Washington, DC

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

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Damon B. Ford
Acting Classification Appeals and FLSA Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance


11/20/2020

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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).

As indicated in this decision, our findings show the appellants official position description (PD) does not meet the standard of adequacy described in section III.E. of the Introduction.  Since PDs must meet the standard of adequacy, the agency must revise the PD to reflect our findings.  The servicing human resources office must submit a compliance report containing the revised PD and corrected Standard Form 50s 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), Agency Compliance and Evaluation (ACE), Washington, DC, office.

Introduction

The appellants’ position is currently classified as Peripheral Equipment Operator, GS-0350-04, assigned to the Payment and Mail Operations Branch, Kansas City Financial Center, Missouri, or Philadelphia Financial Center, Pennsylvania, Bureau of the Fiscal Service (BFS), U.S. Department of Treasury (Treasury).  When this appeal was originally submitted to the U.S. Office of Personnel Management (OPM) by the appellants’ designated representative there were twenty-four appellants.  However, there are only eight remaining appellants as many have moved into other positions and one has retired.  The appellants believe their duties and responsibilities warrant an upgrade to the GS-07 level.  We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

Background

In August 2015, OPM’s Merit System Accountability and Compliance (MSAC), Agency Compliance and Evaluation (ACE) Philadelphia, now MSAC, ACE Central, conducted a Human Capital Management Evaluation (HCME) of Treasury’s BFS.  In March 2016, the HCME report was issued including addressing the classification of a position reviewed under OPM’s authority in 5 U.S.C. 5110 to periodically review the classification of agency positions.  Based on the HCME findings the agency was tasked with explaining the differences between the Payment Disbursement Specialist, GS-1601-09 position, to which the appellants were assigned at the time of the HCME, and a 1997 OPM position classification appeal decision that changed and certified under 5 U.S.C. 5112 the classification of a similar BFS position to Peripheral Equipment Operator, GS-0350-04. It appeared there were no distinctions between the major duties performed in the GS-0350-04 position which OPM had previously certified and those assigned to the GS-1601-09 position reviewed during the ACE Philadelphia HCME.  Over the following months, MSAC, ACE Philadelphia held discussions with Treasury concerning whether the Payment Disbursement Specialist position was properly classified given the 1997 appeal decision.  This effort included an onsite audit by two ACE staff members of employees assigned to the Payment Disbursement Specialist position in the Kansas City Financial Center.  As a result of their fact-finding, ACE Philadelphia issued a final decision on September 18, 2017, classifying the position as Peripheral Equipment Operator, GS-0350-04.  Subsequently, through their representative the employees exercised their right under 5 U.S.C. 5112 to appeal the ACE Philadelphia classification decision to MSAC’s classification appeals office. 

General issues

The appellants make various statements about the classification review process performed by ACE Philadelphia’s office asserting it failed to fully consider the complexity of the work they perform.  In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of their position.  By law, we must make that decision solely by comparing their current duties and responsibilities to OPM position classification standards (PCS) and guidelines (5 U.S.C. 5106, 5107, and 5112).  Because our decision sets aside all previous decisions, the classification practices used by ACE Philadelphia in classifying their position are not germane to the classification appeal process. 

The appellants believe their current PD of record (number 17099P) is not completely accurate.  A PD is the official record of the major duties and responsibilities assigned to a position by an official with the authority to assign work.  A position is the duties and responsibilities that 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 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 appellants. 

Our review disclosed inaccuracies in the appellants’ PD.  For example, it states the position is personally responsible for ensuring payments are issued accurately and timely.  However, we find this responsibility lies with the branch supervisors and upper-level managers.  The PD states the position uses judgment and policies and guidelines to plan and carry out the position’s printing and mailing operations.  However, we find the branch supervisors plan and carry out the flow of work.  Contrary to the PD, we find the reports the position submits to the supervisors concerning any service or equipment issues do not affect software design nor do they improve operations, equipment, or promote cost effectiveness.  The term “analyze” is used in the PD to describe such tasks as the position examining equipment performance, workload, or billing charges from the U.S. Postal Service (USPS).  However, we find the supervisors analyze the workload and assess the validity of USPS billing charges.  Finally, we note that the appellants’ PD under Factor 8, Physical Demands, describes the employee lifting boxes weighing up to 65 pounds (assigning Level 8-2) but the agency has not specified how often this occurs.  Our fact-finding disclosed that like Level 8-2 the appellants only occasionally lift items weighing over 50 pounds.  Therefore, the appellants’ PD of record does not meet the standard of adequacy addressed on pages 11-12 of the Introduction, and the agency must revise it to reflect our findings.

Position information

The Kansas City Financial Center is responsible for processing and issuing all recurring Treasury payments (e.g., benefits, annuities, and salaries), and the Philadelphia Financial Center is responsible for processing and issuing corrections for all post payment errors, e.g., working with Social Security Administration (SSA) recipients when payments are not received or the payments are for inaccurate amounts.  Both centers process and issue public monies via paper check, e.g., research grants and the current stimulus payments on behalf of over 200 Federal customer agencies, including the Department of Veterans Affairs, Internal Revenue Service, and SSA.  They disburse approximately 60 percent of Federal agency payments annually totaling more than $3 trillion. 

Each month the appellants rotate through the payment operations sections of their centers’ Mail Operations Branch.  In the printing operations section, the appellants access the Payment Automated Manager (PAM) system applications to identify and prepare files (e.g., paper checks, U.S. savings bonds, and letters) for printing on IBM 4100 high speed printers.  The printers are inspected to ensure such items as the correct toner and program codes are being used to print the files.  To ensure the paper is properly aligned, the paper roles headers and trailers are input before the job is run.  During printing, the Videk two camera scanning system looks for imperfections.  After completion, the appellants perform various reconciliation functions.  They inspect any potentially faulty pieces flagged on the system’s Post Print Verification (PPV) listing.  The appellants reconcile print processing data fields on progress sheets (e.g., print sequence number, check number, and lot number) and verify production lot folder documents (e.g., payment control card and file history report).  The appellants also perform maintenance on the high-speed printers to include cleaning corona wires, checking oiler rollers, and replacing oiler roller pads weekly.

In the enclosing operations section, the appellants gather the appropriate supplies so the print job is properly folded and placed in the correct envelope with the right insert, if one is required.  They load the printed job in the proper sequence onto the KERN or EPIC enclosing machine, program it, and make machine parts adjustments depending on the job (e.g., size of paper and number of sheets to be inserted in an envelope).  Throughout the process, the appellants monitor the enclosing machine.  They also verify the address is visible in the envelope window.  Jobs with over 20,000 pieces are presorted at the end of the enclosing machine.  After each job is finished, they complete and sign the enclosing machine system checklist and job summary reports, documenting the job is balanced, i.e., each piece of the job is accounted for in the system, at the Balancing Desk  This is completed before another job is loaded onto the same enclosing machine to ensure no missing items are enclosed in the new job.

In the mail operations section, the appellants pre-sort and coordinate workflow so the jobs are sorted and prepared for pick up and mailing by the USPS.  For jobs with fewer than 20,000 pieces, the appellants print bar code tags and set up the Pitney Bowes presort mailing machine as the pre-sorter.  The presort machine sorts envelopes by zip code into the corresponding mail trays.  They scan the trays before transmitting the end of day presort mail report through the Postal One USPS system so the USPS is aware of how much mail will be picked up that day.  The mail report includes the number of pieces sorted into each tray, the number of trays and the presorted postal discount rate applied to the customer agency.  The appellants assist with sleeving, banding, and loading each day’s mail onto USPS mail trucks.  They also perform required machine maintenance such as cleaning or adjusting print heads.

While serving as the workflow coordinator, the appellants monitor the monthly payment calendars and coordinate with the pre-sorter to ensure all the mail required for that day’s mail date is sleeved, banded, and labeled.  They ensure mail trays are correctly marked, adequate mail transport equipment (e.g., carts and trays) and supplies are on hand, and schedule a USPS verifier in advance for mail pick up.  The appellants verify all the mail is collected and accounted for before the arrival of the USPS truck.  They access the Window Book post presort system to produce pallet placards showing the type of payment/ postal type, mail date, and home delivery date to ensure timely delivery of mail to its destination. 

In reaching our classification decision, we have carefully reviewed all information provided by the appellants’ representative and their agency including their 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 appellants’ designated spokespersons from each center and their immediate supervisors from each center.

Series, title, and standard determination

The agency classified the appellants’ position in the Equipment Operator Series, GS-0350, titling it Peripheral Equipment Operator, and the appellants agree.  We concur with the agency’s title and series determination.  Positions in the GS-0350 series are evaluated by reference to the grading criteria in the Equipment Operator position classification standard (PCS) which we have applied below.  The grading rationale provided by the appellants’ representative relies solely on the direct application of the Primary Standard (PS) to six factors.  The PS is the “standard-for-standards” which serves as the basic tool for maintaining alignment across occupations by ensuring grading criteria in PCSs for specific occupations are consistent.  As indicated in The Classifier’s Handbook and the Introduction, the PS may be used when a factor in an individual position fails to meet the lowest or significantly exceeds the highest factor level defined in a specific Factor Evaluation System (FES) occupational standard.  However, the PS must be applied in combination with or supplemented by published FES PCSs in order to assure that the work being evaluated is considered in an appropriate context.  The appellants’ rationale fails to do this and therefore will not be addressed further in this decision.  Moreover, as discussed below we find the appellants’ position does not exceed the highest factor levels described in the GS-0350 PCS. 

Grade determination

The GS-0350 PCS uses the FES, which employs nine factors.  Under the FES, each factor-level description in the PCS describes the minimum characteristics needed to receive credit for the described level.  Therefore, if a position fails to meet the criteria in a factor-level description in any significant aspect, it must be credited at a lower level, unless an equally important aspect that meets a higher level balances the deficiency.  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 GS-0350 PCS.

The appellants disagree with their agency’s assignment of Level 1-3 for Factor 1, Knowledge required by the position; Level 2-2 for Factor 2, Supervisory controls; Level 3-2 for Factor 3, Guidelines; Level 5-1 for Factor 5, Scope and effect; Level 7-1 for Factor 7, Purpose of contacts; and Level 8-2 for Factor 8, Physical demands.  We reviewed the agency’s determination for Factors 4, 6, and 9 for which the appellants agree, and we concur.  Therefore, we have confined our analysis to Factors 1, 2, 3, 5, 7, and 8.

Factor 1, Knowledge required by the position

This factor measures the nature and extent of information or facts that a worker must understand to do acceptable work and the extent of the skills needed to apply this knowledge.  To be used as a basis for selecting a level under this factor, knowledge must be required and applied.

At Level 1-3, which is the highest level for this factor described in the PCS, positions require a thorough knowledge of equipment set up, adjustment, operating procedures, and a corresponding level of skill to set up, operate, and adjust the equipment.  This level of skill and knowledge enables a highly skilled operator to set up, operate, and adjust the equipment, and in addition, diagnose, solve, and correct operating problems affecting the quality and timeliness of the service or product.  The operator may instruct lower graded operators how to complete the required corrective adjustment. Typically, corrective adjustments performed require the operator to consider the symptom(s), possible causes and remedies.

The appellants’ work meets but does not exceed Level 1-3.  Like Level 1-3, the appellants use a thorough knowledge of equipment set up, adjustment, and operating procedures to set up, operate, and adjust the equipment.  The appellants are highly skilled and operate various pieces of equipment to print, enclose, and sort such items as Federal paper checks, U.S. savings bonds, and letters.  They record and input standard information into manual and electronic progress sheets, checklists, and reports used in the different operations sections and track each job.  Like this level, the appellants adjust equipment settings, perform basic equipment maintenance, and use their knowledge and best practices to troubleshoot equipment.  They perform inspections and quality control reviews in the operations sections to ensure product quality and timeliness throughout the process.  They add, remove, and adjust parts on the various machines.  The appellants and the other operators share their learned knowledge concerning revised and new work processes to include the proper use, maintenance, and troubleshooting of equipment.  The record shows the majority of their work is recurring and new hires complete a structured training program that covers each sections’ processes which takes approximately one year to complete.

This factor is evaluated at Level 1-3 and 350 points are credited.

Factor 2, Supervisory controls

This factor covers the nature and extent of direct or indirect controls exercised by the supervisor, the employee’s responsibility, and the review of completed work.

At Level 2-2, which is the highest level for this factor described in the PCS, the supervisor provides continuing and individual assignments by indicating generally what is to be done and the quantity and quality required to complete the assignment.  The supervisor provides additional instructions for new or unusual equipment set ups, operations, or adjustments.  Equipment operating problems and unfamiliar situations not covered by instructions or guidelines are referred to the supervisor for assistance or a decision.  Since most machine operations are well established, the operator typically works independently and uses some judgment in correcting machine adjustments to improve or maintain quality of machine service, adjusting for variations in the work, etc.  The work is reviewed for quality and compliance with guidelines by spot checks or selective sampling.  In addition, the structure of the work provides a continuing form of review through successive machine operations and ultimately by the user of the service or product.

The appellants’ work meets but does not exceed Level 2-2.  Similar to this level, the appellants’ assignments depend on the payment operations section to which assigned.  They work independently carrying out all established and recurring work processes. They know the order of the steps that need to be taken to complete the job so it can move forward to the next section.  Like this level, the supervisors indicate the level of quality expected for each job, establish assignment priorities, provide instructions for new or unusual assignments, and determine or adjust the flow of work.  When operating problems or errors occur with a piece of equipment, the appellants use their knowledge of best practices to troubleshoot the issue.  If they cannot resolve it within a certain timeframe (e.g., approximately 15 minutes), they inform their lead or supervisor who provides guidance as needed.  The appellants also work with the onsite KERN technician or place a service call for equipment repairs.  The supervisors review the work for quality and compliance with established procedures (e.g., review printing and enclosing section reconciliations and check samples from the enclosing machine to ensure envelopes include the customer agency’s inserts).

This factor is evaluated at Level 2-2 and 125 points are credited.

Factor 3, Guidelines

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

At Level 3-2, which is the highest level for this factor described in the PCS, specific guidelines for doing the work have been established and are available to the employee for reference purposes.  The written guides are typically of the same nature as the guidelines noted at Level 3-1; however, the number of guidelines at this level is greater and covers a wider variety of similar situations and tasks in greater detail.  The employee must use judgment in selecting among and applying the appropriate methods to correct operating problems which affect the quality and/or timeliness of the product or service.  Significant deviations or situations to which the guidelines do not apply are generally referred to the supervisor.

The appellants’ work meets but does not exceed Level 3-2.  Like this level, the appellants use a variety of established and specific guidelines and procedures such as equipment operating manuals, BFS and financial center policies and procedures, and standard operating procedures (SOPs).  The guidelines are available to the appellants for reference and they use judgment to identify and select the most appropriate procedures to use.  When operating problems or errors occur with a piece of equipment, the appellants use their knowledge, training, and established best practices to troubleshoot it.  Because the appellants work within established parameters, significant deviations or situations to which the guidelines do not apply are generally referred to the supervisor.

This factor is evaluated at Level 3-2 and 125 points are assigned.

Factor 5, Scope and effect

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

At Level 5-1, which is the highest level for this factor described in the PCS, the purpose of the work is to provide equipment services and/or products to users on a timely basis.  Performance affects the quality and timeliness of the service; however, the work does not affect the accuracy or reliability of the subject matter.

The appellants’ work meets but does not exceed Level 5-1.  Like this level, the purpose of the appellants’ work is to print, enclose, and prepare for mailing by the USPS work products such as paper checks, U.S. savings bonds, and letters to recipients.  These functions are completed in accordance with established work priorities and customer agencies’ set schedules.  Like this level, the appellants’ work facilitates the work of their customer agencies by producing work products in a timely and accurate manner.  However, their work does not affect the accuracy or reliability of the subject matter of the work products.  That responsibility lies with customer agency personnel.

This factor is evaluated at Level 5-1 and 25 points are assigned.

Factor 7, Purpose of Contacts

The purpose of personal contacts ranges from factual exchanges of information to situations involving significant or controversial issues and differing viewpoints, goals, or objectives. The personal contacts which serve as the basis for the level selected for this factor must be the same as the contacts which are the basis for the level for Factor 6.

At Level 7-1, which is the highest level for this factor described in the PCS, personal contacts are for the purpose of exchanging, clarifying, or obtaining factual information relating to the work to be performed and the setup, operation, adjustment, etc., of the equipment operated in the position.

The appellants’ work meets but does not exceed Level 7-1.  Like this level, the appellants’ contacts are for the purpose of exchanging or obtaining information relating to their work assignments and the setup, operation, and adjustment of the equipment operated.  For example, the appellants discuss equipment errors with onsite KERN technicians and when placing service calls for the other machines.

This factor is evaluated at Level 7-1 and 20 points are assigned.

Factor 8, Physical demands

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

At Level 8-2, the work requires some physical exertion such as extended periods of standing, frequent bending, reaching, stooping, or similar activities necessary to set up, operate, adjust, and monitor the operation of the equipment.  The employee lifts, on a recurring basis, a variety of moderately heavy materials and supplies such as boxes of chemicals, record boxes, boxes of cards and envelopes, cartons of film; occasionally the employee may be required to lift heavy (over 50 pounds) items such as mail bags or large stacks of paper stock.

At Level 8-3, in addition to the physical demands described at level 8-2, the work requires frequent lifting of heavy objects over 23 kilograms (50 pounds) such as large boxes of paper, cartons of cards or mail bags.

Level 8-2 is met.  Like this level, the appellants’ work requires some physical exertion such as extended periods of standing, frequent bending, reaching, and stooping in order to setup, operate, adjust, and monitor the operation of the equipment.  Comparable to Level 8-2, the appellants lift a variety of moderately heavy materials and supplies.  For example, after stooping and lifting a chuck (i.e., a spool-shaped piece of steel weighing up to 30 pounds used to control the rotation of a check or letter roll after being loaded on the KERN enclosing machine), they maneuver it into the empty cylinder in the middle of the roll.  While the appellants may occasionally lift items weighing over 50 pounds, such demands infrequently occur. 

Level 8-3 is not met.  Unlike this level, the appellants’ work does not require on a frequent basis lifting heavy objects over 50 pounds such as large boxes of paper or mail bags.  For moving heavier objects such as rolls of paper, they regularly use wheeled roller carts which requires only moderate physical exertion. 

This factor is evaluated at Leve 8-2 and 20 points are assigned.

Summary

Factors	Level	Points
1. Knowledge required by the position	1-3	350
2. Supervisory controls	2-2	125
3. Guidelines	3-2	125
4. Complexity	4-2	75
5. Scope and effect	5-1	25
6. Personal contacts	6-2	25
7. Purpose of contacts	7-1	20
8. Physical demands	8-2	20
9. Work environment	9-2	20
Total		785

The total of 785 points falls within the GS-04 point-range (655-850) on the grade conversion table in the GS-0350 PCS.  Therefore, the appellants’ position is properly graded at the GS-04 level.

Decision

The appellants’ position is properly classified as Peripheral Equipment Operator, GS-0350-04.

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