Washington, D.C
U.S. Office of Personnel Management
Classification Appeal Decision
Under section 5112 of title 5, United States Code
Office of Equity and Civil Rights
National Science Foundation
Alexandria, Virginia
GS-0341-11
Damon B. Ford
Classification Appeals and FLSA Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance
05/22/2023
Date
As provided in section 511.612 of title 5, Code of Federal Regulations (CFR), this decision constitutes a certificate that is mandatory and binding on all administrative, certifying, payroll, disbursing, and accounting officials of the Government. The agency is responsible for reviewing its classification decisions for identical, similar, or related positions to ensure consistency with this decision. There is no right of further appeal. This decision is subject to discretionary review only under conditions and time limits specified in the Introduction to the Position Classification Standards (Introduction), appendix 4, section G (address provided in appendix 4, section H).
Since this decision changes the classification of the appealed position, it is to be effective no later than the beginning of the fourth pay period after the date of this decision (5 CFR 511.702). The applicable provisions of parts 536 and 752 of 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 (PD) 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 Office of Personnel Management (OPM), Merit System Accountability and Compliance, Agency Compliance and Evaluation, Washington, DC, office.
The appellant’s position is currently classified as Management and Program Analyst (Administrative Operations Coordinator), GS-0343-12, but she believes it should be classified at the GS-13 grade level. She is assigned to the Equity and Operations Branch (EOB), Office of Equity and Civil Rights (OECR), National Science Foundation (NSF) in Alexandria, Virginia. We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).
The appellant makes various statements about the agency’s evaluation of her position and compares her position to other positions within her agency. By law, we must classify positions solely by comparing their current duties and responsibilities to OPM standards and guidelines (5 U.S.C. 5106, 5107, and 5112). Since comparison to standards is the exclusive method for classifying positions, we cannot compare the appellant’s position to other positions that may or may not be properly classified as a basis for deciding her appeal. Because our decision sets aside any previous agency decisions, the appellant’s statements regarding the classification practices used by her agency to classify her position are not germane to the classification appeal process.
Like OPM, the appellant’s agency must classify positions based on comparisons to OPM standards and guidelines. The agency also has primary responsibility for ensuring that its positions are classified consistently with OPM appeal decisions. If the appellant considers her position so similar to others in her agency that they all warrant the same classification, she may pursue the matter by writing to her headquarters human resources office. In doing so, she should specify the precise organizational location, classification, duties, and responsibilities of the positions in question. If the positions are found to be basically the same as hers, the agency must correct its classification to be consistent with this appeal decision. Otherwise, the agency should explain to her the differences between her position and the others.
The appellant notes her longevity with the agency and the quality and increased volume of her work as support for her requested grade increase. However, longevity, work quality, and volume of work cannot be considered in determining the grade of a position (The Classifier’s Handbook (Handbook), Chapter 5).
The appellant places emphasis on Contracting Officer’s Technical Representative (COTR) work performed by her as support for her requested grade increase. However, COTR duties can be assigned to any Federal position with the technical knowledge and skill necessary to determine if contracted work is being performed appropriately. For example, a certified electrician COTR may monitor contracted electrical work. Thus, COTR duties are an extension of the existing knowledge and skill required to perform the primary work of the position to which the COTR duties are assigned. Consequently, there is no specific guidance for grading COTR duties, and they must be evaluated against the appropriate position classification standard (PCS) for the position to which the COTR duties are assigned.
During her interview, the appellant described intermittent and short-term duties and responsibilities (e.g., participation in the development of an interagency agreement between NSF and USPS) and duties and responsibilities not currently assigned to her position (i.e., program and project management responsibilities) as support for the requested grade increase. However, only duties which are currently assigned, observable, identified with the position’s purpose and organization, and expected to continue or recur on a regular basis over a period of time, such as one year, can be considered when determining the grade of a position (Handbook), Chapter 3, and 5 U.S.C. 5112).
The appellant’s supervisor states that “Generally, the major duties in the position description accurately reflect the work.” However, during interviews with OPM, both the supervisor and the appellant identified duties and responsibilities in the appellant’s PD (#1802200) which are incorrect, not performed, or overstated. For example, the PD indicates the position is responsible for “…adapting analytical techniques and evaluation criteria to the measurement and improvement of program effectiveness and/or organizational productivity…”. However, we find the appellant uses only basic analytical and evaluative techniques (e.g., side-by-side comparisons and trend analysis) and analytical processes integral to current EOB computer programs (e.g., Excel) to identify and track a variety of information related to EOB programs and processes and to develop reports and recommendations when appropriate. The analyticalprocesses performed by the appellant are incidental to the primary function of her position, which is the provision of a variety of administrative management services essential to the direction and operation of the EOB.
The PD seems to place emphasis on accounting and budgetary work. However, when questioned during his interview with OPM, the Branch Chief (BC) EOB stated that, although 6 of the 17 individual tasks described in the major duties section of the appellant’s PD involve accounting or budget-related duties, this type of work is no more prevalent than the other duties and responsibilities of her position, e.g., administrative support, space management, equipment/supply procurement, personnel management, policy development participation, IT support/system administration, and COTR duties.
The PD indicates the position is responsible for conducting projects and studies and “…has wide latitude in selecting projects and approaches while using significant initiative in defining activities required to meet management objectives…” However, the appellant’s current acting supervisor (Deputy Office Head (DOH)) stated that, although the appellant participates in and provides administrative support for projects and studies, she does not conduct projects and studies, nor does she have or exercise wide latitude to select projects and approaches. Instead, EOB projects and studies tend to be program-specific (e.g., Diversity and Inclusion, Civil Rights policy, and Equal Opportunity) and are typically delegated to staff directly associated with a particular program (i.e., Diversity and Inclusion program manager, Equal Opportunity Specialist, and Civil Rights Policy Analyst), who are delegated authority and wide latitude to select projects and approaches.
The PD indicates the appellant consults with the Office Head (OH) in developing and planning assignments, coordinating work efforts, and keeping the OH informed on progress. However, responsibility for developing and planning assignments, coordinating work efforts, and keeping the OH informed on progress rests with one of OECR’s three Branch Chiefs (BCs), i.e., Equity and Operations Branch Chief; Awardee Compliance Branch Chief; and Equal Employment Accessibility Branch Chief. The appellant’s coordination responsibilities are limited to the distribution of the BC’s updates and progress reports to the OH and acting as liaison between the BCs and the OH to clarify information and convey additional instructions and/or requirements.
A PD is the official record of the duties and responsibilities assigned to a position by an official with the authority to assign work. A position is the duties and responsibilities that make up the work performed by the employee. Classification appeal regulations permit OPM to investigate or audit a position and decide an appeal based on a review of the actual duties and responsibilities currently assigned by management and performed by the employee. An OPM appeal decision classifies a real operating position, and not simply a PD. This decision is based on the work currently assigned and performed by the appellant.
Given the PD inacuracies described above, the appellant’s PD does not meet the standard of adequacy addressed on pages 11-12 of the Introduction. Therefore, the agency must revise the PD to reflect our findings.
NSF is an independent Federal agency created by Congress in 1950 to support fundamental research and education in non-medical fields of science and engineering. As a component of NSF, OECR works with the agency and its awardees to promote diversity and inclusion, provide equal opportunity and access, and eliminate unlawful discrimination, harassment and retaliation within NSF and related programs. EOB manages Diversity and Inclusion, Civil Rights policy, and Equal Opportunity programs and related processes for OECR. The appellant uses established guidelines, tools (e.g., computer programs and databases), methods, and a thorough knowledge of issues and processes involving EOB budget, HR personnel management, property/space management, and other administrative activities and needs to provide direct support, advice, and assistance to the BC EOB and six employees (i.e., 1 Diversity and Inclusion Program Manager; 2 Equal Opportunity Specialists; 1 Management and Program Analyst, 1 Civil Rights Policy Analyst, and Data Scientist student trainees) assigned to EOB, and to provide and/or obtain a variety of management services essential to the direction and operation of the EOB.
She reviews new and existing Federal and agency guidelines, adapts them for EOB use, and distributes them to the BC for review and authorization prior to distribution to EOB staff. She liaises between EOB and administrative support personnel within the United States Postal Service (USPS) regarding cooperative/reimbursable agreements and develops and distributes related records and reports as necessary.
She compiles, interprets, stores, and manages a variety of electronic and hard-copy information and data for EOB and provides basic cyber security, system administration, and information technology (IT) advice and support to EOB personnel. She also coordinates with the BC EOB to identify, review, and acquire new computer hardware and software for EOB and coordinates with the BC EOB, CO, and Federal contractors to install and/or upgrade hardware and software.
The appellant performs the full range of COTR duties for contracted EOB projects involving new and/or modified electronic administrative support products and processes. As a COTR, the appellant acts as a liaison between various Federal contractors and the agency’s Contracting Officer (CO) and is responsible for ensuring satisfactory performance and timely delivery of services as set forth in assigned contracts. She performs contract pre-award tasks, such as preparation of work statements, and arranges for and coordinates the use of Government resources. She provides technical guidance concerning the performance requirements for EOB contract work, and receives, reviews, and submits a variety of contract-related data, documents, and reports (e.g., progress reports, selected invoices, and final reports) to the CO for consideration and action. She uses her administrative management experience and related technical judgment to help the CO monitor the performance and progress of contracted work and makes recommendations to the CO for changes to specific project contracts.
She performs a variety of accounting, budget, and finance-related work in support of EOB programs (Equal Employment Opportunity (EEO) program; Diversity and Inclusion (D&I) program; Reasonable Accommodations (RA) program; Alternative Dispute Resolution (ADR) program; and Civil Rights Compliance (CRC) program) and projects. She develops cost projections for EOB activities (e.g., contracts, products, equipment, hardware, and software); reconciles EOB accounts to the general ledger and resolves discrepancies; tracks income and expenditures for appropriated, and reimbursable funds; resolves normal accounting errors; and processes invoices for payment. She also monitors funds and expenditures for EOB projects and Federal contract work to ensure costs stay within budgets approved by the agency’s Budget Officer (BO) and performs basic budget analysis when required.
Using an EOB issued purchase card with a $2,500 limit, the appellant makes low-cost routine purchases of materials and services (e.g., office supplies and printer repair). She also monitors and records expenditures for herself and all other EOB-issued purchase cards to ensure compliance with established guidelines and produces cyclical and non-cyclical reports as required.
She serves as a liaison between EOB and the servicing HR office regarding the preparation of a variety of personnel actions (e.g., developing position descriptions and vacancy announcements; personnel actions; payroll issues; employee benefits; and performance appraisals); the compilation of personnel-related data; and the preparation of a variety of personnel-related reports. She also coordinates with the servicing HR office to ensure that the BC receives sound personnel action, employee/labor relation, and position management advice and guidance.
In reaching our classification decision, we have carefully reviewed all information provided by the appellant and her agency, including her official PD which, although not completely accurate, we have incorporated by reference into this decision. In addition, to help decide the appeal, we conducted separate telephone interviews with the appellant and her immediate supervisor, as well as subsequent telephone and email communications.
Series, title, and standard determination
The agency classified the appellant’s position in the Management and Program Analysis Series, GS-0343, titling it Management and Program Analyst (Administrative Operations Coordinator). However, as discussed below, we find the duties and responsibilities actually assigned to and performed by the appellant are properly classified in the Administrative Officer Series, GS-0341
The Management and Program Analysis Series, GS-0343, covers positions that primarily serve as analysts and advisors to management on the evaluation of the effectiveness of government programs and operations or the productivity and efficiency of the management of Federal agencies or both. Positions in this series require knowledge of the substantive nature of agency programs and activities; agency missions, policies, and objectives; management principles and processes; and the analytical and evaluative methods and techniques for assessing program development or execution and improving organizational effectiveness and efficiency. Some positions also require an understanding of basic budgetary and financial management principles and techniques as they relate to long range planning of programs and objectives. The work requires skill in application of fact-finding and investigative techniques; oral and written communications; and development of presentations and reports.
The Administrative Officer Series, GS-0341, covers 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.
Administrative management work is primarily concerned with providing, securing, or negotiating for the resources or services needed to manage and run an organization. It involves direct assistance to the "operating" manager, i.e., the official with the primary responsibility for the direction of an organization or unit established to accomplish a basic goal or mission. An administrative officer aids the operating manager and subordinate operating officials in getting things done by applying knowledge and skill in dealing with organizations, methods, funds, people, equipment, and other tools or resources of management. Ordinarily, an administrative officer is responsible for managing both financial and human resources because of their immediate relationship to the operating manager. The administrative officer 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.
Intrinsic to administrative management work is knowledge of the organization served and its mission; the relative importance of various work operations; the relative importance of various management services to these operations; and a management sense of what needs to be done, and when to do it. Most importantly, administrative management requires the ability to apply such understanding and knowledge in solving the practical problems of management. An administrative officer is a generalist. The total management process is his/her interest, and the proficiency required involves many aspects of management. General management skills are the paramount requirement. Though aspects such as budget administration and personnel management assume major importance in many positions and other aspects such as procurement and property management are also important in many jobs, no single function, resource or service area forms a basis for the paramount skills.
The Introduction and the Handbook indicate that identification of a position’s paramount knowledge (i.e., the essential, prerequisite knowledge, skills, and abilities needed to perform the primary duty or responsibility for which the position has been established) and primary purpose (i.e., the reason for a position’s existence) are crucial elements in the accurate classification of a position.
The appellant’s position does not meet the 0343 series. The GS-0343 series covers positions which primarily serve as analysts and advisors to management on the evaluation of the effectiveness of government programs and operations or the productivity and efficiency of the management of Federal agencies or both. However, unlike the 0343 series, the appellant’s analytical and advisory services are not the primary duty and paramount purpose of her position. Instead, her analytical and advisory services are but a part of her overall administrative and management support duties (e.g., office administration, procurement, budget, personnel management, space management, and COTR duties), which are considered of equal importance by the organization.
The appellant’s position fully meets the requirements for classification to the 0341 series. Like the 0341 series, the primary duty of the appellant’s position is to provide, obtain, or negotiate for a variety of management services that directly support the direction and operation of the EOB. Like the 0341 series, the position requires an in-depth knowledge of EOB’s mission and its function within OECR and NSF. The position also requires an in-depth knowledge of EOB’s goals, 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 to accomplish EOB’s mission. Like the 0341 series, the appellant aids the BC EOB and subordinate operating positions in getting things done through her knowledge of and skills in dealing with organization, methods, funds, people, equipment, and other tools or resources of the overall management of the EOB. Like the 0341 series, the appellant serves as an administrative generalist, whose focus is equally distributed among several skillsets (e.g., office administration, procurement, budget, personnel management, space management, and COTR duties), with no single function, resource, or service area forming a basis for the primary duty and paramount purpose of the position. Therefore, the appellant’s position is properly classified to the Administrative Officer Series, GS-0341.
As discussed in the titling guidance of the Position Classification Flysheet (PCF) for the Administrative Officer Series, GS-0341, the title for non-trainee positions in the 0341 series is “Administrative Officer.” Therefore, the position is titled Administrative Officer.
The 0341(PCF) does not contain grading criteria. Thus, positions in this series are evaluated by application of position classification standards (PCSs) and guides, which most closely match the paramount knowledge to perform the primary duties of a particular position. Because the paramount knowledge of the appellant’s position includes knowledge and skill in and application of general office management and analytical/evaluative concepts, methods, and techniques, we have determined that the grade of her work is best evaluated by application of the Administrative Analysis Grade Evaluation Guide (AAGEG).
The agency evaluated Factor 1, Knowledge Required by the Position at Level 1-7; Factor 2, Supervisory Controls, at Level 2-4; Factor 3, Guidelines, at Level 3-4; Factor 4, Complexity, at Level 4-5; Factor 5, Scope and Effect, at Level 5-4; Factor 6, Personal Contacts and Factor 7, Purpose of Contacts at Level 3-c; Factor 8, Physical Demands at Level 8-1; and Factor 9, Work Environment, at Level 9-1. In her OPM appeal request, the appellant originally disagreed with the agency’s evaluation of Factors 1, 2, 3, 4, 6, 7, and 9, believing they should be credited at Levels 1-8, 2-5, 3-5, 4-6, 6-4, 7-d, and 9-2. However, during the interview with OPM she added Factor 5 to her review request believing it should be evaluated at 5-5. After a careful review of Factor 8, we agree with the agency’s evaluation of level 8-1. Therefore, our evaluation will focus on Factors 1, 2, 3, 4, 5, 6, 7, and 9.
The AAGEG PCS uses the Factor Evaluation System (FES), which employs nine factors. Each factor level description 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. Conversely, the position may exceed those criteria in some aspects and still not be credited at a higher level. 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 standard. Our evaluation with respect to the nine FES factors follows.
Evaluation using the AAGEG
Factor 1, Knowledge required by the position
This factor covers the kind and nature of knowledge required and the skills needed and how they are used in doing the work. The agency assigned level 1-7, but the appellant believes she meets level 1-8.
At Level 1-7 assignments includes all knowledge described at Level 1-6, and requires knowledge and skill in applying analytical and evaluative methods and techniques to issues or studies concerning the efficiency and effectiveness of program operations carried out by administrative or professional personnel, or substantive administrative support functions (i.e., internal activities or functions such as supply, budget, procurement, or personnel which serve to facilitate line or program operations). This level includes knowledge of pertinent laws, regulations, policies, and precedents which affect the use of program and related support resources (people, money, or equipment) in the area studied. Projects and studies typically require knowledge of the major issues, program goals and objectives, work processes, and administrative operations of the organization. Knowledge is used to plan, schedule, and conduct projects and studies to evaluate and recommend ways to improve the effectiveness and efficiency of work operations in a program or support setting. The assignments require knowledge and skill in adapting analytical techniques and evaluation criteria to the measurement and improvement of program effectiveness and/or organizational productivity. Knowledge 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.
At Level 1-8, the employee is considered to be an expert analyst who has mastered the application of a wide range of qualitative and/or quantitative methods for the assessment and improvement of program effectiveness or the improvement of complex management processes and systems. In addition to knowledge of the next lower level, this level requires comprehensive knowledge of the range of administrative laws, policies, regulations, and precedents applicable to the administration of one or more important public programs. Typically, this includes knowledge of agency program goals and objectives, the sequence and timing of key program events and milestones, and methods of evaluating the worth of program accomplishments. Work requires knowledge of relationships with other programs and key administrative support functions within the employing agency or in other agencies. Knowledge characteristic of this level are applied to a variety of ways. For example, knowledge is applied to the design and conduct of comprehensive management studies where the boundaries of the studies are extremely broad and difficult to determine in advance, i.e., the actual limits of the project are developed as the study proceeds. Study objectives are to identify and propose solutions to management problems which are characterized by their breadth, importance, and severity, and for which previous studies and established management techniques are frequently inadequate. For other assignments, knowledge may be applied in preparing recommendations for legislation to change the way programs are carried out; in evaluating the content of new or modified legislation for projected impact upon agency programs and resources; and/or in translating basic legislation into program goals, actions, and services. Also included at this level is skill to plan, organize, and direct team study work and to negotiate effectively with management to accept and implement recommendations, where the proposals involve substantial agency resources, require extensive changes in established procedures, or may be in conflict with the desires of the activity studied.
Level 1-7 is met. Like Level 1-7, the appellant applies analytical and evaluative theory, methods, and techniques to issues concerning the efficiency and effectiveness of EOB projects and program operations and the performance of substantive administrative support functions (e.g., supply, budget, procurement, human resources, and COTR duties) which serve to facilitate EOB’s line and program operations. Similar to Level 1-7, the appellant uses knowledge of pertinent equity and civil rights laws, regulations, policies, precedents, and her knowledge of available EOB resources (people, money, services, and equipment) to inform and advise management and staff concerning EOB programs (e.g., Diversity and Inclusion (D&I); Equal Opportunity (EEO); Alternative Dispute Resolution (ADR) and Civil Rights (CR)) and projects. Comparable to Level 1-7, the appellant is fully aware of major issues, program goals and objectives, work processes, and administrative operations of the EOB and has a functional understanding of how EOB’s programs and processes affect OECR and NSF. Like Level 1-7, the appellant uses her knowledge of EOB programs and processes, as well as basic analytical techniqies and administrative technical skills, to assist program and project managers and Federal contractors with planning, scheduling, and conducting projects and studies and reviews processes and applicable guidelines to provide recommendations to improve the effectiveness and efficiency of associated work operations. Similar to Level 1-7, the appellant provides the full range of management and administrative support for the EOB, such as developing, interpreting, and advising on administrative guidelines and policies, defining administrative requirements, providing advice to EOB management on program-related issues and procedures, and evaluating and recommending updates or changes to program-related computer hardware and software. Comparable to Level 1-7, when necessary the appellant uses basic analytical techniques and evaluation criteria to measure the efficiency and effectiveness of EOB administrative processes (e.g., budget, procurement, personnel, space management, and COTR tasks), and programs (e.g., D&I; EEO; D&I; RA; ADR; and CR) and provide data and recommendations to EOB managers and staff for the development of new or modified work methods, organizational structures, staffing patterns, procedures for administering program services, guidelines and procedures, and automated systems to support EOB program operations.
Level 1-8 is not met. While the appellant is viewed as the local expert in administrative management and is responsible for providing support and guidance to EOB for a wide variety of administrative functions, the position is not responsible for analyzing and/or advising NSF broad agency-level programs, as envisioned at Level 1-8. Unlike Level 1-8, the appellant is not required to possess a comprehensive knowledge of the range of administrative laws, policies, regulations, and precedents applicable to the administration of one or more important public programs, including knowledge of agency program goals and objectives, the sequence and timing of key program events and milestones, and methods of evaluating the worth of program accomplishments. Instead, the position requires her to possess a thorough knowledge of Federal and agency laws, regulations, policies, and standard operating procedures (SOP) applicable to EOB programs. Unlike Level 1-8, the position does not require knowledge necessary to design and conduct extremely broad and difficult comprehensive management studies to determine, in advance, the actual limits of projects and/or to identify and propose solutions to management problems which are characterized by their breadth, importance, and severity, and for which previous studies and established management techniques are frequently inadequate, nor does it require knowledge and skill sufficient to plan, organize, and direct team study work or to negotiate effectively with management to accept and implement recommendations, where the proposals involve substantial agency resources. Unlike Level 1-8, the appellant does not prepare recommendations for legislation; evaluate the content of new or modified legislation for impact on agency programs or resources; or make proposals that affect substantial agency resources. Instead, the appellant is responsible for EOB programs, projects, and operations only and does not exercise the far-reaching agency-impacting responsibility described at Level 1-8.
Factor 1 is evaluated at Level 1-7, and 1250 points are assigned.
Factor 2, Supervisory controls
This factor covers the nature and extent of direct or indirect controls exercised by the supervisor, the employee's responsibility for carrying out assignments, and how completed work is reviewed. The agency assigned level 2-4, but the appellant believes she meets level 2-5.
At Level 2-4, the employee and supervisor develop a mutually acceptable project plan, within the framework of priorities, funding, and overall project objectives, (e.g., cost reduction, improved effectiveness and efficiency, better workload distribution, or implementation of new work methods), which typically includes identification of the work to be done, the scope of the project, and deadlines for its completion. Within the parameters of the approved project plan, the employee is responsible 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. Completed projects, evaluations, reports, or recommendations are reviewed by the supervisor for compatibility with organizational goals, guidelines, and effectiveness in achieving intended objectives. Completed work is also reviewed critically outside the employee's immediate office by staff and line management officials whose programs and employees would be affected by implementation of the recommendations.
At Level 2-5, the employee is a recognized authority in analysis and evaluation of programs and issues and is subject only to administrative and policy direction concerning overall project priorities and objectives. At this level, the employee is typically delegated complete responsibility and authority to plan, schedule, and carry out major projects concerned with the analysis and evaluation of programs or organizational effectiveness. The employee typically exercises discretion and judgment in determining whether to broaden or narrow the scope of projects or studies. Analyses, evaluations, and recommendations developed by the employee are normally reviewed by management officials only for potential influence on broad agency policy objectives and program goals. Findings and recommendations are normally accepted without significant change.
Level 2-4 is met. Like Level 2-4, within the framework of priorities, budget, and specific Federal contracts and EOB projects and objectives, the appellant and her supervisor develop mutually acceptable plans for work products to be performed, parameters and authorities, and expected results (e.g., product quality, practical functionality, and deadlines for its completion). Similar to Level 2-4, the appellant provides a wide range of administrative management support to program and project managers, such as the interpretation and application of established administrative technical guidelines; current computer software parameters and applications; expenditures and budget limitations; and coordination between EOB personnel (i.e., OECR), as well as between EOB and USPS personnel responsible for managing the current cooperative agreement between the two agencies. Like Level 2-4, the appellant provides definitive interpretations of guidelines (e.g., policies, standard operating procedures (SOP), contract parameters, and program and project objectives and requirements) affecting the management of EOB administrative operations, and provides the supervisor with regular updates on EOB administrative management issues, processes, and results (e.g., status of ongoing Federal contracts and EOB projects; status of EOB personnel (e.g., vacancies, new hires, training, travel, disciplinary issues, awards, and losses) and budget-related issues) and alerts the supervisor of potentially damaging or controversial issues and problems which may have widespread consequences for the EOB. Like Level 2-4, completed projects, evaluations, reports, and recommendations are reviewed by the appellant’s supervisor for compatibility and effectiveness with regard to EOB, OECR, and NSF goals, objectives, and guidelines. Similar to Level 2-4, the appellant’s work may also receive critical review from OECR and NSF management officials, who are two or more levels above the BC EOB.
Level 2-5 is not met. Level 2-5 recognizes not only independence of action, but also the degree of responsibility and authority inherent in the work as the context for the independence exercised. Level 2-5 is predicated on the position having personal authority and responsibility to independently plan and carry out major program activities or projects and having only broad administrative and policy to guide and direct the work of the position. Because the parameters of the work at Level 2-5 are not clearly defined, an employee at this level must exercise independent authority to determine the most productive areas of endeavor and the most appropriate processes to perform.
Unlike Level 2-5, the appellant is not a recognized authority in analysis and evaluation of NSF programs and issues. Instead, she performs basic evaluations and analysis of EOB-related data and information and provides a wide range of administrative management support for EOB programs, project, and personnel.
Unlike Level 2-5, the appellant is not typically delegated complete responsibility and authority to plan, schedule, and carry out major projects concerned with the analysis and evaluation of NSF programs or organizational effectiveness. Instead, these responsibilities rest with the BC EOB or higher-level agency management officials. The appellant’s responsibilities extend solely to the performance of administrative management functions for the benefit of the EOB and at the discretion and direction of the BC EOB. Thus, the appellant lacks the authority and responsibility to plan, schedule, and carry out major projects concerned with the analysis and evaluation of programs or organizational effectiveness, as required at Level 2-5. Unlike Level 2-5, the appellant does not exercise discretion and judgment in determining whether to broaden or narrow the scope of projects or studies. Instead, this authority rests with the BC EOB, program or project manager responsible for that particular project or study, or higher-level officials within the agency.
In contrast to Level 2-5, analyses, evaluations, and recommendations developed by the appellant are routinely reviewed by the BC EOB and may also receive critical review from OECR and NSF management officials, who are two or more levels above the BC EOB. At any level of review, the appellant’s work can experience correction and/or significant modification. This is in sharp contrast to Level 2-5, where analysis, evaluations, and recommendations are normally reviewed by management officials only for potential influence on broad agency policy objectives and program goals and findings and recommendations are normally accepted without significant change.
Factor 2 is evaluated at Level 2-4, and 450 points are assigned.
This factor covers the nature and extent of guidelines for performing the work and the judgment needed to apply them. The agency assigned Level 3-4, but the appellant believes she meets Level 3-5.
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). 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. 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 which cover it (e.g., workflow, delegations of authority, or regulatory compliance) and makes recommendations for changes. Included at this level are work assignments in which the subject studied is covered by a wide variety of administrative regulations and procedural guidelines. In such circumstances the employee must use judgment in researching regulations, and in determining the relationship between guidelines and organizational efficiency, program effectiveness, or employee productivity.
At Level 3-4, 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. Administrative guidelines usually cover program goals and objectives of the employing organization, such as agency controls on size of work force, productivity targets, and similar objectives. 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 3-3 is met. Like Level 3-3, although not always directly applicable, numerous standard guidelines (e.g., Federal civil rights, diversity, and EEO laws and regulations and associated websites), agency instructions (e.g., purchase card manual, iTrack User Manual, Direction for Managing Interagency Agreements, COR Handbook, Manual 17 Facility Policy Manual, Manual 21 Program Coding and Financing Manual, Employee and IPA Onboarding and Separation Guide, NSF Grant Policy Manual, Proposal and Award Manual, NSF Manual 15 COI & Standards of Ethical Conduct Manual, NSF, OECR, and EOB policies and SOPs, and written and verbal direction from the supervisor), and precedents (e.g., Legislative history, court decisions, and precedent-setting application of diversity and inclusion regulations from other agencies) are available to clarify and direct the appellant’s daily work. Similar to Level 3-3, the appellant uses personal experience and judgment in choosing, interpreting, and adapting available guidelines to specific EOB administrative management issues in order to evaluate the applicability of available guidelines and to recommend the appropriate application of existing guidelines or to recommend updates/changes to current EOB policies and SOPs. Like Level 3-3, the appellant uses judgment in reviewing a wide range of administrative regulations and procedural guidelines to identify any possible impact to EOB programs, projects, studies, and processes.
Level 3-4 is not met. The numerous guidelines available to the appellant, as referenced above, represent a more detailed, specific, and structured type of guidance than the general administrative guidelines and management theories described at Level 3-4.
Factor 3 is evaluated at Level 3-3, and 275 points are assigned.
This factor covers the nature, number, variety, and intracy 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. The agency assigned Level 4-5, but the appellant believes she meets Level 4-6.
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 or program support setting. This is in addition to improving conditions of a procedural nature which relate to the efficiency of organizations and workers described at the previous level. By way of contrast with Level 4-3, work at this level requires the application of qualitative and quantitative analytical techniques that frequently require modification to fit a wider range of variables. Subjects and projects assigned at this level usually consist of issues, problems, or concepts that are not always susceptible to direct observation and analysis (e.g., projected missions and functions). Difficulty is encountered in measuring effectiveness and productivity due to variations in the nature of administrative processes studied (e.g., those associated with processing information, reorganizing to meet changes in mission, or providing support services). Information about the subject is often conflicting or incomplete, cannot readily be obtained by direct means, or is otherwise difficult to document. For example, 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 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.
At Level 4-5, work consists of projects and studies which require analysis of interrelated issues of effectiveness, efficiency, and productivity of substantive mission-oriented programs. Typical assignments require developing detailed plans, goals, and objectives for the long-range implementation and administration of the program, and/or developing criteria for evaluating the effectiveness of the program. Decisions about how to proceed in planning, organizing, and conducting studies are complicated by conflicting program goals and objectives which may derive from changes in legislative or regulatory guidelines, productivity, and/or variations in the demand for program services. Assignments are further complicated by the need to deal with subjective concepts such as value judgments; the quality and quantity of actions are measurable primarily in predictive terms; and findings and conclusions are highly subjective and not readily susceptible to verification through replication of study methods or reevaluation of results. Options, recommendations, and conclusions developed by the employee take into account and give appropriate weight to uncertainties about the data and other variables which affect long-range program performance. For example, the employee may need to consider and assess the relative advantages and disadvantages of centralizing or decentralizing work operations in organizations with several echelons of geographically separated components. In some instances, work is complicated by the need to develop data about workload and program accomplishments which is currently unavailable. Current measurements of program effectiveness may be ambiguous and susceptible to widely varying interpretations. Under these circumstances the employee develops new information about the subject studied and establishes criteria to identify and measure program accomplishments, develops methods to improve the effectiveness with which programs are administered, or develops new approaches to program evaluation which serve as precedents for others.
Level 4-4 is met. Like Level 4-4, the appellant’s work involves gathering information and identifying and analyzing/evaluating issues associated with EOB-related programs and projects. Similar to Level 4-4, she reviews data and information and develops recommendations to resolve substantive problems involving the effectiveness and efficiency of EOB’ organization viability and functionality, e.g., programs, projects, and work operations. Comparable to Level 4-4, the appellant’s work requires the application of qualitative and quantitative analytical techniques (e.g., interviews, focus groups, market research, data mining, surveys) which she modifies to cover variables, such as funding and budget projections. Like Level 4-4, the subject of projects and studies supported by the appellant often consist of issues, problems, or concepts that are not susceptible to direct observation and analysis, such as projected budgets and estimated operational functions of various programs managed by EOB. Similar to Level 4-4, variations in the nature of EOB processes make it difficult for the appellant to measure the efficiency and effectiveness of administrative programs associated processes, such as data processing and mining or providing EEO, D&I, RA, ADR, and CRC information, advice, and support services because information about the impact of EEO, D&I, RA, ADR, and CRC issues is often conflicting or incomplete or difficult to obtain and document. Comparable to Level 4-4, the appellant uses originality to adjust existing methods and techniques for gathering program participation and impact (e.g., data collection and reporting) to document and analyze/evaluate specific administrative management, program, or project issues and to develop and propose a resolution to these problems.
Level 4-5 is not met. Unlike Level 4-5, the appellant’s work is not focused on the subjective considerations aimed at improving the overall administration of NSF programs, nor do her assignments typically require her to develop detailed plans, goals, and objectives for long-range implementation, administration, and evaluation of agency programs. Instead, her work focuses primarily on short-term technical and administrative management issues and EOB projects, programs, and processes, which are supported and implemented by OECR throughout NSF. Furthermore, the appellant does not perform work analogous to the broad program-oriented activities described at Level 4-5 (e.g., work related to the operation of broad NSF programs). Instead, unlike Level 4-5, the administrative program management and project and program support duties performed by the appellant are primarily focused on providing technical support to EOB program and project managers and improving the effectiveness and efficiency of specific EOB programs and activities.
Factor 4 is evaluated at Level 4-4, and 225 points are assigned.
This factor covers the relationship between the nature of the work, i.e., the purpose, breadth, and depth of the assignment, and the effect of work products or services both within and outside the organization. The agency assigned level 5-4, but the appellant believes her position meets level 5-5.
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 involves establishing criteria to measure and/or predict the attainment of program or organizational goals and objectives. Work at this level may also 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 that involves the evaluation of program effectiveness usually focuses on the delivery of program benefits or services at the operating level. 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 missions and programs at these various echelons or locations. Work may affect the nature of administrative work done in components of other agencies (e.g., in preparation and submission of reports, in gathering and evaluating workload statistics, or in routing and storing official correspondence or files).
At Level 5-5, the purpose of the work is to analyze and evaluate major administrative aspects of substantive, mission-oriented programs. This may involve, for example, the development of long-range program plans, goals, objectives, and milestones, or to evaluating the effectiveness of programs conducted throughout a bureau or service of an independent agency, a regional structure of equivalent scope, or a large complex multi-mission field activity. The work involves identifying and developing ways to resolve problems or cope with issues which directly affect the accomplishment of principal program goals and objectives (e.g., the delivery of program benefits or services). Some employees develop new ways to resolve major administrative problems or plan the most significant administrative management aspects of professional or scientific programs, while some employees at this level develop administrative regulations or guidelines for the conduct of program operations, while others develop new criteria for measuring program accomplishments (e.g., the level, costs, or intrinsic value of benefits and services provided) and the extent to which program goals and objectives are attained. Study reports typically contain findings and recommendations of major significance to top management of the agency, and often serve as the basis for new administrative systems, legislation, regulations, or programs. Typical of work products prepared by employees at this level are complete decision packages, staff studies, and recommendations which upon implementation would significantly change major administrative aspects of missions and programs, or substantially affect the quality and quantity of benefits and services provided to the agency's clients.
Level 5-4 is met. Like Level 5-4, the appellant’s work involves ensuring the effectiveness of EOB administrative programs, which includes developing analytical and evaluative methods to predict various administrative and programmatic needs and measure if goals and objectives have been met. Like Level 5-4, the appellant coordinates with the BC EOB to develop administrative guidelines concerning personnel, budget, procurements, space management, and Federal contracts and to promulgate guidelines for the application of EOB programs throughout NSF.
Level 5-5 is not met. At Level 5-5, work is associated with the overall design, structure, and administration of substantive agency or bureau programs or programs affecting large, multi-mission field activities and addresses broad agency program and policy issues and concerns, such as significant administrative management issues; new program regulations and/or guidelines; and new analytical tools and criteria used to measure program goals and objectives. Unlike Level 5-5, the administrative management and project and program analytical and support work performed by the appellant does not affect the design, structure, and administration of overall agency and/or bureau programs, nor does it regularly address broad agency programs, policies issues, and concerns as would be expected at Level 5-5. Instead, the appellant’s work is primarily focused on, and limited to, providing a variety of administrative management technical support for EOB program and related processes and procedures. In addition, the appellant is not responsible for developing new administrative systems, legislation, regulations, and programs which may significantly impact major aspects of NSF as would be expected at Level 5-5. Instead, she typically works within the parameters of EOB programs (e.g., D&I; EEO; RA; ADR; and CR) and makes recommendations and suggestions related to issues and concerns directly associated with processes and procedures affecting the aforementioned programs. Responsibility for decisions and recommendations which may significantly impact major aspects of legislation and regulations and/or NSF’s administrative systems and programs rest with analysts and administrative officials at higher levels within the organization.
Factor 5 is evaluated at Level 5-4, and 225 points are assigned.
Factor 6, Personal contacts / Factor 7, Purpose of contacts
These two factors are interdependent. The relationship between factors 6 and 7 presumes the same contacts will be evaluated under both factors. These factors cover the type and level of contacts made in carrying out the work and the reasons for those contacts. Under the AAGEG, these factors are evaluated separately, but a combined point credit is established by determining where the respective levels intersect in the table in the AAGEG. The agency assigned levels 6-3 for Persons Contacted, and 7-c for Purpose of Contacts, but the appellant believes she meets Levels 6-4, and 7-d.
At Level 6-3, contacts include persons outside the agency which may include consultants, contractors, or business executives in a moderately unstructured setting. This level may also include contacts with the head of the employing agency or program officials several managerial levels removed from the employee when such contacts occur on an ad-hoc basis.
At Level 6-4, contacts include high-ranking officials such as other agency heads, top congressional staff officials, state executive or legislative leaders, mayors of major cities, or executives of comparable private sector organizations.
Level 6-3 is met. Like Level 6-3, the appellant’s contacts include administrative personnel within USPS and Federal contractors in moderately unstructured settings, such as telephone and e-mail communications. Like Level 6-3, the appellant has intermittent contact with persons several managerial levels removed from her position, e.g., OECR program managers and the DOH and OH.
Level 6-4 is not met. Unlike Level 6-4, the appellant does not have contact with high-ranking officials and/or heads of other agencies agency heads, congressional staff officials, mayors of major cities, or executives of comparable private sector organizations indicative of this level.
Factor 6 is evaluated at Level 6-3.
At Level 7-b, the purpose of contacts is to provide advice to managers on noncontroversial organization or program related issues and concerns. Contacts typically involve such matters as: identification of decision-making alternatives; appraisals of success in meeting goals; or recommendations for resolving administrative problems.
At Level 7-c, the purpose of contacts is to influence managers or other officials to accept and implement findings and recommendations on organizational improvement or program effectiveness. May encounter resistance due to such issues as organizational conflict, competing objectives, or resource problems.
Level 7-b is met. Like Level 7-b, the primary purpose of the appellant’s contacts is to obtain data and information and to provide reports, analysis, and recommendations for a variety of non-controversial administrative management matters (e.g., policy, program parameters, budget, personnel, and computer system administrative issues, processes, and procedures) to the CO, BO, BC EOB, DOH, OH, OECR project and program managers, and other OECR staff as needed. Similar to Level 7-b, the purpose of the appellant’s contacts regularly includes decision-making recommendations and alternatives for administrative processes and computer hardware and software, based on the results of data research performed by her. She also provides reports and data concerning EOB’s success or failure in meeting established goals, timelines, and budgets, and provides recommendations to EOB leadership for resolving a variety of administrative problems, such as Federal contracts and EOB-related budgets, hardware and software, and personnel issues.
Level 7-c is not met. Unlike Level 7-c, the purpose of contacts is not to influence managers or other officials to accept and implement findings and recommendations on organizational improvement or program effectiveness. Instead, the purpose of the appellant’s contacts is to provide a variety of administrative management data and information to key EOB personnel for consideration and further action. Unlike Level 7-c, the appellant does not typically encounter resistance from management or other personnel she contacts. Instead, most contacts involve people with similar objectives who work cooperatively to achieve mutual goals.
Factor 7 is evaluated at Level 7-b.
Factors 6 and 7 are evaluated at Levels 6-3, 7-b, respectively, and 110 points are credited.
This factor considers the discomfort and risk of danger in the employee’s physical surroundings and the safety precautions require. The agency assigned Level 9-1 but the appellant believes the position t meets Level 9-2.
At Level 9-1, work is typically performed in an adequately lighted and climate-controlled office and may require occasional travel.
At Level 9-2, assignments regularly require visits to manufacturing, storage, or other industrial areas, and involve moderate risks or discomforts. Protective clothing and gear and observance of safety precautions are required.
Level 9-1 is met. Like this level, the appellant’s work is performed in a well-lit and climate-controlled office setting with little to no travel required.
Level 9-2 is not met. Although the appellant expresses concern over physical obstructions in walkways, requiring her to step over or around obstructions, and items stored on overhead shelves within the office’s supply room, requiring her to stand on step stools or stretch to reach items on high shelves, the overall condition of the work environment does not reach the level of risk and discomfort described at Level 9-2. That level applies to employees who regularly visit manufacturing, storage, or industrial areas where moderate risks and discomforts are common and which employees are required to observe safety additional safety precautions and use protective clothing and gear not typically required in a normal office setting.
Factor 9 is evaluated at Level 9-1, and 5 points are assigned.
Summary
Table 1 Grade Determination
| Factor | Level | Points |
| Knowledge required by the position | 1-7 | 1250 |
| Supervisory controls | 2-4 | 450 |
| Guidelines | 3-3 | 275 |
| Complexity | 4-4 | 225 |
| Scope and effect | 5-4 | 225 |
| Personal contacts | 6-3 | --- |
| Purpose of contacts | 7b | 110 |
| Physical demands | 8-1 | 5 |
| Work environment | 9-1 | 5 |
| Total points | 2545 | |
A total of 2545 points falls within the GS-11 grade level point range of 2355-2750 points listed in the grade conversion table in the AAGEG.
The appellant’s position is properly classified as Administrative Officer, GS-0341-11.