OPM, the appellant’s agency must classify positions based on a comparison to OPM’s PCSs and guidelines.  However, under 5 CFR 511.612, the agency also has primary responsibility for ensuring its positions are classified consistently with OPM appeal decisions.  If the appellant believes his position is classified inconsistently with higher graded positions at other Bureau offices, he may pursue this matter by writing to the human resources office of his agency’s headquarters.  He should specify the precise organizational location, series, title, grade, and responsibility of the positions in question.  The agency should explain to him the differences between his position and the others, or classify those other positions in accordance with this appeal decision. 

The appellant also states his workload has expanded noticeably since he began working in his current position, especially since a co-worker assigned to the same SPD passed away last year. However, volume of work cannot be considered in determining the grade of a position (The Classifier’s Handbook, chapter 5).

Position information

The supervisor certified to the accuracy of the appellant’s SPD, but the appellant did not, only stating that the GS-11 and 12 SPDs at issue are identical.  The position is situated in the [city] office which has an approved staffing level of fewer than 100 employees.  The appellant reports directly to the Assistant Regional Director (ARD), and advises and works in close liaison with the Regional Director (RD) and the rest of the local management team. 

The Bureau administers laws, formulates regulations, and implements policies relating to the broad range of consular services involved in the issuance of passports and other documentation to citizens and nationals, protection of U.S. border security in conjunction with the Western Hemisphere Travel Initiative (WHTI), and facilitation of legitimate travel to and from the United States.   

The appellant oversees a broad range of functions that facilitate and/or directly involve the Directorate's ability to conduct affairs and provide effective services related to passport administration. 

The official SPD shows that the appellant:

1. Monitors, evaluates, and coordinates a variety of services, programs, and systems that serve as the administrative and functional infrastructure that supports the issuance and adjudication of passport applications.  This involves a significant problem-solving component, made complex by the number and range of variables involved.
2. Provides advice and guidance to office management on administrative problems and management issues.
3. Considers both hard statistical and often-elusive qualitative data, when designing and/or evaluating productivity, workload, and customer satisfaction studies.
4. Assesses impact of recommendations for both short- and long-term solutions (e.g., use of overtime to accomplish the office’s weekly workload goals, or the modification of documents required for passport applications and adjudication) on office production.
5. Is responsible for identifying and isolating unique and systemic problems, and taking appropriate action and/or recommending appropriate action to management such as Headquarters intervention, expansion or contraction in workload transfer, or reallocation of other resources.
6. Assists the RD and the ARD in the preparation of a yearly operating plan for incorporation into the overall Passport Services Directorate program plans.
7. Reviews office budget requests to determine whether they realistically reflect required fiscal needs based on current approved levels, and develops and proposes alternative funding levels with supporting rationales when warranted.  Develops the office's yearly budget submissions to the Directorate and Bureau through coordination with all members of the management team.   Manages the office's delegated budget relating to supplies, travel, training, and awards. etc.  Tracks training and awards budgets, alerting RD and ARD to potential shortfalls or surpluses as the fiscal year progresses.
8. Monitors and evaluates productivity systems at the office that inc1ude FTE resources, contract resources, fiscal, materials, electronic systems, and administrative policies and procedures.  Evaluates the needs of the office on a weekly basis in order to retain the optimum volume of work the office can handle; as well as identifies whether workload needs to be diverted from the office to one of the processing centers.  Assesses the adequacy of office resources, qualitatively in terms of distribution, in relation to current and projected workloads, and develops and conducts/leads studies and assessments of new methodologies and techniques to address changing situations.
9. Assists management team with programming of Office appointment and q-matic customer flow management queuing systems.
10. Serves as the office's accountable property officer, ordering supplies and maintaining inventories in accordance with internal controls procedures.  Serves as the office's primary U.S. Government credit card holder. Acts as liaison with the Office of the Executive Director, General Services Division (CA/EX/GSD), and other offices regarding maintenance of equipment and inventory.  Ensures local actions meet the National Environmental Policy Act (NEPA) which requires Federal agencies to integrate environmental values into their decision making processes by considering the environmental impacts of their proposed actions and reasonable alternatives to those actions.  Serves as the local project manager of GSA involvement affecting the office, including requests for minor repairs, modifications to office space, space acquisition, and facilities security. Acts as liaison to the Directorate in the acquisition of contract workers.
11. Serves as the primary point of contact with the Government Printing Office (GPO) for receiving and accounting for blank passport books in inventory.
12. Administers the office's imprest fund monies.
13. Manages the Travel Manager System at the office, overseeing the processing of requests for travel orders and vouchers, and assisting staff in completion of these requests, ensuring timely submission of reports to the Department. 
14. Assists the ARD in the administration of the office's Internal Controls Program by conducting random verification that internal controls actions are being performed properly and on schedule.  Recommends to the ARD specific areas needing internal controls attention, and suggesting courses of action to overcome problem.  Drafts internal controls guidance for the office to be signed by the RD or ARD.  Assists the ARD in implementing internal controls recommendations resulting from Office of the Inspector General and/or Directorate Management Assessment 1nternal Controls Review (MAICR) assessment reports.
15. Serves as Safety/Security Officer conducting an effective safety program including periodic inspections, training, and corrections of hazards, when discovered.  Is responsible for writing, reviewing, and revising, as necessary, the Emergency Action Plan (EAP) for the office in the event of emergency.  Works with management to train all office personnel on the EAP and keep them advised of all changes to the EAP.  Additionally, ensures that the Simplex door and container lock combinations are changed on a regular and/or as needed basis.  Serves as one of the office’s liaisons with the resident Diplomatic Security (DS) Officer and the Supervisory Guard Officer, coordinating with Directorate headquarters, DS, and the Bureau on facility security enhancements, clearances, and building access for visitors and temporary workers.
16. Develops and presents to all new employees an authoritative orientation, including an official  Department welcome, an office security briefing, and basic office procedures.  Ensures that the orientation information and materials are up-to-date and tailored to the specific needs of the office.
17. Identifies training opportunities for improvement and advancement of office personnel; assesses specific staff training needs; gathers comprehensive information on local training available through Office of Personnel Management (OPM), United States Department of Agriculture (USDA), and other sources; and coordinates participation in such training courses with the Career Management staff.
18. Maintains and submits to the Directorate required weekly/monthly workload and FTE reports. Works with the customer service manager on required statistical reports that assist in the tracking of original workload trends and population statistics.
19. Pursues resolution of issues raised by the office with other offices of the Bureau or Department in order to elicit responses, obtain request services, or otherwise bring closure.
20. May represent the office on systems workgroups that involve the testing and evaluation of system upgrades and new production technologies.

The appellant states he spends sixty percent of his work time on passport productivity issues and undeliverable mail problems.  This includes gathering information on employee availability with Supervisory Passport Specialists, checking AWS and leave charts, and checking the Travel Document Issuance System (TDIS) for workload numbers necessary for generating the daily productivity report; tracing lost mail; and performing data collection for a long term Bureau study on RBPO mail.  The remaining forty percent is spent performing the other administrative duties described above. 

A PD is the official record of the major duties and responsibilities assigned to a position by an official with the authority to assign work.  A position is the duties and responsibilities that comprise the work performed by an employee.  Although it is expected that the duties assigned and performed will be accurately depicted in the appellant’s PD, we do not classify the position by relying on language in the PD which is not representative of the actual work performed.  Position 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.  Thus, an OPM appeal decision classifies a real operating position and not simply the PD.  Therefore, we have evaluated the work actually assigned to and performed by the appellant in determining the appropriate classification of his position.

Based on our review of the record, we have concluded the SPD overstates the difficulty and complexity of the work performed by the appellant.  For example, the SPD states he is expected to provide advice and guidance to management on administrative problems and management issues; monitor office productivity standards for local management; and identify and isolate unique systemic problems and take corrective actions, or recommend appropriate actions, to management.  However, the appellant does not perform the full range of the duties stated. None of the work samples submitted includes recommended actions.  His work does not show a significant problem-solving component, nor is it made complex by the number and range of variables involved.  The record does not show that he designs the studies used to evaluate productivity, workload, and customer satisfaction studies; he only collects the data for use by local management.  He is supposed to use quantitative analysis; i.e., the application of quantitative techniques such as statistics and stochastics, to analyze the data collected, and develop qualitative and quantitative data pertaining to workload and workload transfer data in order to retain optimum volume of work in progress.  Although the appellant develops workload data, the methodology used is limited to data collection without any accompanying analysis of the data.  He does not “manage” the budgets for supplies and awards, he only administers the amounts approved by Bureau HQ.  He is not an authorized credit card holder.  Instead, he compiles and submits purchases to GSA providers and sends invoices and bills to Bureau HQ for processing.  He is not a "project manager” but rather the point of contact with GSA for handling requests for minor repairs, modifications to office space, space acquisition, and facilities security.  He does prepare a daily productivity report to determine a daily goal of passports issued, but it is based on data from the TDIS which collects and maintains records related to applications for U.S. passports and is generated by an Excel macro application.  He is also supposed to develop and conduct studies and assessments for implementation of new methodologies and techniques proposed by the Bureau, but the record does not contain any examples.  He does consider statistical data and qualitative records when evaluating impact of long- and short-term solutions (e.g., use of overtime to accomplish the Workload Transfer Program) on passport administration, but these decisions are made from readily obtainable data.  He also inputs data for the RBPO mail study into Microsoft SharePoint, which is a Web application platform, but the study analysis itself is performed by specialists at Bureau HQ.  The record shows the supervisor is the primary point of contact with the GPO, not the appellant. He does not identify employee training needs; this determination is made by supervisors, although the appellant does provide information as to where to receive the training.  He does not assist with programming of the Office appointment and q-matic customer flow management queuing systems.  Rather, he sets and resets these automated systems.  Any required system adjustments are handled by the systems administrator, and if need be, the contactor who handles q-matic

The appellant states his PD is inaccurate because it does not adequately reflect all of his duties and responsibilities.  For example, he says it does not mention that he serves as liaison for the courier registration program to assist businesses and travel agencies serve their customers’ needs.  The PD also does not list his work on the computer refresh project with Bureau staff.  However, we will address all of the functions he does perform in support of the office administrative infrastructure and the other examples of work emphasized in his rationale for a higher grade; i.e., the handling of undeliverable mail, the transit benefits program, the employee evacuation plan, new employee orientation, and the courier registration program, in the grade determination section below.

Series, title, and standard determination

The primary purpose of this position is to monitor, evaluate, and coordinate a variety of services, programs, and systems that serve as the administrative and functional infrastructure that supports the core mission of the office.  This includes developing workload statistics, preparing budget and operational planning documents, property management, serving as liaison to various entities for administrative purposes, and similar work.  Administrative support on such matters as security, budget, financial management, personnel, general services, and other administrative services, such as orientation, transit benefits, and facility emergency evacuation planning follows written guidance and training provided by the Department. 

The record shows that in classifying the position, the agency initially found the work to be substantially similar to the purpose of the Administrative Officer Series, GS-341.  As defined in the GS-341 Administrative Officer Series flysheet, this series includes positions in which the employees are responsible for providing or obtaining a variety of management services essential to the direction and operation of an organization.  The paramount qualifications required are extensive knowledge and understanding of management principles, practices, methods and techniques, and skill in integrating management services with the general management of an organization.  The performance of work covered by this series requires a high order of analytical ability; the use of sound judgment and imagination in applying the practices, theories, techniques, and methodology of management in solving problems; the ability to communicate effectively orally and in writing; etc.  The flysheet’s explanatory statement states, in pertinent part:

Ordinarily, he has a responsible role in the management of both financial and human resources because of his immediate relationship to the operating manager. He generally does key work in several other vital functions or services such as management analysis, procurement, contract administration, property management, space management, security administration, reports management, data processing, and similar or closely related activities.

Based on this language, the agency determined the GS-341 series to be inappropriate because “[s]ubstantially final authority in these and similar areas is not vested in the [appellant’s] position.”  As a result, the agency placed the position in the Miscellaneous Administration and Program Series, GS-301, which includes positions whose duties are to perform, supervise, or manage nonprofessional two-grade interval work for which no other series is appropriate.  However, we find the duties of, and the responsibilities and knowledge required by the appellant’s position, are a direct match to those covered by the GS-341 series and his position, therefore, is not appropriately placed in the GS-301 series.

The appellant’s duties and responsibilities, and the corresponding knowledge and skills required, match the GS-341 series.  This series includes positions responsible for providing, obtaining or negotiating for a variety of management services that support the direction and operation of an organization.  Like the appellant, Administrative Officers are expected to have an in-depth knowledge of the organization’s mission and functions, goals and objectives, operating programs and projects, position structure for carrying out those programs and projects, the kinds of positions and people needed, equipment and materials used, and financial resources needed.  They are generalists and no single functional or service area is paramount skills-wise.  Though aspects such as budget administration, human resources management, procurement, and property management assume varying degrees of importance in many positions, no single functional, resource, or service area forms a basis for the paramount skills.  The appellant’s position provides a variety of management services in support of the direction and operation of the office and requires knowledge comparable to that required for coverage by the GS-341 series.  That the appellant’s position is not vested “final authority” in these support functions is not series determinative. 

The 341 PCS prescribes only one authorized title for all non-trainee positions in this series: Administrative Officer.  Therefore, the appellant’s position is properly allocated to the GS-341 series as Administrative Officer. 

The agency applied the Administrative Analysis Grade Evaluation Guide (AAGEG; the Guide) to evaluate the appellant’s position.  The appellant does not disagree.  The record shows the appellant serves as a generalist in the administrative function in which no one area is predominant.  Therefore, after careful review of the record, we concur with the agency’s application of the Guide.

While the appellant’s program administration functions are properly allocated to the GS-341 series, we note many of his more routine duties are single-grade interval in nature and would be properly evaluated at a lower grade level than that derived in the grade determination section of this decision.  For example, in his rationale for a higher grade, the appellant emphasizes the amount of time he spends each day on resolving problems with mail returned by the U.S. Postal Service.  However, the Mail and File Series, GS-305, covers positions involving the administration, supervision, or performance of clerical work related to the processing of incoming or outgoing mail.  This was a key part of our review because the appellant spends much of his time handling the mail returned as “undeliverable.”  He also states he has written several SOPs concerning this function.  However, a careful review of the record determined that this work would not exceed the GS-7 level, which is the highest grade described in the PCS for this type of work.  Similarly, other types of one-grade interval work performed by the appellant, such as the purchasing of supplies, which is covered by the GS-1105 series, and human resources liaison work, which is covered by the GS-203 series, do not individually constitute a significant enough portion of his time to be considered grade-controlling and would not exceed the grade level derived in the grade determination section of this decision.  Therefore, these functions are not evaluated separately in this decision.

Grade determination

The Guide is written in the Factor Evaluation System (FES) format, under which factor levels and accompanying point values are to be assigned for each of the nine factors below, with the total then being converted to a grade level by use of the grade conversion table provided in the standard.  The factor point values mark the lower end of the ranges for the indicated factor levels.  For a position to warrant a given point value, it must be fully equivalent to the overall intent of the selected factor level description (FLD).  If the position fails in any significant aspect to meet a particular factor level description, the point value for the next lower factor level must be assigned, unless the deficiency is balanced by an equally important aspect that meets a higher level.

The appellant believes his position should be classified to a higher grade for his work involving the handling of undeliverable mail, the transit benefits program, the employee evacuation plan, new employee orientation, and the courier registration program.  Using the Guide, the agency assigned Levels 1-7, 2-4, 3-3, 4-4, 5-3, 6-3, 7-b, 8-1, and 9-1.  The appellant believes his position should be evaluated at Levels 3-4, 4-5, 5-4, and 7-c, but does not challenge the evaluation of the remaining factors.  After careful review of the record, however, we have decided to evaluate Factors 1 through 7 due to the finding that the SPD overstates the types and levels of work performed while omitting other duties and responsibilities, as noted. 

Factor 1, Knowledge required of the position

This factor measures the nature and extent of information an employee must understand in order to do the work and the skills needed to apply that knowledge.

The agency assigned Level 1-7, and the appellant does not disagree.  However, he states the agency failed to recognize that his daily work with undeliverable vital records and passport documents calls upon his adjudication experience which requires knowledge of both the U.S. Code of Federal Regulations (CFR) and the Foreign Affairs Manual (FAM).

At Level 1-6, skill is required in applying analytical and evaluative techniques to the identification, consideration, and resolution of issues or problems of a procedural or factual nature.  The issues or problems deal with readily observable conditions, written guidelines covering work methods and procedures such as performance and production standards, and information of a factual nature.  Included at this level is knowledge of the theory and principles of management and organization, including administrative regulations and the operating practices and procedures common to the organization, such as those pertaining to areas of responsibility, channels of communication, delegation of authority, routing of correspondence, filing systems, and storage of files and records.

Level 1-6 is met.  The appellant’s administrative analysis and support functions are of a comparable procedural or factual nature. For example, he tracks passport productivity and monitors workspace and telecommunications/computer requirements based on readily observable conditions.   His work in administering the emergency preparedness plan, serving as the point of contact for HR and payroll, responding to requests for new equipment and changes in phone lines, reviewing funds availability as part of his budget administration functions, and providing procurement services are performed within the same context; i.e., a small, single-mission document processing organization functioning within the parameters of bureau-level program directives.  The appellant applies knowledge and skill typical of Level 1-6, including knowledge of pertinent parts of the CFR, in providing a variety of administrative functions to ensure that the needs of the organization are met, and knowledge of the FAM as it relates to the office's operating procedures. 

The position does not meet Level 1-7, where employees use knowledge and skill in applying analytical and evaluative methods and techniques to issues or studies concerning the efficiency and effectiveness of substantive administrative support functions such as supply, budget, procurement, or personnel which serve to facilitate line or program operations.  At this level, projects and studies typically require knowledge of the major issues, program goals and objectives, work processes, and administrative operations of the organization and pertinent laws, regulations, policies, and precedents.  Employees plan studies and projects and develop new or modified work methods, organizational structures, records and files, management processes, staffing patterns, procedures for administering program services, guidelines, etc.  They conduct detailed analyses of complex functions and work processes at a military headquarters or field installation or organization of equivalent scope and complexity.

The appellant has responsibilities for management analysis and advice, trouble-shooting, budget, supply, property, travel, security, and safety which concern the efficiency and effectiveness of substantive administrative support functions and require knowledge of pertinent regulations and guidelines.  While he does perform limited functional studies concerning passport productivity and undeliverable mail, he does not directly develop or modify work methods, organizational structures, records and files, or management processes as intended at Level 1-7.  Instead, his work involves advising management in a small organization of under 100 employees where the analytical and administrative support functions he performs generally are based on the application of well-established techniques and methods common to the organization and factual and readily available information.  The appellant’s studies and projects do not have the broad scope and complexity typical of Level 1-7.

Level 1-6 is credited for 950 points.

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 agency assigned Level 2-4, and the appellant agrees.

At Level 2-3, the supervisor assigns specific projects in terms of issues, organizations, functions, or work processes to be studied, sets deadlines for completing the work, and provides assistance on controversial issues or in applying analytical techniques when precedent studies are not available.  The employee plans, coordinates, and carries out the successive steps in fact-finding and analysis of issues.  Work is reviewed for conformance with overall requirements, consistency, choice of analytical methods, and practicality of recommendations.  As is typical at Level 2-3, the appellant functions independently and plans, coordinates, and carries out assignments according to accepted office policy, precedent, and/or regulations.  He resolves most problems encountered by application of established policies and precedents or contacts the Bureau headquarters or other staff for assistance.  Personnel actions, budget, and other documents are reviewed and signed by the supervisor.  Work is reviewed in terms of overall accomplishments through results achieved 

Level 2-4 is not met.  At Level 2-4, the employee and supervisor develop mutually acceptable project plans which typically include identification of the work to be done, the scope of the project, and deadlines for completion.  Within the parameters of the project, the employee is responsible for planning and organizing the project steps, estimating costs, coordinating with staff and line management personnel, conducting all phases of the project, and keeping the supervisor informed of controversial or widely impacting problems.  This frequently involves the definitive interpretation of regulations and study procedures.  Unlike Level 2-4, the appellant’s work assignments do not typically require him to make definitive interpretations of regulations and procedures.  This is done by Bureau headquarters staff.

For example, typical of Level 2-3, the appellant is coordinating the computer refresh project with Bureau staff to meet program goals and requirements as part of the Department’s Global Information Technology Modernization program.  The program provides a 4-year modernization cycle to ensure that every domestic and overseas classified and unclassified system is modernized.  This and his other recurring assignments involve working within established parameters; e.g., budget and other functions have established regulations, procedures, and precedents which cover most areas of responsibility.  Thus, his assignments do not normally involve performing studies and projects having the scope and complexity intended at Level 2-4 nor does the organizational context in which he works require the comparable plan development and identification of project work, scope, and deadlines found at this level. 

Level 2-3 is credited for 275 points.

Factor 3, Guidelines

This factor covers the nature of the guidelines used and the judgment needed to apply them.

The agency assigned Level 3-3, but the appellant disagrees.  In his rationale, the appellant lists a number of administrative services he believes warrant classification to a higher grade, such as orienting new employees, coordinating the transit benefit program, preparing the local facility emergency evacuation plan, and coordinating the courier registration program.  He states he develops or administers these programs without any written guidance or training from the Bureau.   

At Level 3-3, guidelines consist of standard reference material, texts, and manuals covering the application of analytical methods and techniques (statistical, descriptive, or evaluative) and instructions and manuals covering the subjects involved (e.g., organizations, equipment, procedures, policies, and regulations).  The employee uses judgment in choosing, interpreting, or adapting available guidelines to specific issues or subjects studied.  As at Level 3-3, the appellant uses policy statements, OPM and agency regulations, standards, directives and administrative orders, and other Federal government supply, budget, and procurement regulations.  Some judgment is required in interpreting and selecting the right guideline in light of the specific issue.  Most agency procedures do not require further refinement for office use.  The appellant is responsible for developing any necessary procedures for administrative areas, but generally they relate to straightforward issues such as an orientation plan, emergency escape plan, or steps for processing various administrative actions.  This is generally comparable to the application of a wide variety of administrative regulations cited at Level 3-3 and meets the intent of that level.  Analytical methods contained in the guidelines are not always directly applicable to specific work assignments.  However, precedent studies of similar subjects are available for reference. 

Level 3-4 is not met.  At this level, guidelines consist of general administrative policies and management and organizational theories which require considerable adaptation and/or interpretation for application to issues and problems studied.  At this level, administrative policies and precedent studies provide a basic outline of the results desired, but do not go into detail as to the methods used to accomplish the project.  The appellant states he orients new employees using an orientation program he developed, but the record shows he provides routine information available on the agency website.    In addition, the appellant has been delegated authority to certify expenses for employees eligible to participate in the Department of Transportation Transit Benefits Program as outlined in Executive Order 13150, “Federal Workforce Transportation,” April 21, 2000, and related statutory, regulatory, and administrative standards.  He states he administers the program locally, which subsidizes commuting costs for eligible employees.  Guidance for this program is readily available on the Department website showing that State administers a Transit Benefits Program which encourages employees to use public transportation for commuting to and from work on a regular and ongoing basis.  Unlike Level 3-4, the appellant’s work does not require adapting or interpreting policies and precedents or determining the methodology to be used.  Instead, his guidelines generally are directly applicable to his assignments, although they may require some interpretation.  This represents a more detailed and specific type of guidance than the general administrative guidelines and management theories described at Level 3-4.

Level 3-3 is credited for 275 points.

Factor 4, Complexity

This factor covers the nature, number, variety, and intricacy of tasks or processes in the work performed; the difficulty in identifying what needs to be done; and the difficulty and originality involved in performing the work.

The agency assigned Level 4-4 and the appellant agrees.

At Level 4-3, the work principally involves dealing with problems and relationships of a procedural nature and requiring application of accepted analytical techniques.  Projects usually take place within organizations with related functions and objectives.  Findings and recommendations are based on analysis of work observations, review of records or other documents, research of precedent studies, and application of standard administrative guidelines.  Typical of Level 4-3, the appellant’s work largely involves using accepted methods and techniques to handle factual and procedural aspects of administrative support services for a small organization with related functions.  Most analysis is based on observable conditions and review of records.  The appellant assesses needs, takes or directs action to accomplish tasks, and resolves problems or provides necessary advice.  The issues vary; e.g., they may include returned mail, request backlogs, overtime, supplies, and new equipment.  The appellant participates with management in program planning activities and provides advice based on application of established regulations, directives, procedures, guidelines, and precedents.

Level 4-4 is not met.  At this level, the work involves gathering information, identifying and analyzing issues, and developing recommendations to resolve substantive problems of effectiveness and efficiency of work operations in a program or program support setting.  Work at this level requires the application of qualitative and quantitative analytical techniques which frequently require modification to fit a wider range of variables.  Subjects and projects assigned at this level usually consist of issues, problems, or concepts which are not always susceptible to direct observation and analysis.  The appellant’s work with budget and other support services does not involve comparable substantive problems.  For example, he tracks spending for supplies and contract work, training and awards, and property and prepares annual budget requests for routine administrative expenses; performs procurement officer type work (e.g., securing critical supplies and construction services); and works with Directorate HQ to excess unneeded property by way of GSA auctions.  These and other assignments, unlike Level 4-4, generally relate to factual and procedural matters such as budget, supplies, services, facilities, time and attendance, and other administrative services, and are usually susceptible to direct observation and analysis.  The appellant occasionally develops procedures relating to workflow.  However, the small size of the organization limits the scope of administrative subjects and projects and, ultimately, the associated problems.  The record does not show the work of the organization requires the modification of qualitative and quantitative analytical techniques, typical of Level 4-4, in order to fit a wide range of variables. 

Level 4-3 is met for 150 points.

Factor 5, Scope and effect

This factor covers the relationship between the nature of the work and the effect of work products or services both within and outside the organization.

The agency assigned Level 5-3, but the appellant disagrees because he believes his work with the courier program is national in scope, as private courier companies registered in [City] are often registered in many other U.S. locations, and a courier incident here, such as a suspension, or a courier drop action based on lack of business, is routinely applied across the passport system as the companies maintain numerous registrations. 

At Level 5-3, the purpose of the work is to plan and carry out projects having conventional problems to improve the efficiency and productivity of organizations and employees in administrative support activities.  Completed reports and recommendations influence decisions by managers concerning the internal administrative operations of the organizations and activities studied.  The purpose of the appellant’s work is comparable to Level 5-3 in that it is to ensure the efficiency and effectiveness of administrative support activities for the Office.  The appellant analyzes and makes recommendations to resolve conventional office problems in the areas of human resources, budget, procurement, equipment, communications, space, record keeping, security, and service contracts.  He prepares standard operating procedures (SOPs) to clarify procedures to be followed in the Office.  As at Level 5-3, his advice on performance and work issues influences management decisions and improves work productivity of the office.

Level 5-4 is not met.  At this level, the purpose of the work is to analyze and resolve problems in the staffing, effectiveness, and efficiency of administrative support and staff activities.  Work at this level may include developing related administrative regulations, such as those governing the allocation and distribution of personnel, supplies, equipment and other resources, or promulgating program guidance for application across organizational lines or in varied geographic locations.  Work contributes to the improvement of productivity, effectiveness, and efficiency in program operations and/or administrative support activities at different echelons and/or geographical locations within the organization.  While the appellant is concerned with determining the effectiveness of the administrative support program, he is not involved, as at Level 5-4, in developing administrative regulations or promulgating program guidance for use across organizational lines or at varied organizational locations.  For example, he is assigned to review and keep current the Emergency Action Plan (EAP).  The Federal Occupant Emergency Plan establishes procedures for safeguarding lives and property during emergencies in specific federally leased space under stipulated emergency conditions.  However, this and other work, including his liaison with courier companies, involves providing administrative support work to a small organization with most employees at one site.  That an office courier incident may lead to agency-wide suspension of that courier service is not a decision vested in the appellant’s position.  Higher echelons maintain significant control over functional operations, particularly those involving financial and HR resources, and are responsible for pertinent regulations and guidance found at Level 5-4.

Level 5-3 is credited for 150 points.

Factor 6, Personal contacts, and Factor 7, Purpose of contacts

These factors measure the nature and purpose of personal contacts. 

These two factors are interdependent.  The relationship between Factors 6 and 7 presumes the same contacts will be evaluated under both factors.  Personal contacts include face-to-face and telephone contacts with persons not in the supervisory chain.  The nature of the discourse defines the reason for the communication and the context or environment in which the communication takes place.  The levels of these factors; i.e., the FLDs described under each 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.

Persons Contacted

The agency assigned Level 6-3 under Persons Contacted, but the appellant in his appeal rationale stated his agency failed to credit him with any points for Factor 6.  He also believes he should be credited with 120 (not 110) points for Factor 7.  However, the record shows this issue resulted from a misreading of the point chart in the Guide.  That is, once the appropriate level for personal contacts and the corresponding level for purpose of contacts are determined, the point value for these factors are obtained from the intersection of the two levels as shown on the point assignment chart contained in the Guide.

Level 3 is met.  The appellant's contacts are comparable to this level in that they are with office heads, headquarters personnel, field personnel, co-workers, representatives of other Federal and State agencies and educational institutions, Congressional staffers, various vendors for goods and services, and the general public.  For example, the appellant serves as liaison for the courier registration program to assist businesses and travel agencies serve their customers’ needs.  Passport expeditor/courier services are private, third party companies, some of which are registered at passport agencies and are allowed to submit expedited passport applications on behalf of customers.  The appellant performs liaison service to the registered courier services.  Overall, his contacts frequently are not structured and the content and extent are normally established during the course of the contact.

Level 4 is not met.  The appellant does not have contacts with high-ranking officials such as agency heads, top Congressional staff officials, State executive or legislative leaders, or other equivalently high-level officials in highly unstructured settings.

Purpose of Contacts

The agency assigned Level b under Persons Contacted.  The appellant disagrees, saying he should be credited with Level c because he provides information services, passport expertise, and guidance in regards to passport operations at the office in person and by telephone. 

Level b is met.  As at this level, the appellant provides advice and guidance to management on administrative problems and management issues.  He also participates in the development of local policies and prepares SOPs implementing program changes issued from Bureau HQ.  He identifies resources to enhance and improve passport services, and uses considerable tact and diplomacy in convincing office managers and supervisors of proposed recommendations for improvement of workflow and streamlining processes. 

Level c is not met, where contacts are to influence managers to accept recommendations on organizational or program improvement where resistance may be encountered due to such issues as organizational conflict or resource problems.  The record does not show evidence of such resistance.

Together, Factors 6 and 7 are assigned Level 3b.  The points assigned are determined by the intersection of the relationship of both Factors 6 and 7 as found in the chart within the Guide; i.e., assigning Levels 6-3 and 7-b equates to 110 points. 

Factors 6 and 7 are evaluated at Level 3b and credited with 110 points.

Summary

Factor	Level	Points
1.  Knowledge required by the position	1-6	950
2.  Supervisory controls	2-3	275
3.  Guidelines	3-3	275
4.  Complexity	4-3	150
5.  Scope and Effect	5-3	150
6&7.   Personal Contacts & Purpose of contacts	3-b	110
8.  Physical demands	8-1	5
9.  Work environment	9-1	5
Total points		1920

The total of 1920 points falls within the GS-9 point range (1855-2100 points) in the AAGEG.

Decision

The appellant’s position is properly classified as Administrative Officer, GS-341-9.

 

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