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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

Karen Buckhanan
Administrative Officer
Business Office
Administrative Service
Veterans Affairs Medical Center
Veterans Health Administration
U. S. Department of Veterans Affairs
Shreveport, Louisiana
Administrative Officer

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, 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 May 30, 2014, OPM’s Agency Compliance and Evaluation (ACE)-Dallas accepted a classification appeal from Ms. Karen Buckhanan and on July 22, 2014, it was transferred to ACE-Philadelphia for adjudication.  The appellant’s position is currently classified as Administrative Officer, GS-341-9, and is located in the Business Office, Administrative Service, Overton Brooks Veterans Affairs Medical Center (VAMC), Veterans Health Administration (VHA), U. S. Department of Veterans Affairs (VA), in Shreveport, Louisiana.  The appellant believes her position should be upgraded to the GS-11 grade level.  We received the complete agency administrative report on June 9, 2014, and have accepted and decided this appeal under section 5112(b) of title 5, United States Code (U.S.C.).

To help us decide the appeal, we conducted telephone interviews with the appellant on August 1, 4, 8, 12, and 28, and September 30, 2014, and her immediate supervisor on August 14 and 15, 2014.  In reaching our decision, we have carefully considered all of the information obtained from the interviews, as well as all other information of record provided by the appellant and her agency.

Background and general issues

The appellant’s supervisor prepared, and certified the accuracy of an Administrative Officer position description (PD) on August 28, 2013 which the Veterans Integrated Service Network (VISN) 16 Classification Unit classified on September 13, 2013, as Administrative Officer, GS-341-11.  On October 21, 2013, her supervisor requested approval for a non-competitive promotion for the appellant.  Although the VAMC Associate Director signed the request on October 22, 2013, the signature did not indicate whether the request was approved or disapproved.  The record showed the VISN 16 Classification Unit reviewed the PD again on December 20, 2013, and classified the position at the GS-9 grade level.  The appellant filed a classification appeal with VA headquarters Compensation and Classification Service on March 17, 2014, and in an April 10, 2014, letter, she was notified that the agency determined her position was appropriately classified as Administrative Officer, GS-341-9.  On April 17, 2014, the appellant appealed the classification of her position to OPM, explaining in her appeal request:

The position description is accurate but differs in the factor level analysis of assigned points by the classifier.  This position description was classified at the GS-11 level by the same classifier in September 2013, but later came back and changed the points under the factor level descriptions.  There were no changes in the duties of the position description…In addition, Human Resources indicated that due to a classification appeal decision dated December 23, 2013, all Administrative Officer position descriptions should be classified at the GS-9.

In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of the appellant’s position.  Because our decision sets aside all previous agency decisions, any concerns regarding the agency’s classification review of her position are not germane to this decision.

Position information

The appellant’s position reports directly to the Business Office Chief and performs administrative support activities for the Business Office, consisting of 178 authorized full time equivalent (FTE) positions, including title 38, title 38 hybrid, and title 5 positions.

The appellant performs the following management and program support functions:  She is responsible for extracting data from various databases, such as the VHA Support Service Center (VSSC) and the Veteran Information System and Technology Architecture (VISTA) databases, to prepare various types of reports.  For example, she extracts data from VISTA, imports the data into Microsoft Excel, prepares the daily report of patient gains/losses for the VAMC, and posts it on a shared drive.  With regard to improving Business Office operations, she compares data such as spending costs on non-VA care (physical therapy, dialysis, eye glasses) to determine whether the VAMC should hire another employee to provide these services instead.  She also performs time and motion surveys to determine the time it takes Business Office employees to perform certain tasks or processes.  For example, she measured the time it takes medical support clerks to register patients.  She examined the results to determine whether additional or fewer FTE were needed and whether there was another method for efficiently accomplishing the work, and prepared and submitted her recommendations to the Business Office Chief for consideration.

She reviews any VA, VHA, or VISN 16 policies associated with Business Office operations and, after speaking to Business Office subject matter experts, drafts local guidance.  Her supervisor then reviews the draft local guidance prior to review and comment by other VAMC services.  The appellant will discuss the comments received from other VAMC services with the Business Office Chief, make any revisions, and forward the revised document o the VAMC Director for approval and signature.  The appellant ensures the Business Office-issued policies/procedures are current and unexpired and that Business Office staff competency folders contain current copies of certifications, credentials, and other required documents for when a Joint Commission team arrives to conduct an evaluation.

The appellant performs the following contracting support functions.  With regard to contracting for lease and/or purchase of new office equipment throughout the VAMC, such as scanners, fax machines, or copiers; or procurement of services, such as shredding, she contacts vendors, obtains comparison quotes, reviews historical acquisition information for similar procurements, and prepares statements of work.  She speaks to the Contracting Officer, (CO), Business Office Contracting Officer’s Representatives (CORs), and others to determine the types of equipment or services needed for the VAMC, and adds the billing and service requirements to the performance work statements.  The appellant prepares the criteria used to evaluate vendor proposals on a contract or equipment purchase, which is approved by the CO.  After the CO posts the contract on the internet for bids and receives proposals from vendors, the appellant, her supervisor, the CO, and the COR review the proposals and assign each a rating.  After the contract is awarded and in place, the appellant may need to prepare a contract modification, which is approved by the CO.

The appellant performs similar performance work statement and related functions with the CORs for contracts in support of their respective program areas including the veterans’ burial services contract which is used when a deceased veteran’s body is not claimed and the VAMC is responsible for burial of the veteran.  The COR ensures the funeral home processes the bodies for burial as agreed to in the contract and reviews the bills for accuracy.  Because of the high volume of outgoing mail throughout the VAMC, the presort mail services contract is used to obtain discounts on United States Postal Service (USPS) postage.  The COR for that contract maintains a daily count of outgoing mail and the vendor picks up hundreds of pieces of mail daily for pre-sorting.  The COR reviews the monthly bills from the vendor for accuracy.  The mail postage machine lease contract is used to lease equipment to pay for and attach USPS postage on outgoing mail throughout the VAMC.  The VAMC establishes accounts with the vendor and with the USPS to transfer funds for postage onto the mail postage machine.  The COR for that contract monitors the amount of funds on the mail postage machine to ensure the accuracy of the bill.  The reproduction copier lease contract is used to lease a piece of equipment for printing a fixed number of brochures, books, and large manuals for the VAMC.  The COR for that contract reviews the bill for accuracy by ensuring the number of copies printed is accurate.  The appellant receives and reviews the bills from the CORs, authorizes them for payment, and forwards them to the Financial Services Center (FSC) in Austin, TX for payment.

The copier supply contract provides toner and staples for the copiers throughout the VAMC.  The COR maintains an adequate supply of toner and staples so that he can fulfill the requests for supplies from the VAMC services.  The COR reviews the bills and verifies their accuracy.  The shredding services contract is used to ensure the proper disposal of up to 85 bins of sensitive information monthly throughout the VAMC.  The COR reviews the bill and verifies its accuracy.  The appellant receives and reviews the bill from the CORs, authorizes it for payment, and forwards it to the FSC for payment.

The telephone operator services contract provides telephone operator services when insufficient VAMC employees are available.  The COR ensures the contract telephone operators are courteous and are aware of various codes used within the hospital e.g., “code blue.”  When the appellant is notified of the absence of a permanent FTE telephone operator, she checks the amount of funds available in the control point to see if there are funds to cover the costs of an additional contract telephone operator.  If sufficient funds are not available, she prepares a request for additional funding to the Business Office Chief for his review and approval before forwarding it to the VAMC Resource Management Committee (RMC) for consideration.

The appellant provides budget and financial support to the Business Office.  She compiles the budget for the Business Office in response to the call for the annual business plan using the template provided by the Fiscal Service.  The appellant reviews the funding for contracts and control points, and compares the funding to previous fiscal years to ensure the Business Office has sufficient funds for the next fiscal year.  Once the budget request is developed, the appellant forwards it to the Business Office Chief for review and approval and then to Fiscal Service.  The VAMC senior leadership team conducts the budget briefing attended by the Business Office Chief and other Service Chiefs.  If the Business Office Chief does not attend the budget briefing or asks the appellant to discuss certain line items, she will discuss the agreed line items or conduct the Business Office portion of the briefing, presenting the budget line-by-line and answering any questions.

The appellant regularly checks the administrative and medical control points controlled by the Business Office.  She updates her personally developed spreadsheets, monitors the balances through VISTA, and ensures the bills are paid timely and correctly.  If she notices funding will be insufficient for one of the administrative control points, she will review the funding level of the other administrative control points to see if funds can be transferred.  If this occurs, the appellant prepares a funds transfer request to the Business Office Chief for his approval before it is submitted to the Fiscal Service, which transfers the funds.  If she notices funding will be insufficient for one of the medical control points, she prepares a request for additional funding to the Business Office Chief for his review and approval before forwarding it to the VAMC RMC for consideration.

The budget for the Business Office includes funding for the beneficiary travel program and Fiscal Service allocates the funds into the control point as requested.  On a monthly basis, the beneficiary travel clerk sends a request to the appellant for funds to be added to the control point for disbursement of travel payments such as airline or bus tickets.  The appellant then forwards the request to Fiscal Service to allocate funds.  The appellant reviews the bills the beneficiary travel clerk receives and forwards them to the FSC for payment.  If funds appear to be insufficient, the appellant will prepare a request for additional funding to the Business Office Chief for review and approval by the RMC.

The Business Office manages funding for non-VA medical care, such as physical therapy, home health care services, eye glasses, or dialysis services, is included in the VAMC’s annual operating budget, which is allocated by Veterans Integrated Service Network (VISN) 16 based on the prior years’ spending.  The Fiscal Service receives the funds and allocates the money on a monthly basis into the control point.  The non-VA medical care clerk disburses the funds and the appellant reviews the bills and forwards them for payment to the Consolidated Fee Unit in Jackson, Mississippi.  If funds appear to be insufficient, Fiscal Service prepares a request for additional funding to VISN 16.

The appellant also develops and monitors the expenditures of funds for the previous described contracts.  She prepares justifications for additional resources not provided for in the approved budget or the projected needs of the Business Office.  Once a justification is completed, the appellant forwards it to the Business Office Chief for review and approval and then to the RMC for consideration.  She may also present the request to the RMC if directed to by the Business Office Chief.  If she locates discrepancies between Fiscal Service records and her own, she uses VISTA to review transactions to determine where the error lies and works with Fiscal Service to resolve them.

The appellant performs the following human resources (HR) support functions:  She serves as the administrator of the Talent Management System (TMS), where she establishes and maintains the training records for Business Office employees and resets passwords.  She prepares a monthly report to ensure Business Office employees have completed the annual “Rules of Behavior” training so they may maintain their VA computer access.  She assists Business Office supervisors with employee relations issues, e.g., sick leave abuse, tardiness, and posting time and attendance.  If a supervisor has questions concerning such matters, he or she contacts the appellant.  She discusses the situation with the supervisor, contacts HR to find out how to proceed, and provides the information to the supervisor.  The appellant provides information to Business Office employees on other HR matters, such as the title 38 hybrid boarding and promotion process, requesting leave without pay, and information on the Family and Medical Leave Act.  If she is unable to resolve the issues based on her knowledge of VA, VHA, and OPM guidelines and regulations, or she will contact HR for assistance.

When a supervisor has a vacant position, he or she contacts the appellant, who will discuss the situation to determine whether a current PD exists and can be used or needs revision and assists supervisors in doing so.  If the supervisor submits a new or revised PD, the appellant will review it to verify it contains all of the duties to be performed, adding any missing duties before forwarding it to the VISN 16 Classification Unit for classification.  If the grade level assigned does not match the one requested by the Business Office, the appellant will notify the Business Office Chief and meets with the supervisor and the Business Office Chief to discuss how to proceed.  After a new PD is classified, the appellant will prepare the necessary justifications for the RMC to approve filling the vacant position.  Once approved, the appellant submits a Standard Form 52 and PD to the HR for recruitment, and works with HR to advertise the vacancy develop the criteria for ranking qualified applicants.  The appellant assists supervisors in preparing performance-based interview questions and coordinates the entrance on duty dates with HR and the supervisor after selections are made.

The appellant gathers and submits the performance ratings for Business Office employees to HR at the end of the rating period.  She also ensures supervisors conduct the mid-year assessments for their subordinate employees.  The appellant helps the supervisors establish and maintain competency folders for each employee, so that they are complete.

She is an approved certifier for the Business Office time cards in the absence of supervisors.  She compiles the leave, overtime, compensatory time, etc. for each Business Office employee and prepares a report for the Business Office Chief.

The appellant serves as the alternate Automated Data Packages Application Coordinator (ADPAC) in the absence of the ADPAC.  In this role, she supports the VAMC scheduling computer software by making system changes.  For example, if a clinic wants to change the amount of time between each appointment, the appellant will implement the change.  The appellant also supports the beneficiary travel computer software by responding to inquiries from clerks who enter patient information, calculate the mileage, etc.

After careful review, we find the appellant’s PD meets the standards of adequacy for classification purposes as discussed in section III.E of the Introduction and we incorporate it by reference into our decision.

Series, title, and standard determination

The appellant does not question the series or title of her position or use of the grading criteria in the Administrative Analysis Grade Evaluation Guide (AAGEG) to evaluate her position, since the GS-341 position classification standard (PCS) contains no grading criteria.  Based on a review of the record, we concur that her position is correctly allocated to the GS-341 series, in accordance with the titling instructions of the GS-341 PCS, her position is titled Administrative Officer and is properly evaluated by application of the AAGEG.

Grade determination

The AAGEG uses the Factor Evaluation System (FES), which employs nine factors.  Under the FES, each factor level description in a PCS describes the minimum characteristics needed to receive credit for the described level.  Therefore, 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.  Each factor level has a corresponding point value.  The total points assigned are converted to a grade by use of the grade conversion table in the PCS.

Factor 1, Knowledge Required by the Position

This factor measures the nature and extent of information or facts a worker must understand in order to do acceptable work and the nature and extent of skills needed to apply that knowledge.

At Level 1-6, employees apply 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, and information of a factual nature.  Included at this level is knowledge of the theory and principles of management and organization, including administrative practices and procedures common to organizations; e.g., channels of communication, delegations of authority, routing of correspondence, filing systems, and storage of files and records.

Level 1-6 is met.  As at this level, the appellant’s administrative analysis and support functions are of a comparable procedural or factual nature.  For example, when a decedent affairs clerk was preparing to separate from the Business Office, the Business Office Chief requested a review to determine whether or not they needed to fill the decedent affairs clerk position.  The appellant spoke to the departing employee and found out he was performing additional duties.  Based on a review of the departing employee’s work, she recommended abolishing the position and assigning its duties to others in the Business Office.  Also comparable to Level 1-6, the appellant is responsible for monitoring performance measures regarding patient registration.  By pulling data from various VA databases, the appellant determines whether the medical support clerks are omitting important data.  When registrations are not completed properly, the VAMC may not receive funding for the patients it serves and the performance measures are inaccurate.  The appellant’s budget, fiscal, and HR support functions also involve dealing with readily observable conditions and information of a factual nature.  As at Level 1-6, written guidelines cover work methods and procedures.  For example, the appellant reviews the current budget, the VAMC goals for the Business Office, and any projected needs; e.g. equipment, supplies, and workload requirements prior to compiling the annual business plan for the next fiscal year, using the template provided by the Fiscal Service.

At Level 1-7, in addition to knowledge required at Level 1-6, assignments require knowledge and skill in applying analytical and evaluative methods and techniques to study the efficiency and effectiveness of program operations carried out by administrative or professional personnel or substantive administrative support functions.  This level includes knowledge of pertinent laws, regulations, policies, and precedents which affect the use of program and related support resources in the area being studied.  This knowledge is used to plan, schedule, and conduct studies to evaluate and recommend ways to improve the effectiveness and efficiency of work operations, program effectiveness, and/or organizational productivity.  Knowledge at this level is applied in developing new or modified work methods, organizational structures, records and files, management processes, staffing patterns, procedures for administering program services, guidelines and procedures, and automating work processes for the conduct of administrative support functions or program operations.  Knowledge may also be applied in analyzing and making recommendations concerning the centralization or decentralization of operations.

Level 1-7 is not met.  The operational scope of the appellant’s position does not require or permit the application of comparable knowledge.  Her assignments result in accurate and complete data that are used by higher management levels in support of decisions concerning the efficiency and effectiveness of substantive administrative support functions and require knowledge of pertinent regulations and guidelines.  However, the appellant’s position is not responsible for conducting the depth and breadth of program or other studies found at Level 1-7.  In contrast to Level 1-7 work involving efficiency and effectiveness of programs resulting in the significant changes in organizational structures, staffing patterns, or program procedures, the appellant’s work is constrained by the limited size of the Business Office staff and its clearly defined functions.  The analytical functions she performs generally are based on the application of well-established techniques and methods common to the office and factual and readily available information, e.g., redistributing the work of a single decedent affairs position.  The record shows that the appellant’s studies and projects do not have the broad scope and analytical complexity typical of Level 1-7.

This factor is evaluated at Level 1-6 and 950 points are credited.

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.

At Level 2-3, the supervisor assigns specific projects in terms of issues, organizations, functions, or work processes to be studied and sets deadlines for completing the work.  The supervisor or higher-grade analyst provides assistance on controversial issues or on the application of qualitative and quantitative analytical methods to the study of subjects for which precedent studies are not available.  The employee independently plans, coordinates, and carries out the successive steps in fact-finding and analysis of issues necessary to complete each phase of assigned projects.  Work problems are normally resolved without reference to the supervisor in accordance with the body of accepted policies and precedents.  Work is reviewed for conformance with overall requirements as well as contribution to the objectives.  Findings and recommendations developed by the employee are reviewed prior to release, publication, or discussion with management officials.

Level 2-3 is met.  As at this level, the appellant functions independently and plans, coordinates, and carries out assignments according to accepted office policy, precedent, and/or regulations.  She resolves most problems encountered by application of established policies and precedents or contacts a subject matter expert (SME); e.g., Business Office Chief, Chief of Staff, other Service Chiefs, HR, other logistics or contracting representatives, for assistance.  If multiple assignments are received, their established deadlines create their priority.  The appellant gathers information by running reports, retrieving the information from other service points of contact, using readily available material to plan and conduct the assignment.  Most of her work is Business Office-related, and she forwards her work to the Business Office Chief for review and approval before forwarding it to the assignment originator.  As at Level 2-3, the appellant’s work products, which often include recommendations, are reviewed for conformance with VAMC requirements.  Thus, responsibility for the information disseminated by the Business Office lies with the Business Office Chief.

At Level 2-4, within a framework of priorities, funding and overall project objectives (e.g., cost reduction, better workload distribution), the employee and supervisor develop a mutually acceptable project plan which includes identification of the work to be done, the scope of the project, and deadlines for its completion.  Within the parameters of the approved plan, the employee has responsibility for planning and organizing the study, estimating costs, coordinating with staff and line management personnel, and conducting all phases of the project.  This frequently involves the definitive interpretation of regulations and study procedures, and the initial application of new methods.  The employee informs the supervisor of potentially controversial findings, issues, or problems with widespread impact.  Staff and line management officials whose programs and employees would be affected by implementation of the recommendations also review completed work critically outside the employee’s immediate office.

Level 2-4 is not fully met.  Although the appellant independently performs her duties, the assignments are limited in scope and are not so complex that they require her to work with her supervisor to develop a plan and establish project parameters and resources needed.  The appellant carries out her day-to-day work independently, developing her own schedule, setting her own priorities, gathering Business Office information or coordinating with other office staff and management personnel to retrieve needed information in order to accomplish assignments within established deadlines.  However, the record shows that the appellant is not assigned individual studies of the scope meeting Level 2-4, which require the employee to plan, organize, and conduct the phases of the study and to estimate the funds needed to conduct the study.  The limited nature of the work does not require review, comparable to Level 2-4, for feasibility and compatibility with other program requirements.  Likewise, the appellant’s position is not responsible for studies that result in recommendations of the scope envisioned at Level 2-4.

This factor is evaluated at Level 2-3 and 275 points are assigned.

Factor 3, Guidelines

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

At Level 3-3, the guidelines consist of standard reference material, texts, and manuals covering the application of analytical methods and instructions and manuals covering the subjects involved.  Analytical methods in the guidelines are not always directly applicable to work assignments.  However, precedents are available for reference.  The employee uses judgment in choosing, interpreting, or adapting available guidelines to specific issues or subjects studied. 

The employee analyzes the subject and the current guidelines and makes recommendations for change.

Level 3-3 is met.  As at this level, the appellant uses VA and VHA directives, policies, handbooks, manuals, notices, etc., VAMC guidance, title 38 regulations, OPM regulations, standards, directives, and administrative orders, and Federal government budget, supply, and procurement regulations, Joint Commission requirements, etc.  Some judgment is required in interpreting and selecting the right guideline in light of the specific issue, as in justifying additional resource needs, preparing purchasing or contracting documents, projecting budget changes due to unexpected changes in Business Office workload, projecting VAMC postage usage, etc.

At Level 3-4, guidelines consist of general administrative policies and management and organizational theories which require considerable adaptation or interpretation for application to issues and problems studied.  The 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 administrative guidelines usually cover program goals and objectives of the employing organization.  Within the context of broad regulatory guidelines, the employee may refine or develop more specific guidelines such as implementing regulations or methods for the measurement and improvement of effectiveness and productivity in the administration of operating programs.

Level 3-4 is not met.  The appellant’s work is covered by procedures and guidelines which are developed and controlled at the Joint Commission, VA, and VHA levels.  These guidelines include standard reference materials and operating manuals typical of Level 3-3 which go into detail as to the methods and procedures to be used to accomplish the work.  Responsibility for guideline interpretation found at Level 3-4 is vested in the VAMC staff offices, such as HR and Fiscal Service, with which the appellant works.  While the position’s guidelines require the use of judgment to apply, they are not so broad as the general administrative policies and management theories typical of Level 3-4.

The factor is evaluated at Level 3-3 and 275 points are assigned.

Factor 4, Complexity

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

At Level 4-3, the work principally involves dealing with problems and relationships of a procedural nature rather than the substance of work operations, issues, or other subjects studied.  At this level, the employee analyzes the issues in the assignment, then selects and applies accepted analytical techniques such as task analysis, workload measurement, and trend analysis to resolve procedural problems affecting the efficiency, effectiveness, or productivity of the organization and/or workers studied.  Projects usually take place within organizations with related functions and objectives, although organization and work procedures differ from one assignment to the next.  Organizational efficiency assignments typically involve observing work in progress to identify and resolve problems in work-flow, work methods, and procedures, task distribution, overall workload, forms and recordkeeping, span of control, and organizational structure.  When performed, evaluative studies involve measurement of current work output, group productivity and accomplishments, or identification of current resource needs; e.g., staff, supplies, equipment, and space.  Findings and recommendations are based upon analysis of work observations, review of production records or similar documentation, research of precedent studies, and application of standard administrative guidelines.

Level 4-3 is met.  Similar to this level, the appellant’s work mostly involves using accepted methods and techniques to handle factual and procedural aspects of administrative support functions for a small office with related functions.  Most analysis is based on observable conditions and review of records, e.g., studying the decedent affairs clerk’s workload and measuring the time it took medical support clerks to register patients.  The appellant assesses needs, takes or directs action to accomplish tasks, and resolves problems or provides recommendations.  As at Level 4-3, she evaluates the Business Office’s compliance with nationally established goals and objectives and employee compliance with patient registration performance standards by running reports and comparing the data to established requirements.  When compiling a budget request, the appellant reviews the current budget, VAMC goals for the Business Office, and projected needs such as additional funding, equipment and supplies.  When positions are being filled, she develops interview questions based on the performance requirements of the position.  Typical of Level 4-3, the appellant compares factual data to specific standards or requirements as shown in the above examples.

At Level 4-4, 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 setting.  Subjects and projects assigned at this level usually consist of issues, problems, or concepts that are not always susceptible to direct observation and analysis.  Difficulty is encountered in measuring effectiveness and productivity due to variations in the nature of administrative processes studied and information that is conflicting or incomplete or cannot readily be obtained by direct means.  At this level, assignments may involve compiling, reconciling, and correlating voluminous workload data from a variety of sources with different reporting requirements and formats, or the data must be carefully cross-checked, analyzed, and interpreted to obtain accurate and relevant information.  Characteristic of work at this level is originality in refining existing work methods and techniques for application to the analysis of specific issues or resolution of problems.  For example, the employee may revise methods for collecting data on workload, adopt new measures of productivity, or develop new approaches to relate productivity measurements to a performance appraisal system.

Level 4-4 is not met.  The appellant’s assignments and support service functions do not involve comparable substantive problems.  Unlike Level 4-4, her assignments generally relate to factual and procedural matters; i.e., comparing factual data to specific requirements, and administrative services such as budget, purchasing, supplies, HR, and time and attendance which present issues which are usually susceptible to direct observation and analysis.  Illustrative of work at Level 4-4 is an employee who studies, analyzes, and develops methods to improve the accuracy, adequacy, and timeliness of information and systems for disseminating information about the agency’s programs and work force to managers at many organizational echelons and/or geographic locations.  The appellant works at a local VAMC; therefore she does not disseminate information to other echelons or geographic locations.  The small size of the appellant’s office affects the number of sources and volume of the workload data to review.  The work of the office does not require the modification of qualitative and quantitative analytical techniques, typical of Level 4-4, in order to deal with a wide range of variables.

This factor is evaluated at Level 4-3 and 150 points are credited.

Factor 5, Scope and Effect

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

At Level 5-3, employees identify, analyze, and make recommendations to resolve conventional problems and situations in workflow, work distribution, staffing, performance appraisal, organizational structure, and/or administration.  Employees may be assigned portions of broader studies of largely administrative organizations or participate in the evaluation of program effectiveness at the operating level.  Completed reports and recommendations influence decisions by managers concerning the internal administrative operations of the organizations and activities studied.

Level 5-3 is met.  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 Business Office; i.e., an operating-level organization.  The appellant compares factual data to specific requirements to resolve conventional problems in areas such as budget, purchasing, equipment, and contracts.  For example, she conducts time studies to determine the number of employees needed to perform a function within the Business Office and determines whether nationally established performance measures concerning patient registration goals are being met.  Like Level 5-3, her advice on performance and work issues influences management decisions and improves Business Office work productivity.

At Level 5-4, the purpose of the work is to assess the productivity, effectiveness, and efficiency of program operations or to analyze and resolve problems in the staffing, effectiveness and efficiency of administrative support and staff activities.  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.  Work affects the plans, goals, and effectiveness of the missions and programs at these various echelons or locations.

Level 5-4 is not met.  While the appellant is concerned with determining the effectiveness of the administrative support program, she is not usually involved, as employees at Level 5-4, in developing administrative regulations or promulgating program guidance for use across organizational lines or at varied organizational locations.  In contrast, she provides service to the Business Office, a small organization with most employees at one site, in an operating-level activity.  Higher echelons within VA maintain significant control over administrative operations and are responsible for the scope and impact of work found at Level 5-4.

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

Level 3 is met.  The appellant's contacts are comparable to this level in that they are with patients, families, visitors, non-VA medical and allied health professionals, VISN 16 staff members, and various vendors providing goods or services.  For example, she interacts with vendors to arrange for training classes or to resolve discrepancies with bills.  Her contacts with non-VA staff 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

Level b is met.  As at this level, the appellant provides advice and guidance to management officials on administrative problems and management issues.  She also participates in the development of local procedures and updates existing procedures in accordance with changes issued by VISN 16 or VHA. 

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 the appellant encounters resistance or is routinely required to use the level of influence described at this level.

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

Factor 8, Physical demands

This factor covers the requirements and physical demands placed on the employee by the work assignment.

Level 8-1 is met.  The appellant performs her work in an office setting, requiring no special physical effort.  Unlike Level 8-2, the appellant’s work does not require her to spend long periods of time standing, bending, or stooping.

This factor is evaluated at Level 8-1, and 5 points are credited.

Factor 9, Work environment

This factor considers the risks and discomforts in an employee’s physical surroundings, or the nature of the work assigned and the safety regulations required.

Level 9-1 is met.  The appellant performs her work in a typical office environment with adequate light, heat and ventilation.  Unlike Level 9-2, the appellant’s work does not require regular visits to manufacturing, storage, or other industrial areas, involve moderate risks or discomforts, wear protective clothing, or observe safety precautions.

This factor is evaluated at Level 9-1, and 5 points are credited.                   


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 1885 points falls within the GS-9 point range (1855-2100) on the grade conversion table in the AAGEG.  Therefore, the position is graded at the GS-9 level.


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




































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