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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

[appellant's name]
Administrative Officer
Division of Administration
National Park Service
U.S. Department of the Interior
[City, State]
Administrative Officer

Robert D. Hendler
Classification and Pay Claims
Program Manager
Merit System Audit and Compliance



As provided in section 511.612 of title 5, Code of Federal Regulations (CFR), this decision constitutes a certificate which is mandatory and binding on all administrative, certifying, payroll, disbursing, and accounting officials of the Government.  The agency is responsible for reviewing its classification decisions for identical, similar, or related positions to ensure consistency with this decision.  There is no right of further appeal.  This decision is subject to discretionary review only under conditions and time limits specified in the Introduction to the Position Classification Standards (Introduction), appendix 4, Section G (address provided in appendix 4, section H).


On September 5, 2012, Chicago Oversight of the U.S. Office of Personnel Management (OPM) accepted a position classification appeal from [appellant].  Her position is currently classified as an Administrative Officer, GS-341-12, but she believes her duties and responsibilities warrant upgrading her position to the GS-13 grade level.  The appellant works at [installation] [acronym], [Region], National Park Service (NPS), U.S. Department of Interior, in [City, State].  We received the complete agency administrative report (AAR) on October 9, 2012, and notification from the appellant that she had no further comments on October 15, 2012.  We accepted and decided this appeal under section 5112(b) of title 5, United States Code (U.S.C.).


NPS consolidated human resources (HR) services to a centralized approach by establishing a Servicing Human Resources Office (SHRO) for each NPS region.  The SHROs report to the Workforce Management Office for each region, which then report to the NPS headquarters office (HQ) in Washington, D.C.  The Human Resource Operations Center (HROC), which also reports to NPS HQ, was created for processing personnel actions, benefits, and classification of positions across the service for all SHROs.  The HR staff assigned to the [installation] was reassigned to the [Region].  The development of the centralized HR operation changed the structure of HR services for the park, placing the appellant as the park’s primary contact for HR, serving as a liaison between employees, supervisors, and the SHRO.  Additionally, the park created a Program Assistant position under the direction of the appellant to handle processing initial paperwork and requests involving HR items, such as hiring and benefits, with the SHRO.  This position is also assigned as the park’s contact for workers compensation.

In addition to the consolidation of HR services, the NPS is moving to implement a new automated administrative system, the Federal Business Management System; has modified the method of processing payments for vendors from a third party draft to an electronic fund transfer; and established requirements for a Director’s Approval Board for contracting requests.  These changes brought about a change in the requirements and methods for accomplishing the appellant’s duties and responsibilities.  To accommodate these changes, an accretion of duties request was submitted to place the appellant in an Administrative Officer, GS-341-13 position description.  The position was reviewed by the agency, which denied the “accretion of duties promotion” requested by the appellant on the basis that the duties performed by the appellant were properly classified as an Administrative Officer, GS-341-12.

General issues

The appellant believes the evolution of her duties through the changes made within the NPS warrant an upgrade of the position.  Additionally, the appellant compares her duties to similar, but higher graded positions assigned to the other parks to support her request that her position be upgraded.  In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of the position.  By law, we must make that decision solely by comparing the appellant’s current duties and responsibilities to OPM position classification standards (PCS) and guidelines (5 U.S.C. 5106, 5107, and 5112).  Since comparison to OPM PCSs and guidelines is the exclusive method for classifying positions, we cannot compare the appellant’s current duties to other positions which may or may not be classified properly as a basis for deciding her appeal.

Like OPM, the appellant’s agency must classify positions based on comparison to OPM standards and guidelines.  However, the agency also has primary responsibility for ensuring that its positions are classified consistently with OPM appeal decisions.  If the appellant considers her position so similar to others that they all warrant the same classification, she may pursue the matter by writing to her agency’s human resources headquarters.  In doing so, she should specify the precise organizational location, classification, duties, and responsibilities of the positions in question.  If the positions are found to be basically the same as hers, the agency must correct their classification to be consistent with this appeal decision.  Otherwise, the agency should explain to her the differences between her position and the others.

In reaching our classification decision, we have carefully reviewed all information of record furnished by the appellant and the agency.  Additionally, we interviewed the appellant and the appellant’s supervisor to further gather information concerning the duties and responsibilities of the position which we fully considered in this decision.

Position information

The appellant reports to the Superintendent for [installation] and serves as Chief of Administration and head of the administrative division for the park.  As such, she is responsible for managing the administrative and business operations of the park.  This includes serving as an advisor to the Superintendent and peer division chiefs on administration and business operations, as well as serving as an active member of the senior management team (SMT), consisting of the Superintendent and the division chiefs representing each division of the park:  Resource Management, Facilities Management, Administration, Interpretation and Partnership, and Law Enforcement.

The appellant supervises seven employees who provide administrative services in the areas of budget and financial management, information technology, contracting and procurement, and personnel services.  In addition to supervising the administrative staff, her duties are encompassed in the following five main areas:

Budget and Financial Management – The appellant is responsible for keeping the park’s revenues and spending in balance through sound advice and supervision of the staff dedicated to budget and financial management.  She oversees and directs the budget and financial management staff in preparing, consolidating, and submitting budget estimates and justifications for park programs.  She also works with financial management officials at the regional and headquarters levels to stay informed of shifts in funding, advising park leadership on opportunities and strategies for acquiring funding.

Administrative Services – The appellant is responsible for overseeing the following administrative functions:  bills of collection, payment of invoices, internal controls, and point of contact for the Government Performance and Results Act (GPRA) 

Human Resources Management – The appellant serves as the primary liaison with the SHRO, coordinating the identification and communication of needs and receipt of HR services from the SHRO.  Additionally, she assures supervisors and managers receive sound advice and guidance on position management and is involved in discussions concerning employee relations matters.

Acquisition and Property Management – The appellant is responsible for coordinating goods and services the park requires to accomplish its mission and programs.  This includes ensuring contracting packages are complete prior to forwarding to the servicing Major Acquisition Buying Office (MABO).  She also oversees the work of employees in charge of property management and control systems of the park.

Information Management – The appellant is responsible for providing information technology, connectivity, communications, and automation advice and support of programs for the park through the supervision of an Information Technology Specialist.

Series, title, and standard determination

The agency has classified the position in the Administrative Officer Series, GS-341, titling it Administrative Officer by application of the GS-341 PCS, and is properly graded by application of the General Schedule.  The appellant does not disagree.  Based on careful review of the record, we concur with these determinations.  As discussed below, the position is properly graded by application of the Administrative Analysis Grade Evaluation Guide (AAGEG) and the General Schedule Supervisory Guide (GSSG).

Grade determination

There are no grade-level criteria for the GS-341 series.  The GS-341 PCS instructs that other individual standards for work related to the major duties or function performed are to be used to evaluate positions in this series.  In order for a set of duties to be grade-controlling, those duties must occupy at least 25 percent of the employee’s time.  Duties performed for a lesser percentage of time do not influence the grade of a position.

The duties of the position are dispersed over the various administrative functions performed.  The appellant and supervisor agree the following amounts of time are spent by the appellant in performing the work of the position:

Management and Decision Making – 15%

Budget – 20 %

Administrative Advice – 15%

Supervisory Responsibilities – 30%

Administrative Services – 15%

Freedom of Information Act (FOIA) Officer – 5%

The appellant serves as a generalist in the administrative function in which no one area is predominant.  Therefore, we have evaluated the position based on AAGEG.  This guide covers the broad scope of administrative responsibilities as it is designed to evaluate staff analytical, planning, and evaluative work concerned with the administrative and operational aspects of programs and management.  Positions covered by this guide require knowledge of: (1) overall mission, functions, and organization of the agency or component; (2) the principles, functions, and processes of management and the organization of work; (3) agency program operations, processes, goals and objectives; and (4) evaluative, planning, and analytical processes and techniques.  This knowledge is applied in a staff advisory capacity to line management in support of planning, development, and execution of agency programs.

Due to the appellant's supervisory responsibilities, we have also evaluated the position based on application of the GSSG.  For coverage under the GSSG, supervisory responsibilities must accomplish work through combined technical and administrative direction of others, constitute a major duty occupying at least 25 percent of the position's time, and meet at least the lowest level of Factor 3 identified in the guide.

The appellant's supervisory responsibilities encompass 30 percent of her time.  To be considered under the GSSG, the supervision of employees must include technical and administrative supervision.  The appellant exercises both technical and administrative supervision over all her subordinates other than the contracting specialist.  The NPS provides contracting services to parks through a centralized unit called the MABO.  Within the [Region], contracting specialists are placed throughout the region in various parks with administrative supervision exercised by the assigned park.  Technical guidance and the assignment of work come from the centralized MABO.  While the contracting specialist for the park is under the appellant’s supervision, this supervision is only administrative and, therefore, is not considered in regard to the GSSG.  However, not considering this position, the appellant's supervisory responsibilities still encompass at least 25 percent of her time.

Evaluation using the AAGEG

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

Factor 1, Knowledge Required by the Position

This factor covers the kind and nature of knowledge and skills needed and how they are used in doing the work.

At Level 1-7, work 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 service 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 recourses (people, money, and equipment).  Projects typically require knowledge of the major issues, program goals and objectives, work processes, and administrative operations of the organization. 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 processes for the conduct of administrative support functions or program operations.

At Level 1-8, knowledge of 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.  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.  The 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; preparing recommendations for legislation to change the way programs are carried out; or evaluating the content of new or modified legislation for projected impact upon agency programs and resources.  Proposals made involve substantial agency resources or require extensive changes in established procedures.  Illustrative examples for this level describe situations where the work is applied to a multi-layered military command and include developing resource guidance to subordinate activities.

The distinction between Levels 1-7 and 1-8 as it relates to the appellant’s position rests on the breadth of the knowledge required.  Level 1-7 requires knowledge of the program operations of the organization or knowledge of substantive administrative support functions which facilitate the line or program operations of the organization.  This knowledge is applied in the context of such assignments as developing new or modified work methods, records and files, management processes, or procedures for automating work processes.  These assignments affect the administration of program services to the extent of making them more efficient or effective, but do not change the fundamental nature of the programs as is expected at Level 1-8.  This is a very clear parallel to the appellant’s position.  As at Level 1-7, the appellant is responsible for the administrative function of the park and serves as an integral part of the park's SMT, participating in setting annual goals and making operational decisions for the park, while providing administrative guidance to the team.  This role requires knowledge of laws, regulations, policies, procedures, program goals and objectives, work processes and precedents affecting the programs of the park.

The position does not meet Level 1-8.  While the position is viewed as the local expert in administration and is responsible for guiding the park in administrative functions, the position does not comprise the broader program responsibilities of an agency program such as, preparing recommendations for legislation, evaluating the content of new or modified legislation for impact on agency programs or resources, or making proposals that affect substantial agency resources.  These functions and changes in fundamental program function are performed at higher organizational levels in the agency.  The appellant's responsibilities are confined to the park and do not have the far reaching impact or complexity as described in this level.

Level 1-7 is credited for 1250 points.

Factor 2, Supervisory Controls

This factor covers how the work is assigned, the extent to which the employee is responsible for carrying it out, and how the work is reviewed.

At Level 2-4, the employee and supervisor develop mutually acceptable project plans which typically include identification of the work to be done, the scope of the project, and deadlines for its completion.  Within the overall parameters, the employee is responsible for planning and organizing the work, estimating costs, coordinating with staff and management, and conducting all phases of the work.  This frequently involves the definitive interpretation of regulations.  The employee keeps the supervisor informed of potential controversies or problems with widespread impact.  Completed work is reviewed for compatibility with organizational goals and effectiveness in achieving objectives.

The supervisory controls for this position meet Level 2-4.  The Superintendent sets the overall objectives and parameters for assignments in coordination with the appellant.  Typical assignments originate at the national office, are assigned to the regional office, then to the park.  The appellant has latitude to decide how to accomplish tasks within the broad parameters set by the supervisor, but informs the supervisor of potential controversies or problems that may have widespread impact.  Completed work is reviewed for overall compatibility with the park's goals and is generally accepted without change.  At times, the supervisor will request the appellant to add additional information to work products in order to conform to the overall goals of the organization.  For example, the appellant was responsible for completing a report outlining the EEO efforts of the organization.  When reviewing the report, the supervisor had the appellant include information on the park's telework efforts, as this was an item of interest at the regional and national levels.

At Level 2-5, the employee is subject only to administrative and policy direction concerning overall project priorities and objectives.  The employee is typically delegated complete responsibilities 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.  Work is normally reviewed by management officials only for potential influence on broad agency policy objectives and program goals.

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.  While the appellant has great latitude in completing assignments, the supervisor manages the overall scope of and exercises organizational oversight over the work.  Because the parameters of the work are not clearly defined, the employee at Level 2-5 has the authority to determine the most productive areas of endeavor.  In contrast, the appellant carries out an ongoing set of activities, the content and boundaries of which are well-established.  The appellant works in conjunction with the SMT in deciding how to carry out major projects concerning organizational effectiveness.  Thus, she does not exercise independent judgment and discretion in regard to the overall scope of major projects.  Additionally, her work does not involve planning and carrying out projects of the magnitude expected at this level.

Level 2-4 is credited for 450 points.

Factor 3, Guidelines

This factor covers the nature and extent of guidelines for performing the work and the judgment needed to apply the guidelines or develop new guidelines.

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.  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.

This position meets Level 3-4.  The employee uses NPS management policies, directives, memoranda, as well as applicable laws and regulations that outline and govern the programs under administration and business management.  The appellant provided examples of guidelines used to include the Park Compendium, Director's Orders, reference manuals, and the Code of Federal Regulations.  The guidelines used are not all inclusive and judgment is required to apply them to specific tasks.  For example, when working with the fee program or special use permits, guidelines overlap and the appellant uses different sources to obtain necessary guidance.  Additionally, the appellant develops further guidelines for the park from the regional and national policies and procedures.  For example, the appellant established guidelines for park supervisors to follow when providing performance awards to employees that ensured a fair and equitable process across the organization within budgetary constraints.

At Level 3-5, guidelines consist of basic administrative policy statements concerning the issue or problem being studied, and may include reference to pertinent legislative history, related court decisions, State and local laws, or policy initiatives of agency management.  The employee uses judgment and discretion in determining intent, and in interpreting and revising existing policy and regulatory guidance for use by others within or outside the employing organization.  Some employees review proposed legislation or regulations which would significantly change the basic character of agency programs, the way the agency conducts its business with the public or private industry, or which modify important inter-agency relationships.  At this level, the employee is recognized as an expert in the development and/or interpretation of guidance on program planning and evaluation in their area of specialization.

Level 3-5 is not met as the appellant works within policy controls more specific than legislative history, related court decisions, or State and local laws, etc.  The appellant’s interpretive responsibility is limited to the park activities and she is not involved in developing agency policies and their implementing procedures, as indicated at this level.  This type of work is conducted at offices at higher levels within the NPS and/or Department of the Interior (Interior).  While the appellant does develop guidelines, they are constrained to the operations of the park and are not policy or regulatory guidelines for use by others outside of the immediate organization.

Level 3-4 is credited for 450 points.

Factor 4, Complexity

This factor covers the nature of the assignment, difficulty in identifying what needs to be done, and difficulty and originality involved in performing the work.

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 next lower level, 4-3.  In contrast, this level requires the application of qualitative, quantitative and analytical techniques that frequently require modification to fit a wider range of variables.  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. 

Level 4-4 is fully met.  The appellant’s role in managing the park’s administrative program and as a member of the SMT are instrumental in the planning of the park operations and input into the managerial decisions made concerning operations.  She participated in developing the park’s General Management Plan, outlining the long-range plans of the park in regard to programming, construction, land acquisition, and overall aspects of what management envisions the park to become in 10 years or more.  The plan outlines the major goals and the steps necessary to obtain these goals.  She also participated in core operations reviews, outlining the necessary cuts that would be required in the event of a decrease in funding levels.  This meeting was facilitated by a representative for the regional office, but the appellant was responsible for leading the management team in discussions and workshops to come to the appropriate conclusions, should this lack of funding scenario be encountered.  This review incorporated each aspect and division of the park.

At Level 4-5, the 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.  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.  Illustrations at this level discuss assignments typically affecting major administrative programs of an agency or nationwide programs where the employee develops new approaches to program evaluation which serve as precedents for others.

While the appellant's role in the senior management team (SMT) of the park is instrumental in the decision making and long-term planning of the park's operations, it does not fully meet the intent of Level 4-5 since overall responsibility is not vested in her position.  Further, unlike level 4-5, the appellant does not work in an environment complicated by actions being measurable primarily in predicative terms or where findings and conclusions are highly subjective and are not readily susceptible to verification through replication of study methods or reevaluation of results.  Instead, the appellant deals with work operations within a single park within the confines of program plans made at higher echelons within the NPS. 

Level 4-4 is credited for 225 points. 

Factor 5, Scope and Effect

 This factor covers the relationship between the purpose, breadth, and depth of the assignment and considers the impact of the work products or services both within and outside the organization.

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.

The position meets Level 5-4.  The appellant’s work involves ensuring the effectiveness of administrative programs at the operating level within the organization.  This responsibility involves working across organizational lines with cooperating organizations, who work in conjunction with the park.  For example, the appellant works with the administrative staff of the city of [City, State], in securing funding through a grant setup with the park to provide resources for an expanded police force to assist when large numbers of visitors are in the area due to the national attraction and programs of the park.  The appellant is responsible for ensuring the business operations of the park support the organization in carrying out its mission.

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.  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. 

Level 5-5 is not met.  The appellant’s work within the SMT of the park does encompass long-range program plans, goals, and objectives.  However, the scope of this work is limited to the operating level within the NPS.  The scope of work identified at this level includes programs that are conducted throughout a bureau, such as the NPS, or in a regional structure of equivalent scope.  The appellant does not advise top management within the NPS. Rather, her responsibilities are limited to the park and related activities which does not constitute the scope identified at this level.

Level 5-4 is credited for 225 points.

Factor 6, Personal Contacts; and Factor 7, Purpose of Contacts

These factors cover the type and level of contacts made in carrying out the work and the reasons for those contacts.  Under the standard, each factor is evaluated separately, but a combined point credit is established by determining where the respective levels intersect.  The relationship between Factors 6 and 7 presumes that the same contacts will be evaluated under both factors.

Under personal contacts, the appellant’s contacts match Level 3.  At this level, contacts include program officials within the agency but several managerial levels removed from the employee and persons outside the agency which may include consultants, contractors, or business executives in a moderately unstructured setting.  The appellant makes contact with officials of the local towns in the vicinity of the park and administrative staff at the centralized offices within the NPS..  Additional contacts include managerial staff of NPS cooperating organizations/partners and administrative staff at the regional office.

Level 4 is not met.  At this level contacts are with 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.  Contacts of this level are not made by the appellant.

Under purpose of contacts, Level c is met, where contacts are to influence managers or other officials to accept and implement findings and recommendations on organizational improvement or program effectiveness.  The appellant is responsible for influencing officials within the centralized offices of the NPS to take action as necessary for the best interest of the park.  For example, she addressed an employee pay issue with the SHRO in which the SHRO initially disagreed with the outcome sought by the park.  She was instrumental in discussing the issue with the SHRO and various entities involved to influence the SHRO officials to take the action requested by park management.  She is also responsible for communicating with local city officials to enhance the effectiveness of park operations such as securing their assistance with necessary street closures when large crowds of visitors are present at the park for special events. 

Level d is not met, where contacts are to justify or settle matters involving significant or controversial issues: e.g., recommendations affecting major programs, dealing with substantial expenditures, or significantly changing the nature and scope of organizations.  Contacts of this scope are not made by the appellant, but instead are made by higher level management officials within the agency.

Level 3c is credited for 180 points.

Factor 8, Physical Demands

This factor covers the physical demands placed upon an employee in this position.

This position meets Level 8-1, which covers sedentary work.

Level 8-2 is not met.  This level covers assignments that involve long periods of standing, bending, and stooping and also considers work operations in an industrial or comparable work area.  The appellant’s assignments and work area do not require this type of physical activity.

Level 8-1 is credited for 5 points.

Factor 9, Work Environment

This factor considers the risks and discomforts that may be imposed on an employee in this position.

 This position meets Level 9-1, which describes a typical office environment.

Level 9-2 is not met.  This level entails assignments that regularly require visits to manufacturing, storage, or other industrial areas, and involve moderate risks or discomforts.  Protective clothing, gear and observance of safety precautions are required.  The appellant’s position does not involve this type of work environment or hazards.

Level 9-1 is credited for 5 points.

Summary of application of AAGEG:

Factor Level Points
1.  Knowledge required by the position  1-7 1250
2.  Supervisory controls 2-4 450
3.  Guidelines 3-4 450
4.  Complexity 4-4 225
5.  Scope and Effect 5-4 225
6&7.   Personal Contacts & Purpose of contacts 3-c 180
8.  Physical demands  8-1    5
9.  Work environment 9-1    5
Total points 2790

The total of 2790 points falls within the GS-12 grade level point range (2755-3150 points) on the grade conversion table in the AAGEG.

Evaluation of supervisory duties using the GSSG

The GSSG is a cross-series guide used to determine the grade level of supervisory positions in the General Schedule.  The GSSG has six evaluation factors, each with several factor-level definitions and corresponding point values.  Positions are evaluated by crediting the points designated for the highest level met under each factor, and converting the total to a grade by using the grade conversion table provided in the guide. 

Factor 1, Program Scope and Effect

This factor assesses the general complexity, breadth, and impact of the program areas and work directed, including its organizational and geographic coverage.  It also assesses the impact of the work both within and outside the immediate organization.  Each level defines both the scope and effect.  Scope addresses the general complexity and breadth of the program (or program segment) directed; and the work directed, the products produced, or the services delivered.  The geographic and organizational coverage of the program (or program segment) within the agency structure is also included under scope.  The effect addresses the impact of the work, the products, and/or the programs described under "scope" on the mission and programs of the customers, the activity, other activities in or out of government, the agency, other agencies, the general public, or others.

To assign a factor level, the criteria for both scope and effect must be fully met.  In evaluating the population affected under this factor, we may only consider the total population serviced directly and significantly by a program.  We cannot count the total population in the geographic area potentially covered by a program.

At Level 1-2, the scope encompasses a program segment or work directed that is administrative, technical, complex clerical, or comparable in nature.  The functions, activities, or services provided have limited geographic coverage and support most of the activities comprising a typical agency field office, an area office, a small to medium military installation, or comparable activities within agency program segments.  The effect encompasses services or products supporting and significantly affecting installation level, area office level, or field office operations and objectives, or comparable program segments; or provide services to a moderate, local or limited population of clients or users comparable to a major portion of a small city or rural county.

The appellant's position meets both the scope and effect identified in Level 1-2.  The administrative division directed by the appellant is responsible for the administrative function of the park.  The services provided support the operations of the Park with various administrative duties and complex clerical work which is comparable to a field office.

At Level 1-3, the scope directs a program segment that performs technical, administrative, protective, investigative, or professional work.  The program segment and work directed typically have coverage which encompasses a major metropolitan area, a State, or a small region of several States.  Providing complex administrative, technical or professional services directly affecting a large or complex multi-mission military installation also falls at this level.  The effect is activities, functions or services accomplished directly and significantly impact a wide range of agency activities, the work of other agencies, or the operations of outside interests, or the general public.  At the field activity level (involving large, complex, multi-mission organizations and/or very large serviced populations) the work directly involves or substantially impacts the provision of essential support operations to numerous, varied and complex technical, professional and administrative functions.

The scope and effect identified at Level 1-3 are beyond that provided by the administrative division supervised by the appellant.  The organization serviced is not of the scope explained at this level, such as a large (employee-equivalent population exceeding 4000 personnel, and with a variety of serviced technical functions) or complex multi-mission military installation as defined in the GSSG.  While the work of the division overlaps with various cooperating organizations working with the park, the effect of this work is not comparable to substantially impacting the provision of essential support operations to numerous, varied and complex technical, professional and administrative functions to the substantially larger population required to meet Level 1-3.

Level 1-2 is credited for 350 points.

Factor 2, Organizational Setting

This factor considers the organizational situation of the supervisory position in relation to higher levels of management. 

The appellant's position meets Level 2-2 where the position is accountable to a position that is one reporting level below the first SES, flag or general officer, or equivalent or higher level position in the direct supervisory chain.  The appellant reports to the Superintendent of [installation], who reports to the Deputy Director of the [Region], who reports to the Director, an SES position.  While the appellant's position is two supervisory levels below the first SES, the Deputy Director shares in the responsibility for managing the Region.  As such, the appellant's position is credited as one reporting level below the first SES as the GSSG stipulates that a position reporting to a deputy or full assistant chief is credited as reporting to the chief.

 Level 2-2 is credited for 250 points.

 Factor 3, Supervisory and Managerial Authority Exercised

This factor covers the delegated supervisory and managerial authorities which are exercised on a recurring basis. 

The appellant's position meets Level 3-2c in that she carries out at least three of the first four, and a total of six or more of the authorities and responsibilities listed under that level.  Like Level 3-2c she:  (1) plans work to be accomplished by subordinates, sets and adjust short-term priorities, and prepares schedules for completion of work; (2) assigns work to subordinates based on priorities, selective consideration of the difficulty and requirements of assignments, and the capabilities of employees; (3) evaluates work performance of subordinates; (4) gives advice, counsel, or instruction to employees on both work and administrative matters; (5) interviews candidates for positions in the unit and recommends appointments, promotions, or reassignments; (6) hears and resolves complaints from employees, and refers group grievances and serious unresolved complaints to higher level supervisors; (7) is authorized to take minor disciplinary measures and recommends other action in more series cases; (8) identifies developmental and training needs of employees and arranges for such training; (9) finds ways to improve work production or increase the quality of work directed; and (10) develops performance standards.

The appellant’s position does not meet Level 3-3a.  Unlike Level 3-3a, she does not have the managerial authority to set a series of annual, multi-year, or similar types of long range work plans and schedules for in-service or contracted work implemented by subordinate organizational units or others.  She is not closely involved with high level program officials or comparable agency-level staff (Interior) in the development of overall goals and objectives for programs or program segments.  Such matters are controlled by and addressed at higher levels within the NPS. 

The appellant’s position also does not meet Level 3-3b.  Although she exercises the delegated supervisory authorities and responsibilities described at Level 3-2c of this factor, unlike the requirements of Level 3-3b she does not exercise at least eight of the fifteen responsibilities listed at that level.  Moreover, the workload she supervises is not so large or complex to require the regular and recurring exercise of such responsibilities.  For example, the division’s workload is not so large and complex as to require the direction of subordinate staff through the efforts of subordinate supervisors, team leaders or similar personnel (Elements 1, 2, 5, 6, 8 and 10); making the non-routine or costly resource decisions envisioned at this level (e.g., the annual internal division budget is not multimillion as defined in Element 4,  the appellant does not routinely deal with extensive overtime or non-routine or costly training as defined in Elements 11 and 13).  Consequently, Level 3-3b cannot be awarded.

Level 3-2c is credited for 450 points.

Factor 4, Personal Contacts

This is a two part factor which assesses the nature, Subfactor 4A, and the purpose, Subfactor 4B, of personal contacts related to supervisory and managerial responsibilities.  The contacts credited under both Subfactors must be based on the same contacts.

Subfactor 4A:  Nature of contacts

The appellant's position meets Level 4A-2.  Like this level, contacts include officials of the local towns in the vicinity of the park and managerial staff of NPS cooperating organizations/partners.  Additional contacts include administrative staff at centralized offices within the NPS, peer division chiefs within the park, and administrative staff at the regional office. 

Level 4A-3 is not met.  Examples of contacts at this level are with high ranking managers, supervisors, and technical staff at bureau and major organization levels of the agency, administrative support staff at agency headquarters, or comparable personnel in other Federal agencies; contracting officials and high level technical staff of large industrial firms; and/or local officers of regional or national trade associations, public action groups, or professional organizations.  These contacts take place in meetings and conferences or may be unplanned where the employee is designated as a contact point by higher management, and often require extensive preparation of briefing materials or up-to-date technical familiarity with complex subject matter.  While the appellant does contact agency administrative staff for various administrative inquiries related to the park or to provide information, the contacts do not entail the more complex settings and preparation identified at this level.

Level 4A-2 is credited for 50 points.

Subfactor 4B:  Purpose of contacts

The appellant's position meets Level 4B-2.  Like this level, the appellant makes contact with outside cooperating organizations with the park, coordinates work with these organizations, and is instrumental in resolving differences of opinion among managers, supervisors, and others within the park.

Level 4B-3 is not met.  At this level the purpose of contacts is to justify, defend, or negotiate in representing the project, program segment, or organizational unit directed; obtain or commit resources; and gain compliance with established policies.  While the appellant does provide administrative guidance to the SMT, input into the managerial decisions of the park, and persuades the SMT to accept items related to the business operations of the park, the full intent of this level is not met as the appellant does not have the sole authority to obtain or commit resources or speak with finality for her program.  This authority is retained by the Superintendent.

Level 4B-2 is credited for 75 points.

Factor 5, Difficulty of Typical Work Directed

This factor measures the difficulty and complexity of the basic work most typical of the organization(s) directed, as well as other line, staff or contracted work for which the supervisor has technical or oversight responsibility directly or through subordinate supervisors, team leaders or others.  This level is determined by identifying the highest grade which best characterizes the nature of the basic (mission-oriented) non-supervisory/non-leader work performed or overseen by the organization directed, and which constitutes 25 percent or more of the workload of the organization.

The GSSG excludes from consideration the work of lower level positions which primarily support or facilitate the basic work of the unit.  Therefore, we excluded the Administrative Support Assistant, GS-303-05, from our consideration of the appellant’s organization.  As discussed previously, the Contract Specialist, GS-1102-11, is excluded from consideration under the GSSG due to the appellant only administratively supervising the position.  The Information Technology Specialist, GS-2210-12, is a shared position, with only 60 percent of the workload attributed to the appellant’s organization.  The workload is broken down as follows:


0.6       Information Technology Specialist, GS-2210


1.0       Budget Analyst, GS-560


1.0       Budget Technician, GS-561

1.0       Program Assistant, GS-303



1.0       Supply Technician, GS-2005

Total nonsupervisory mission-oriented workload is 4.6.  The percentage of nonsupervisory mission-oriented workload at each grade level is as follows:

GS-12:            13%

GS-11:            22%

GS-7:              43%

GS-6:              22%

At 22 percent, the GS-11 grade level work constitutes less than 25 percent of the nonsupervisory workload.  When combined with the 13 percent expended on the GS-12 workload, we find the GS-11 work represents the highest level of nonsupervisory work creditable under this factor.  Using the conversion chart in the GSSG for Factor 5, a GS-11 base level equates to Level 5-6.

Level 5-6 is credited for 800 points.

Factor 6, Other Conditions

This factor measures the extent to which various conditions contribute to the difficulty and complexity of carrying out supervisory duties, authorities, and responsibilities.  There are two steps involved in assigning a level under Factor 6:  (1) select the highest level that the position meets, and (2) if the level selected in step 1 is either 6-1, 6-2, or 6-3, refer to the Special Situations section of Factor 6.  If the position meets 3 or more of the situations, then a single level is added to the level selected in the first step.  If the level selected under step 1 is either 6-4, 6-5, or 6-6, the Special Situations section does not apply, and no level is added to the one selected in step 1. 

Level 6-4a requires substantial coordination and integration of a number of major work assignments, projects, or program segments of professional, scientific, technical, or administrative work comparable in difficulty to the GS-11 level.  An example of this work provided by the standard is:  indentifying and integrating internal and external program issues affecting the immediate organization, such as those involving technical, financial, organizational, and administrative factors.

Level 6-4a is met.  As indicated in Factor 5 above, the base level of work was identified at the GS-11 level.  The appellant is responsible for supervising the administrative division of the park, responsible for carrying out all administrative functions to include financial and administrative factors.  The appellant oversees the work of the budget staff in duties such as, preparing budget estimates and justifications for park programs, preparing budget cost projection plans, and tracking various accounts to include project and labor costs, ensuring spending levels remain within constraints and identifying any issues.  The administrative team is also responsible for ensuring the information technology needs of the organization are met, recommending technological resources to support and enhance the operations of the park.

Level 6-5a requires significant and extensive coordination and integration of a number of important projects or program segments of professional, scientific, technical, managerial, or administrative work comparable in difficulty to the GS-12 level.  Supervision at this level involves major recommendations which have a direct and substantial effect on the organization and projects managed.  This level is not met as the base level of work, as indicated in Factor 5 above, does not meet the GS-12 grade level.

Level 6-5b pertains to supervision of highly technical, professional, administrative, or comparable work at GS-13 or above involving extreme urgency, unusual controversy, or other, comparable demands due to research, development, test and evaluation, design, policy analysis, public safety, public health, medical, regulator, or comparable implications.  This level and type of work is not found in the appellant's position.

Level 6-5c pertains to managing work through subordinate supervisors and/or contractors who each direct substantial workloads comparable to the GS-11 level.  The appellant is a first line supervisor and does not oversee the work of subordinate supervisors and/or contractors who each direct substantial GS-11 workloads.

Level 6-4a is credited for 1120 points.

Summary of application of GSSG:

Factor Level Points
1.  Program Scope and Effect 1-2 550
2.  Organizational Setting 2-2 250
3.  Supervisory & Managerial Authority Exercised 3-3 450
4.  Personal Contacts
A.  Nature of Contacts 4A-2 50
B.  Purpose of Contacts 4B-2 75
5.  Difficulty of Typical Work Directed 5-6 800
6.  Other Conditions 6-4a 1120
Total 3,095


The total of 3095 points falls within the GS-12 grade level point range (2755-3150 points) on the grade conversion table in the GSSG.


By comparison with the AAGEG, the appellant performs administrative duties at the GS-12 level and by comparison with the GSSG, her supervisory responsibilities are evaluated at the GS-12 level.  The appropriate grade for the appellant's position is GS-12.


The appellant’s position is properly classified as Administrative Officer, GS-341-12.

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