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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

Susan C. Porte
Program Analyst
GS-343-13
Program Management Staff
Government Employee Services Division
National Finance Center,
Office of the Director
Office of the Chief Financial Officer
U.S. Department of Agriculture
New Orleans, Louisiana
Program Analyst
GS-343-12
C-0343-12-09

Linda Kazinetz
Classification Appeals and FLSA Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance

06/14/2017


Date

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

Since this decision lowers the grade of the appealed position, it is to be effective no later than the beginning of the sixth pay period after the date of this decision, as permitted by 5 CFR 511.702.  The applicable provisions of parts 351, 432, 536, and 752 of title 5, Code of Federal Regulations, 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 U.S. Office of Personnel Management (OPM).

Introduction

The appellant’s position is currently classified as Program Analyst, GS-343-13.  However, she believes her position should be classified at the GS-14 level.  The position is assigned to Program Management Staff, Government Employee Services Division (GESD), National Finance Center (NFC), Office of the Director, Office of the Chief Financial Officer (OCFO), U.S. Department of Agriculture (USDA) in New Orleans, Louisiana.  We have accepted and decided this appeal under section 5112 of title 5, United States Code.

General issues

The appellant makes various statements about her agency’s classification of her position description (PD), asserts they failed to fully consider the complexity and volume of work she performs and compares her position to GS-14 Program Analyst positions within her organization.  In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of the appellant’s position (5 U.S.C. 5106, 5107, and 5112).  Because our decision sets aside all previous agency decisions, the appellant’s concerns regarding her agency’s classification review process are not germane to this decision.  By law, we must classify positions solely by comparing their current duties and responsibilities to OPM standards and guidelines.  Since comparison to standards is the exclusive method for classifying positions, we cannot compare the appellant’s position to other positions, which may or may not have been properly classified, as a basis for deciding her appeal.  In addition, volume of work cannot be considered in determining the grade of a position (The Classifier’s Handbook, Chapter 5).

Position information

The appellant’s supervisor certified to the accuracy of the appellant’s PD of record.  In the appellant’s original appeal request, she disagreed with the accuracy of her PD.  However, in subsequent discussions with OPM, she certified to the accuracy of her PD but disagreed with her agency’s classification of her position.

NFC is an organizational component of USDA’s OCFO and is a fee-for-service provider responsible for maintaining core functions of software development, business development, and production operations for electronic financial management services (FMS) programs (e.g., payroll and personnel systems) and human resources management services (HRMS) (e.g., human resources line of business systems), and for developing and providing services designed to increase the efficiency and effectiveness of electronic FMS and HRMS programs and services for customers inside and outside USDA.

The appellant performs project management duties and responsibilities within NFC’s GESD which, among other things, is responsible for the coordination and implementation of OCFO’s FMS and HRMS software (e.g., Paycheck8, WebTA, EmpowHR) with the current systems and programs of their customers.  The appellant coordinates with a variety of individuals, organizations, and businesses (e.g., customers, PLs, PMs, contractors, GESD’s Information Technology Service Division (ITSD)) to identify and address a variety of technical issues (e.g., system compatibility issues, system error codes) and customer satisfaction issues (e.g., product integration shortfalls, data deficiencies) which may arise.  She assists in the establishment of metrics for determining productivity, quality, and project status reporting (e.g., start dates, end dates, milestones).  She coordinates with GESD and ITSD managers to identify and discuss challenges and goals associated with established project objectives; ensures plans and schedules are updated; and uses project management software tools, communications software, and graphics software to develop project schedules and ensure customers, PMs, and directors are informed of the status of their requests.

When the integrated systems are working properly, the appellant performs a post-project review with the customers, PMs, directors, and other affected parties and distributes copies of applicable documents and information (e.g., lessons learned table) as appropriate.  Upon completion of the post-project review, she hands the project over to one of NFC’s customer liaisons (e.g., quality assurance) who is responsible for continued management of the project.

The appellant provides suggestions and recommendations to NFC and GESD management regarding the creation, implementation, monitoring, and evaluation of process management plans designed to improve the division’s software development capabilities and quality and software process improvement work groups.  She also serves as a member of the software improvement evaluation team which determines the strengths and weaknesses of NFC’s software by comparing it to the Software Engineering Institute’s Capability Maturity Model.  She monitors and tracks project life cycles and makes recommendations for improvements to her supervisor or higher-level management regarding program and project-related policies, processes, and procedures.  She reviews a variety of reports and policy statements for issues which could affect project-related goals, objectives, and methods (e.g., revisions to implementation or completion metrics and timelines, updated contract requirements).  She tracks project data and develops reports which assist various organizational echelons within USDA with efforts to improve the quality, effectiveness, and efficiency of the processes, procedures, and products associated with the business development program.  She also maintains a current knowledge of industry practices regarding software development and software project management through review of internal and external sources and methods (e.g., professional publications, conferences, agency training).

The appellant reviews new and existing policies, processes, and SOPs related to the administrative, procedural, and technical aspects of NFC software project management.  She coordinates with NFC and GESD staff to establish, document, communicate, and promote project management policies, procedures, guidelines, standards, and tool usage and provides recommendations for modifications and updates to the aforementioned guidance to her supervisor and higher-level management as appropriate.  She informs and advises PLs, PMs, and other internal and external personnel with regard to a variety of policies, processes, and standard operating procedures (SOPs) related to FMS and HRMS projects.  She also coordinates with her supervisor and coworkers to improve existing project management skills and capabilities for GESD.

She provides support for short- and long-term organizational capability maturity goals in order to ensure NFC’s software reliability and sustainability standards match current industry standards, and helps ensure the reliability and consistency of the process improvement efforts and software implementation issue resolution related to assigned projects for both NFC and its customers.  She may also assist with software diagnosis issues and reviews and may audit assigned projects for adherence to agency and industry processes, procedures, and standards.

In reaching our classification decision, we carefully considered all information gained through interviews, as well as documents submitted by the appellant and her agency.

Series, title, and standard determination

The agency has allocated the work of the appellant’s position to the Management and Program Analysis Series, GS-343, titled it “Program Analyst,” and graded it by reference to the Administrative Analysis Grade Evaluation Guide (AAGEG).  The appellant does not disagree with the series, title, and standard determination of her agency and, based on our review, we concur.

Grade determination

There are no grade-level criteria specific to the GS-343 series.  Therefore, positions in this series are evaluated by reference to 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 the nine factors within the guide.  The total points are then converted to a grade level by using the grade conversion table provided in the standard.  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 in any significant aspect to meet a particular factor-level description, the point value for the next lower factor level must be assigned, unless the deficiency is balanced by an equally important aspect that meets a higher level.

The appellant’s agency assigned the following factor levels to her work:  1-8, 2-4, 3-4, 4-5, 5-5, 6-3, 7-c, 8-1, and 9-1.  The appellant agrees with the factor levels the agency assigned for Factors 1, 2, 3, 6, 7, 8, and 9.  However, she disagrees with the agency’s assignment of Levels 4-5 and 5-5 and believes her work should be credited with Levels 4-6 and 5-6 respectively.  After careful review of the record, we concur with the agency’s factor-level assignments for Factors 2, 3, 6, 7, 8, and 9.  However, we disagree with the agency’s factor-level assignments for Factors 1, 4, and 5.  Therefore, we have evaluated Factors 1, 4, and 5 below.

Factor 1, Knowledge required by the position

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

At Level 1-7, work requires knowledge and skill in analyzing and evaluating the efficiency and effectiveness of program operations carried out by administrative or professional personnel, or substantive administrative support functions such as supply, budget, procurement, or human resources which 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 (e.g., program access, resources, equipment).  Projects and studies typically require knowledge of the major issues, program goals and objectives, work processes, and administrative operations of the organization.  This knowledge is used to conduct studies to evaluate and recommend ways to improve the effectiveness and efficiency of work operations in a program or support setting.  Knowledge may also be used to develop new or modified work methods, records and files, management processes, staffing patterns, and procedures for automating work processes for the conduct of administrative support functions or program operations.

Level 1-8 analysts are expert analysts who have mastered the application of a wide range of qualitative and quantitative methods for the assessment and improvement of program effectiveness or the improvement of complex management processes and systems.  Level 1-8 requires comprehensive knowledge of the full range of administrative laws, regulations, policies, and precedents applicable to the administration of one or more important public programs.  This knowledge is used to carry out such assignments as designing and conducting comprehensive management studies where the boundaries are extremely broad and difficult to determine in advance; preparing recommendations for legislation to change the way programs are carried out; or evaluating new legislation for potential program impact and to translate it into program actions and services.  The proposals made involve substantial agency resources or require extensive changes in established procedures.

The distinction between Levels 1-7 and 1-8, as it relates to the appellant’s position, lies in the breadth of the knowledge and responsibility typically required to perform the work.  Level 1-7 describes assignments where the employee is responsible for understanding existing programs and activities for the purpose of supporting and facilitating the line or program operations of the organization.  Conversely, Level 1-8 typically requires an employee to exercise much broader staff responsibilities involved with defining and establishing programs and developing and initiating major changes to the activities or services of existing programs.  In addition, Level 1-8 requires a much broader knowledge of the “range of administrative laws, policies, regulations, and precedents applicable to the administration of one or more important public programs,” which is applied in the context of such assignments as making legislative recommendations that change the way programs are carried out or substantially alter the purpose, intent, or requirements of operational programs.  In contrast, Level 1-7 requires knowledge of laws, policies, regulations, and precedents affecting specific programs and projects.  Thus, Level 1-7 is associated with the operational work of the organization while Level 1-8 is concerned with issues relating to and affecting the fundamental nature and function of agency programs (e.g., new and proposed legislation, agency-level policy changes). 

Within this context, the appellant’s work is analogous to Level 1-7 in that she performs project management work in support of OCFO’s current business development program which integrates NFC FMS and HRMS computer software with those of specific customers within the boundaries of existing laws, policies, regulations, and precedents rather than exercising responsibility for the overall scope, design, and requirements of the business development program.  Similar to Level 1-7, she makes recommendations based on an analysis of the compatibility of specific customer systems and objectives, as well as existing policies and procedures affecting both USDA and individual customers.  She also interprets and communicates project rules and procedures, establishes deadlines, answers technical questions, and takes appropriate steps to comply with established laws, policies, SOPs, and regulatory requirements associated with the integration of a variety of NFC FMS and HRMS computer software with those of various customers, both inside and outside USDA, in support of OCFO’s business development program.  Also similar to Level 1-7, she maintains and tracks data and provides reports associated with projects and program-related information and activities which may affect the efficiency and effectiveness of OCFO’s business development program.  Like 1-7, the appellant’s work requires considerable interpersonal skills to facilitate discussions with peers, contractors, supervisors, and customers inside and outside USDA (e.g., Department of Homeland Security, Department of Justice) to gather information and discuss needs and issues.  She gathers, researches, compiles, and shares information from various sources; identifies resources needed for individual projects; and provides technical and administrative project and program guidance to peers, contractors, and customers.

Level 1-8 is not met. At this level, studies, decisions, and recommendations address the broader program responsibilities of an organization and affect the review, assessment, and development of significant programs and policies or the improvement of complex management processes and systems.  In contrast, the appellant’s projects are confined to GESD activities and are focused on analyzing, supporting, and implementing segments of the OCFO’s business development program, i.e., individual software development projects where the parameters are established (e.g., integrating an existing software product with the customer’s current systems) rather than comprehensive and “extremely broad” management studies where the boundaries are undefined.  Studies, decisions, and recommendations made by the appellant do not involve substantial agency resources or directly influence the focus and/or direction of USDA’s programs or policies.  Therefore, the appellant’s work does not have the far-reaching impact or complexity envisioned at Level 1-8.

Level 1-7 is credited (1250 points).

Factor 4, Complexity

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

At Level 4-4, work involves gathering information, identifying and analyzing issues, and developing recommendations to improve the effectiveness and efficiency of work operations in a program or program support setting.  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.

At Level 4-5, work consists of projects and studies requiring analysis of interrelated issues of effectiveness, efficiency, and productivity of mission-oriented programs.  Typical assignments require developing detailed plans, goals, and objectives for the long-range implementation and administration of the program, where the work deals less with concrete administrative processes than with subjective issues requiring value judgments regarding the relative advantages and disadvantages of various ways of improving the effectiveness of program administration.

The complexity of the appellant’s work is consistent with Level 4-4 in that she adapts existing methods and techniques to identify, predict, and resolve possible computer program integration issues and to meet the unique needs and requirements of each project (e.g., current data storage capacity, organizational goals and objectives, implementation deadlines).  She is responsible for gathering extensive amounts of information from a variety of automated and non-automated sources (e.g., USDA, OCFO, and NFC policy and procedure manuals, Federal laws and regulations, customer staff, information technology specialists, contractors), both inside and outside her agency, which she uses to facilitate FMS and HRMS software integration.  Like Level 4-4, the issues she encounters are not always susceptible to direct observation and analysis and require her to apply qualitative and quantitative analytical techniques which must frequently be modified in order to assess the effectiveness and efficiency of specific projects.  For example, in assessing the cost of integrating the customer’s currently used software and operating systems with NFC’s software, the appellant must consider numerous variables, such as manpower and resource availability, timelines and milestones, and scheduling which may change during the project cycle or from project to project and are difficult to predict.  Similar to Level 4-4, the appellant provides advice and recommendations for improving the effectiveness and efficiency of NFC’s software integration projects which provide support OCFO’s business development program.

Level 4-5 is not met.  The appellant asserts her work directly affects the effectiveness, efficiency, and productivity of mission-oriented programs.  However, her work is not focused on the subjective considerations aimed at improving the overall administration of agency programs indicative of Level 4-5.  Instead, the appellant’s work focuses on technical and administrative issues and considerations necessary to support the integration of NFC’s FMS and HRMS software with the electronic systems and programs of specific customers.  In addition, the appellant does not perform work analogous to the broad program-oriented activities described at Level 4-5 (i.e., work that relates to the operation of the overall program rather than to specific projects and program support activities).  Instead, the project management duties performed by the appellant are primarily focused on improving the effectiveness and efficiency of NFC’s support for OCFO’s business development program.

Since the complexity of the appellant’s work does not meet the criteria for Level 4-5, it is neither necessary nor appropriate to make comparisons to Level 4-6 criteria.

Level 4-4 is credited (225 points).

Factor 5, Scope and effect

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

At Level 5-4, the purpose of the work is to assess the efficiency and productivity of program operations or to analyze and resolve problems in the staffing, effectiveness, and efficiency of administrative support and staff activities.  At this level, work contributes to improvement of program operations and/or administrative support activities at different echelons and/or geographic locations in the organization, or may affect the nature of administrative work done in components of other agencies.

At Level 5-5, the purpose of the work is to analyze and evaluate major administrative aspects of substantive, mission-oriented programs, such as 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 study reports prepared 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.

The appellant’s work meets Level 5-4 in that the appellant, within the context of assigned projects, performs analysis of, and provides recommendations for, improvements to FMS and HRMS program integration policies, processes, and procedures.  Her analysis and recommendations contribute to the efficiency and effectiveness of OCFO’s business development program which affect different echelons within USDA (e.g., GESD, NFC), and the nature, effectiveness and efficiency of electronic FMS and HRMS processes and procedures of customer agencies and organizations outside USDA.

The appellant’s work does not meet Level 5-5.  At this level, work is associated with the overall design, structure, and administration of substantive agency or bureau programs or programs affecting large, multi-mission field activities.  Work at this level addresses broad agency program and policy issues and concerns, such as significant administrative management issues; new program regulations and/or guidelines; new analytical tools and criteria used to measure program goals and objectives, etc.  In contrast, the project management work performed by the appellant does not affect the design, structure, and administration of overall agency and/or bureau programs or regularly address broad agency programs, policy issues, and concerns as would be expected at Level 5-5.  Instead, the appellant’s work is primarily focused on, and limited to, providing technical and administrative support for the OCFO’s business development 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 the overall organization as would be expected at Level 5-5.  Instead, the appellant typically works within the parameters of the OCFO’s business development program and makes recommendations and suggestions related to issues and concerns directly associated with processes and procedures affecting the aforementioned program.  Responsibility for decisions and recommendations which may significantly impact major aspects of legislation and regulations and/or USDA’s administrative systems and programs rest with analysts and administrative officials at higher levels within the organization.

Therefore, the appellant’s work is analogous to Level 5-4 in that the appellant performs project management work which analyzes and supports OCFO’s business development program; supports activities at multiple echelons within USDA; and affects the plans, goals, and effectiveness of the missions and programs at the aforementioned echelons of the organization and components of other agencies.

Since the scope and effect of the appellant’s work do not meet the criteria for Level 5-5, it is neither necessary nor appropriate to make comparisons to Level 5-6 criteria.

Level 5-4 is credited (225 points).

Summary

Summary

Factors

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     

3c

               180

8. Physical demands

8-1

                   5

9. Work environment

9-1

                   5

Total

             2790

In accordance with the grade conversion table on page 4 of the AAGEG, the total of 2790 points falls within the GS-12 range (2755-3150 points).  Therefore, the appellant’s position is graded at the GS-12 level.

Decision

The appellant's position is properly classified as Program Analyst, GS-343-12

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