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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

Carla Y. Hubbard et al.
Grants Resources Specialist
GS-0301-11
Headquarters Grants Administration Office
Management Operations Directorate
Goddard Space Flight Center
National Aeronautics and Space Administration
Greenbelt, Maryland
GS-503-06
(Title at agency discretion)
C-503-06-01

Robert D. Hendler
Classification and Pay Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance

05/18/2016


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 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 OPM office which accepted the appeal.
 
Introduction

The U.S. Office of Personnel Management’s (OPM) Merit System Accountability and Compliance accepted a position classification appeal from the appellants on September 17, 2014.  The appellants occupy the position of Grants Resources Specialist, GS-301-11, in the Headquarters Grants Administration Office (HGAO), Management Operations Directorate, at Goddard Space Flight Center (GSFC), National Aeronautics and Space Administration (NASA), in Greenbelt, Maryland.  They request reclassification of their position as GS-301-13.  We received the agency administrative report on November 12, 2014.  We accepted and decided the appeal under the provisions of section 5112 of title 5, United States Code.

Background

The HGAO was established at GSFC by NASA headquarters in 1997.  One of the appellants was reassigned to the organization in 2001 into the position of Grants Resources Specialist, GS-301-7.  At that time, the full performance level of the position was GS-9, to which grade she was subsequently promoted.  Sometime in 2004, after no apparent change in the appellant’s duties, the full performance level of the position was raised to GS-11, and the appellant was again promoted.  The remaining two appellants were reassigned to the organization in 2007 and 2013 as GS-301-7 and GS-301-9 Grants Resources Specialists, respectively, and by 2013 all three appellants had been promoted to the GS-11 level, again without any apparent change in duties.   

Early in 2014 the appellants’ supervisor requested a reassessment of the position to support another promotion.  On April 17, 2014, an audit of the position was conducted by NASA’s GSFC Office of Human Capital Management (OHCM).  OCHM determined that the position was properly classified as Grants Management Specialist, GS-1109-12, but that the reclassified position had to be filled competitively.  A vacancy announcement was posted but before its closing date, was cancelled by the appellants’ supervisor because she believed the position should have been classified at the GS-13 level.  The appellants shared her belief that the position is properly classified as GS-301-13, and appealed its classification to OPM.  Throughout this sequence of events, the appellants and their supervisor confirmed that the duties of the position had not changed, but that the electronic PD system had limited their ability to accurately represent the actual duties performed.  

General issues

The appellants disagree with their agency’s classification review process.  They assert that the agency did not consider substantive information provided in their work samples.  In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of the position.  Because our decision sets aside all previous agency decisions, the agency’s classification review process is not germane to this decision.  

Further, the appellants submitted an “existing/certified GS-13 PD” (#71678) in an apparent attempt to compare their position to a higher-graded position.  By law, we must classify positions solely by comparing their current duties and responsibilities to OPM position classification standards (PCS) and guidelines (5 U.S.C. 5106, 5107, and 5112).  Since comparison to PCSs is the exclusive method for classifying positions, we cannot compare the appellants’ position to others as a basis for deciding their appeal. 

Position information

NASA headquarters awards two-year research and development grants for about 60 projects totaling approximately $600 million in appropriated funds and an additional $1.5 million in reimbursable funds from other Federal agencies, representing about 80 percent of all NASA grant awards.  The funds are awarded to universities and other qualifying scientific organizations throughout the United States via over 2,500 grant actions per year (i.e., new awards, multi-year funding continuations, augmentations, etc.).  The HGAO serves as an intermediary between the NASA headquarters science and engineering program offices which develop and submit grant actions (also called technical requirements proposal or TRP) and the NASA Shared Services Center (NSSC) which awards and administers the grants.   

NSSC performs all pre-award and post-award actions for both competitive and noncompetitive grants; awards funding and administrative supplements; processes Principal Investigator (PI) transfers; processes cancellations; approves foreign travel, equipment purchases, and re-budgeting requests; and monitors zero costing and suspicious drawdowns.  The HGAO role is to review TRPs and other requested grant actions submitted by the Technical Officers (TOs) at NASA headquarters and requiring movement of funds (such as augmentations, de-obligations, or PI transfers) for completeness of documentation prior to their submission to NSSC in order that the actions may be processed without undue delays, and generating the associated procurement requests (PRs) which are the vehicles for requesting any grants action by NSSC.  The HGAO also provides continuous coordination of grant funding between NASA headquarters and GSFC by ensuring that any proposed funding has been transferred from the RAPTOR grant resource tracking system to the SAP core financial system by the TOs before grants action is taken, and provides continuous status information to the program offices on the expenditure and availability of grant funds.

The appellants carry out the daily processing of grant transactions in the HGAO.  They are responsible for reviewing the TRPs for their assigned grant projects to ensure that the grant documentation is sufficient and appropriate for the requested action and the existing grant status (e.g., multi-year funding, augmentation, etc.) and to ensure regulatory compliance with the NASA Grant and Cooperative Agreement Handbook, Federal Acquisition Regulations (FAR), and the NASA FAR Supplement; ensuring that budget elements are appropriate relative to "allowable costs"; flagging potential problem areas in the TRPs and obtaining missing or corrected information from NASA personnel and/or the grantee institutions; and preparing PRs in SAP to forward the TRPs to NSSC for action.  The purpose of these activities is to ensure that the TRPs are complete, contain accurate cost information, and meet regulatory requirements so that the subsequent procurement process carried out at NSSC flows smoothly and TRPs are not returned to the program offices by NSSC because of insufficient documentation or other problems.  The appellants also monitor the status of funds for their assigned blocks of grant projects through the use of RAPTOR, SAP, and other financial and business systems by reviewing financial reports and resolving discrepancies with NASA personnel; ensure that expenditures are consistent with funding information in RAPTOR; perform reconciliation of funding for their assigned grant projects at the task level; and conduct year-end closing activities. The purpose of these activities is to ensure that the program offices have access to accurate and up-to-date records on grant expenditures and available funds. 

The appellants do not dispute the accuracy of their PD (#1012580) except to assert that the “language in the factors does not adequately capture the scope of the competencies that are required to perform the duties of [their] position,” and their supervisor certified its accuracy.  The appellants state the PD was developed “using the new system (ePDS),” which contains standardized language that can be modified to fit a particular position.  Although the PD appears to contain the basic elements of the position, these are subsumed within the extensive standardized verbiage that materially misrepresents both the nature of the work they perform and the level of authority they are delegated.  For example, they do not "collaborate with contracting officers on controversial contracting positions" or "provide staff compliance review of a wide range of contracting actions" (the HGAO has no involvement with NASA contracting as opposed to grant actions); "provide technical advice and guidance on new or revised procurement policies" or "develop written policies" (this is not within HGAO mission parameters); "conduct studies of problem areas and develop standard methods and operating procedures for implementation at subordinate levels" (there are no organizational levels subordinate to the HGAO); "schedule and conduct compliance reviews of grantees" or "implement government policy designed to assure uniform application throughout the assigned area with respect to subcontracting programs" (these are not within HGAO mission parameters); "after budget has been approved, direct execution" (this is not within HGAO mission parameters and the appellants do not have supervisory or managerial authority); "determine the responsibility of the grantee or offeror based on an evaluation of financial and technical information gained during the pre-award survey" or "conduct negotiation sessions and award or recommend award of the grant" (these functions are performed by NSSC); or "support higher-graded Development Assistance Specialists in backstopping sectoral programs" or "review sectoral strategies to appraise and report on progress toward the achievement of goals and the adequacy of institutional arrangements" (this has no apparent relationship to the appellants' work).  These are merely examples of duties described in the appellants' PD which are not actually performed, the full list of which would be too extensive to address here.  Further, the factor-level descriptions consist of general language associated with the assigned factor levels, but do not have an identifiable relationship to the work they actually perform and appear to have been selected solely to support the desired factor level assignments.   

An employee's PD is expected to meet certain minimum standards of adequacy and accuracy in depicting the duties being performed in that it serves as the basis for determining the employee's pay and other associated benefits based on that pay.  The appellants’ PD does not meet these minimum standards of adequacy and accuracy and should be revised to describe the actual work they are performing, to more realistically depict the factor level characteristics associated with their work, and to provide an accurate documentation and clear understanding of the duties and responsibilities representing the approved classification.  See section III.E of the Introduction. Briefly, the following incongruities are noted between the factor-level descriptions in the appellants’ PD and the actual work performed:

  • Factor 1 - The appellants’ position does not require the types of grants administration knowledges described because, as discussed later in this decision, the HGAO does not perform grants administration functions associated with such knowledge requirements, which reside at NSSC, but rather a grants support function.  The HGAO reviews the documentation being submitted to NSSC to initiate the award of a proposed grant or the modification of an existing grant, and only for the limited purposes of ensuring complete documentation and screening for any issues that may delay processing by NSSC.  Nothing in the record suggests that the appellants use “qualitative and quantitative techniques to identify, evaluate, and recommend management actions for resolving complex interrelated problems and issues," nor do they "independently plan and conduct evaluations of agency, contractor, and provider operational programs and their related accounting systems.”   
  • Factor 2 - The appellants’ position does not allow for the nature and extent of responsibility as described.  For example, they do not interpret policy on their own initiative.  Instead, the appellants carry out well-defined and continuing assignments within an established program support function.  Policy interpretation would not be applicable to either the appellants’ position or to the type of support functions carried out by the HGAO.  Since the work is well-defined in terms of its execution, it does not require the appellants to determine approach or methodology.  Further, rather than their work being reviewed only from an overall standpoint for feasibility and effectiveness, TRPs are technically reviewed by a higher-graded employee before their submission to the supervisor and forwarding to NSSC.  We note that the language used under this factor is identical to Level 2-4 in the Primary Standard found in Appendix 3 of the Introduction  and this level is generally only applicable to two-grade interval positions. 
  • Factor 3 – Nothing in the record suggests that the appellants’ position requires them to “use judgment in interpreting and adapting guidelines, such as agency policies, regulations, precedents, and work directions for application to specific cases or problems.”  Instead, they apply recurring provisions and established interpretations of agency program guides, and situations that are unclear are referred to higher-graded staff. 
  • Factor 4 - The appellants’ position does not have the level of difficulty in identifying what needs to be done as described.  Nothing in the record suggests that “decisions regarding what needs to be done include the assessment of unusual circumstances, variations in approach, and incomplete or conflicting data.”  As explained later, most of the appellants’ duties are performed using a practical knowledge of the purpose, procedures, techniques, and guidelines of their specific program area.  We note that the language used under this factor is identical to Level 4-4 found in the Primary Standard and this level is generally only applicable to two-grade interval positions. 
  • Factor 6 – Nothing in the record suggests that the appellants maintain personal contacts with the news media or public action groups, or have regular and recurring contacts with attorneys, contractors, or representatives of professional organizations.
  • Factor 7 – The purpose of the appellants’ contacts is not to “influence or motivate individuals or groups” but rather to provide a support function to facilitate the processing of grant transactions. 

In adjudicating a classification appeal, we determine the proper classification of the appellant’s position, i.e., the duties assigned by management and performed by the appellant, not the appellant’s PD.  Although it is expected that the duties assigned and performed will be accurately depicted in the appellant’s PD, we do not classify the position by relying on language in the PD which is not representative of the actual work performed.  To help decide this appeal, we conducted a telephone audit with the appellants on April 6, 2015, and with their supervisor, Ms. LaTanya Gilliam, on June 19, 2015.  This decision is based on our assessment of the appellants’ duties and responsibilities as determined through our fact-finding, including the telephone audit and interview with the supervisor, review of work samples furnished by the appellants, and other material received in the agency administrative report. 

Series determination

The agency had classified the appellants’ position to the Miscellaneous Administration and Program Series, GS-301.  This series includes positions the duties of which are to perform, supervise, or manage nonprofessional, two-grade interval work for which no other series is appropriate, and which requires analytical ability, judgment, discretion, and knowledge of a substantial body of administrative or program principles, concepts, policies, and objectives.  The GS-301 flysheet instructs that if the basic subject matter knowledges and skills for a position are covered by other specific series, then the position should be assigned to that series rather than the GS-301 series.  It also instructs that mixed positions, i.e., positions that involve work classifiable in more than one series, should be classified to the series that represents the paramount qualifications required.  In the appellants’ case, their work is directly associated with two one-grade interval occupational series as discussed further below, and as such the GS-301 series is not appropriate.

The agency-proposed allocation of the appellants' position to the GS-1109 Grants Management Series is also incorrect.  The GS-1109 series covers positions which manage, supervise, lead, or perform administrative, business, policy, and analytical work involving: (1) the management, award, and/or obligation of funds for grants, cooperative agreements, and other related instruments and services such as discretionary and mandatory grants, using financial, administrative, business, and negotiation procedures; (2) the competitive or non-competitive evaluation of grant proposals; and/or (3) the administration or termination, and/or closeout of grants and/or grants assistance and agreement awards.  To expand upon this series definition, the GS-1109 series flysheet provides a list of typical duties that include a range of functions related to awarding and administering grants.  Duties associated with awarding grants include such functions as announcing grant opportunities and soliciting applications or proposals; determining awardee eligibility; reviewing and evaluating grant applications, plans, and estimates; and negotiating terms and conditions of grant awards including costs, schedules, and oversight responsibilities.  Duties associated with administering grants include such functions as processing, issuing, and tracking grant awards; establishing performance measures; monitoring and assessing awardee performance and compliance with the terms and conditions of the award; conducting risk assessments and business reviews; serving as liaison between the Government and the awardee organizations; and performing final review of completed awards, making appropriate adjustments or disallowances, and processing close-outs.  Work in the GS-1109 series requires knowledge of:

  • laws, regulations, rules, policies, procedures, and methods governing the administration of Federal grants, cooperative agreements, and awards;
  • grants management processes and techniques consistent with sound business and industry practices; and
  • financial methods, procedures, and practices to assess the financial stability of recipients of Federal grants.

Responsibility for the grants management functions described above resides at NSSC.  The appellants' role as it relates to the awarding of grants is limited to reviewing TRPs for completeness of documentation and resolution of identified problems prior to their submission to NSSC in order that the above actions may be taken without undue delays.  Their role as it relates to grant funding is limited to such functions as monitoring fund status and resolving discrepancies in financial records as opposed to awarding and obligating funds, as the HGAO does not have this authority.  The work requires primarily knowledge of the documentation needed for a complete grant package that can be processed by NSSC and some limited knowledge of regulatory requirements pertaining to the awarding of grants sufficient to flag potential problems.  However, these knowledge requirements do not approach those associated with the GS-1109 series.      

Guidance on determining whether work is one- or two-grade interval in nature is contained in The Classifier’s Handbook (Handbook).  Support work involves proficiency in one or more functional areas or in certain limited phases of a specified program.  Normally, a support position can be identified with the mission of a particular organization or program.  Employees who perform support work follow established methods and procedures.  They may occasionally develop work plans or recommend new procedures, but these typically are related to the employee’s individual assignment or immediate work unit.  Support work can be performed based on a practical knowledge of the purpose, operation, procedures, techniques, and guidelines of the specific program area or functional assignment.  Support personnel typically learn to do the work on the job through what may be many years of experience.  Administrative work, on the other hand, requires primarily a high order of analytical ability combined with a comprehensive knowledge of (1) the functions, processes, theories, and principles of management; and (2) the methods used to gather, analyze, and evaluate information.  Administrative work also requires skill in applying problem solving techniques and skill in communicating effectively orally and in writing.  Administrative work often involves planning for and developing systems, functions, and services; formulating, developing, recommending, and establishing policies, operating methods, or procedures; and adapting established policy to the unique requirements of a particular program.

Within this context, the appellants’ duties represent one-grade interval support work rather than two-grade interval administrative work.  Their work requires proficiency in and is specifically identified with certain limited phases of the NASA grants administration function and is transactional in nature; i.e., it is not based on a body of broad functional knowledge associated with an administrative field, such as the grants management functions covered by the GS-1109 series, but rather focuses on the review and processing of documents so that the substantive functions associated with the awarding and administration of grants can be carried out by others.  Although the appellants may provide input to procedural changes in the NASA Grant Handbook and NRA Proposers Guidebook as these specifically relate to the work of the HGAO, they otherwise follow established methods and procedures; i.e., their work is clearly defined in terms of the processes to be carried out.  They perform their work based on a practical knowledge of NASA grant documentation requirements and readily identifiable disallowed conditions as acquired through extensive on-the-job exposure.  They do not, however, perform work requiring a high order of analytical ability and a comprehensive knowledge of management processes and functions.  For example, the appellants provide information requested by program officials relative to the status and funding of specific grants by researching the grant history in various electronic financial and business systems or by drawing on their own recollection of actions that transpired.  However, obtaining information by pulling data or reports from an automated system does not involve the exercise of a "high order of analytical ability," and reporting a sequence of events does not require "comprehensive knowledge of management processes."  As another example, the appellants identify issues in TRPs that are potentially disallowable.  However, the work samples submitted show that any problems extending beyond missing documentation, conflicting information, or recurring issues and which would potentially require a “high order of analytical ability” are referred to higher-graded staff and/or the TOs, NASA legal counsel, or the procurement office.   

The appellants describe their work involving the review of TRPs prior to their submission to NSSC as "procurement" duties.  However, this is an inaccurate characterization.  The appellants do not carry out the "procurement" process as it relates to the solicitation and awarding of grants, which work is carried out at NSSC.  Rather, their work supports the grant management functions carried out at NSSC by ensuring the submission of complete and supportable documentation for processing; i.e., they prepare and/or review procurement requests for the actual procurement to be carried out by others.  As such, their work is most closely associated with the GS-1106 Procurement Clerical and Assistance Series, which includes positions that involve performing or supervising clerical or technical work that supports the procurement of supplies, services, and/or construction and includes such work as preparing, controlling, and reviewing procurement documents such as purchase requests, amendments, waivers, and other preaward documents, and researching errors or conflicting information in procurement documentation.  This accurately depicts the appellants’ position in that they review “procurement documents” (i.e., TRPs, analogous to purchase requests, amendments, and other “preaward documents”) to identify “errors or conflicting information in procurement documentation.”

The appellants' work involving monitoring the status of funds and reconciling funding discrepancies is likewise one-grade interval in nature and is most closely associated with the GS-503 Financial Clerical and Technician Series, which includes positions that involve performing or supervising clerical or technical work in support of financial management functions and specifically covers such work as processing the transactions of an organization and reconciling accounts. 

There is no basis for classifying the position to one of the two-grade interval series in the GS-500 Accounting and Budget Occupational Group, such as the GS-501 Financial Administration and Program Series.  Positions in this series perform work of a fiscal, financial management, accounting, or budgetary nature that is not classifiable to another more specific professional or administrative series in the GS-500 group (such as GS-510 Accounting, GS-511 Auditing, or GS-560 Budget Analysis).  Examples of GS-501 positions provided in the corresponding Job Family Standard (JFS) include such work as developing new or revised automated financial management systems, or conducting financial oversight by monitoring financial transactions to ensure the cost effective use of funds (e.g., by identifying potential reimbursable costs or early payment discounts).   By contrast, the appellants' work does not involve two-grade interval financial oversight in the sense of, for example, identifying ways that cost savings could be achieved, but rather the more mechanical function of searching through financial records to identify unobligated funds or the source of funding discrepancies, which work is directly described within the context of the GS-503 series.

The appellants reported that the above-described financial support duties occupy most of their time and thus represent the paramount qualifications of the position, and therefore the position is properly classified to the GS-503 series.

Title determination

Titles are not specified for positions classified to the GS-503 series except that positions GS-5 and above should have a Technician title.  Therefore, the agency may construct a title for the appellant's position following guidance provided in the Introduction.

Grade determination

Evaluation using the GS-500 Job Family Standard (JFS) for Clerical and Technical Accounting and Budget Work

The appellants’ financial support work is evaluated using the GS-500 JFS for Clerical and Technical Accounting and Budget Work.  The GS-500 JFS 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 following nine factors, with the total then being converted to a grade level by use of the grade conversion table provided in the JFS.  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 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.

When an individual FES factor falls either below the lowest or above the highest factor level described in the applicable FES standard, the Primary Standard may be referenced to evaluate that factor.  The Primary Standard serves as the basis for all occupational FES standards and is used to maintain alignment across occupations.

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 1-4, work requires in-depth or broad knowledge of a body of accounting, budget, or other financial management regulations, practices, procedures, and policies related to the specific financial management functions.  At this level, work typically includes:  

Knowledge of a wide variety of interrelated steps, conditions, and procedures or processes required to assemble, review, and maintain complex accounting, budget, or other fiscal transactions (e.g., adjusting tax accounts or processing tax returns involving numerous supporting schedules; reconciling accounts in accounting systems involving extensive subdivision of accounts, frequent and varied adjustments to accounts, or extensive balancing and reconciling of detailed summary accounts; or resolving problems in balancing accounts, adjusting discrepancies, developing control records, verifying the accuracy of budgetary data, adjusting dollar amounts of accounts by line item and object class, and preparing reports on the status of funds);

Knowledge of various accounting, budget, or other financial regulations, laws, and requirements (e.g., related fiscal regulations and applicable schedules, pay and leave rules, administrative rules associated with recording and tracking budgetary transactions, tax laws, entitlement rules, documentation requirements, schedules, deductions, etc.) to ensure compliance and recommend action;

Knowledge of a variety of accounting and budget functional areas and their relationships to other functions to research or investigate problems or errors that require reconciling and reconstructing incomplete information, conducting extensive and exhaustive searches for required information, or performing actions of similar complexity;

Knowledge of automated accounting and budget systems to reconcile errors that require an understanding of nonstandard procedures or to provide assistance in the development of automated procedures for clerical operations; and/or

Knowledge of extensive and diverse accounting, budget or other financial regulations, operations, and procedures governing a wide variety of types of related transactions to resolve nonstandard transactions, complaints, or discrepancies, provide advice, or perform other work that requires authoritative procedural knowledge.

Level 1-4 is met.  As at that level, the appellants’ financial support work, as it relates to supporting the grants administration process, requires a thorough knowledge of the agency’s financial systems.  They use the various systems to research variances in grant funding at the task level and resolve problems of processed transactions (e.g., funding was erroneously applied to a contract rather than the intended grant).  This work requires knowledge of different interrelated systems in order to reconcile errors and to reconstruct different information.    

Factor-level illustrations are provided in the GS-500 JFS to give insight into the meaning of the factor-level descriptions.  The following illustration of Level 1-4 knowledge requirements is provided in the PCS:

Employees maintain control accounts and subsidiary accounts and process accounting transactions for a wide variety of functions including obligations, accrued expenditures, disbursements, appropriation refunds, reimbursable orders, earnings, collections, expenditure vouchers, cost transfers, rejected transactions, interfund bills, and other accounts in connection with the general ledger. They receive and review purchase orders, contracts, and travel orders pertaining to claims and other similar documents against obligated funds. They certify and audit all payments to assure compliance with terms.

Similar to the Level 1-4 illustration, the appellants maintain control over their individual accounts at the task level and process transactions for a variety of actions including obligations, de-obligations, and augmentations.  The appellants also, in the same way the illustration describes, receive and review “purchase orders” (i.e., TRPs) against obligated funds.       

At Level 1-5 (the highest level described under this factor), the work requires a broad, in-depth practical knowledge of accounting or other financial management technical methods, techniques, precedent cases, and procedures to resolve especially difficult or sensitive problems.  At this level, employees typically use:

Knowledge of the accounting methods, procedures, and techniques to conduct difficult and responsible analysis and determinations within a complete accounting system to validate transactions and to perform research to resolve inconsistencies;

Knowledge of the interrelationships of various accounting system applications and computer file systems and content to resolve problems of processed transactions.  These modifications relate to obligations, collections, disbursements, and interfund transactions or other actions involving complicated adjustments such as carry back and carry forward and restricted interest cases; and/or

Knowledge of related financial regulations and rulings covering diverse types of transactions to typically function as a technical authority for the resolution of an extensive range of issues or problems.

The position does not fully meet Level 1-5.  The appellants are not each individually responsible for performing “difficult and responsible analysis” within the context of a “complete accounting system” but rather perform more limited tasks for assigned program areas, nor do they independently resolve “complicated adjustments”  comparable to those described at this level.  Further, they do not function as “technical authorities” in the resolution of an extensive range of issues or problems in that our fact finding revealed that within the organization, a higher-graded employee serves as the “technical authority” for the resolution of the more complex transactional funding discrepancies.           

Level 1-4 is credited (550 points).

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.

The supervision under which the appellants operate is consistent with Level 2-3 (the highest level described under this factor).  At this level, the supervisor assigns work with standing instructions on objectives, priorities, and deadlines and provides guidance for unusually involved situations.  The employee independently processes procedural and technical tasks or actions and handles problems and deviations in accordance with instructions, policies, previous training, or accepted practices.  The supervisor evaluates completed work for overall technical soundness and conformance to agency policies, legal, or system requirements.  Completed work is reviewed by sampling in a quality review system and/or spot checked for results and conformity to established requirements and deadlines.  The methods used to complete the assignment are seldom reviewed in detail.

The appellants' position fully meets this level in terms of the extent of controls exercised by the supervisor and the employee's responsibility, in that the appellants work within the parameters of established procedures and independently resolve routine funding and reconciliation problems. 

At Level 2-4 in the Primary Standard, the supervisor sets the overall objectives and resources available.  The employee and supervisor, in consultation, develop the deadlines, projects, and work to be done.  The employee, having developed expertise in the line of work, is responsible for planning and carrying out the assignment, resolving most of the conflicts that arise, coordinating the work with others as necessary, and interpreting policy on own initiative in terms of established objectives.  In some assignments, the employee also determines the approach to be taken and the methodology to be used.  The employee keeps the supervisor informed of progress and potentially controversial matters.  Completed work is reviewed only from an overall standpoint in terms of feasibility, compatibility with other work, or effectiveness in meeting requirements or expected results.

The supervisory controls and review described at Level 2-4 are based on the performance of more difficult and extended assignments and projects that require such elements as planning, determining approach and methodology, and independently interpreting policy.  The employee must keep the supervisor informed of progress and potential controversies because the assignments are longer-term and involve making decisions or taking actions that may have repercussions.  The type of review exercised at this level is that normally associated with work which is analytical or otherwise two-grade interval in nature.  By contrast, the appellants' work is routinized and involves carrying out established processes to, for example, monitor the status of funds and identify the source of funding discrepancies.  Their work assignments are short-term and do not involve any significant degree of planning, determining approach or methodology, or interpreting policy, nor would they be expected to generate controversies.  Therefore, their work does not lend itself to the type of supervisory controls and review described at Level 2-4.

Level 2-3 is credited (275 points).

Factor 3, Guidelines

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

At Level 3-2, a number of established procedures and specific guidelines in the form of agency policies and procedures, Federal codes and manuals, specific related regulations, precedent actions, and processing manuals are readily available for doing the work and are clearly applicable to most transactions.  The number and similarity of guidelines and work situations require the employee to use judgment to identify and select the most appropriate procedures to use, choose from among several established alternatives, or decide which precedent action to follow as a model. There may be omissions in guidelines, and the employee is expected to use some judgment and initiative to handle aspects of the work not completely covered. In locating, selecting, and applying the most appropriate instructions, references, or procedures, the employee may make minor deviations in guidelines to adapt to specific cases. The employee refers situations in which the existing guidelines cannot be applied or significant deviations must be made to the supervisor or designated employee.

Level 3-2 is met.  As at this level, Federal regulations, agency policies, handbooks, and other guidelines are available to the appellants.  However, based on their experience, acquired knowledge of the function, and the routinized nature of the work, the appellants do not often have to actually refer to the guidelines when making decisions.  They use judgment and past experience to select from among available alternatives.  When guidelines do not apply, they refer the matter to higher-level employees. 

At Level 3-3, guidelines are the same as Level 3-2 but because of the complicating nature of the assignments, they lack the specificity, frequently change, or are not completely applicable to the work requirements, circumstances, or problems. For example, when completing a transaction, the employee may have to rely on experienced judgment, rather than guides, to fill in gaps, identify sources of information, and make working assumptions about what transpired.  The employee uses judgment to interpret guidelines, adapt procedures, decide approaches, and resolve specific problems. This includes, for example, using judgment to reconstruct incomplete files, devise more efficient methods for procedural processing, gather and organize information for inquiries, or resolve problems referred by others (e.g., those that could not be resolved at lower levels).  The employee analyzes the results of applying guidelines and recommends changes.  These changes may include suggesting specific changes to the guidelines themselves, the development of control mechanisms, additional training for employees, or specific guidance related to the procedural handling of documents and information.

Level 3-3 is not met.  There is no evidence that the appellants’ guidelines lack specificity or frequently change.  Although the appellants are required to use some judgment when selecting guidelines and courses of action from established procedures, they are not routinely required to interpret or adapt policies and regulations.  The instructions and guidelines available generally apply to most situations.

Level 3-2 is credited (125 points).

Factor 4, Complexity

This factor covers the nature, number, variety, and intricacy of the 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 4-3, work involves performing various accounting, budget, or financial management support related duties or assignments that use different and unrelated processes, procedures, or methods.  The use of different procedures may result because transactions are not completely standardized; deadlines are continually changing; functions assigned are relatively broad and varied; or transactions are interrelated with other systems and require extensive coordination with other personnel.  The employee decides what needs to be done by identifying the nature of the problem, question, or issue, and determining the need for and obtaining additional information through oral or written contacts or by reviewing regulations and manuals.  The employee may have to consider previous actions and understand how these actions differ from or are similar to the issue at hand before deciding on an approach.  The employee makes recommendations or takes actions (e.g., determine eligibility for deductions, entitlements, or claims, verify factual data, or make other financial determinations) based on a case-by-case review of the pertinent regulations, documents, or issues involved in each assignment or situation.  For example, employees use different established procedures to review and reconcile various financial documents and records; resolve a variety of problems through coordination with vendors, employees, taxpayers; and review and reconcile various types of transactions involving multiple funds or a number of different control accounts, or numerous modifications to contracts.

Level 4-3 is met.  As at this level, the appellants’ work involves performing various financial  support related assignments that use different and unrelated processes such as comparing funding authorizations in RAPTOR, creating purchase requisitions in SAP, and utilizing other business systems like NSPIRE (NASA Solicitation and Proposal Integrated Review and Evaluation System) and MINX (Xerox document sharing database).   The appellants must identify the nature of the transaction, obtain additional information as needed, review and reconcile various financial records, and resolve funding problems by coordination with program staff.

At Level 4-4, the work is characterized by (1) the variety and complexity of the examinations, transactions, or systems involved; (2) the nature and variety of the problems encountered and resolved; and (3) the nature of independent decisions made by the employee.  The work involves application of many different and unrelated processes and methods relating to examination or analysis of complex and unusual transactions requiring substantial research and thorough understanding of a wide variety of transactions and accounts.  Decisions regarding what needs to be done include assessing unusual circumstances or conditions, developing variations in approach to fit specific problems, or dealing with incomplete, unreliable, or conflicting data.  The work requires making decisions, devising solutions, and taking actions based on program knowledge.

Level 4-4 is not met.  The elements described at this level are not present in the appellants’ position, which is primarily concerned with providing financial support related assignments and tasks described at Level 4-3 in the JFS.  The appellants’ position does not involve examining or analyzing unusually complex transactions requiring substantial research and thorough understanding of a wide variety of transactions and accounts, nor do the decisions regarding what must be done include developing variations in approach to fit specific problems, or dealing with incomplete, unreliable, or conflicting data.  The appellants are not authorized to make decisions on the handling of particularly complex or unusual transactions but rather refer such cases to higher-graded staff for assistance or resolution.  Work samples provided by the appellants are not indicative of the complexities envisioned at Level 4-4. 

Level 4-3 is credited (150 points).

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.

The scope and effect of the appellants’ work meets Level 5-3 (the highest level described under this factor).  At this level, the purpose of the work is to treat a variety of problems in accounting, budget, or financial management transactions.  Issues might result, for example, from insufficient information about the transaction, a need for more efficient processing procedures, or requests to expedite urgently needed cases.  The work affects the quality, quantity, and accuracy of the organization’s records, program operations, and service to clients.  For example, the effect of the work is to ensure the integrity of the overall general ledger; the amount and timely availability of money to pay for services; the economic well-being of employees being serviced; or compliance with legal and regulatory requirements.

The appellants' position fully meets but does not exceed this level in that their work requires resolving identified problems in financial transactions in order to ensure the overall accuracy of grant funding records in terms of expenditures and available funds.

Level 5-3 is credited (150 points). 

Factor 6, Personal contacts
     and
Factor 7, Purpose of contacts

These factors include face-to-face and telephone contacts with persons not in the supervisory chain and the purposes of those contacts.  The relationship between Factors 6 and 7 presumes that the same contacts will be evaluated under both factors.

     Persons contacted

The appellants’ personal contacts match level 2, where contacts are with employees in the same agency but outside the immediate organization, such as with personnel in other functional areas, and/or with members of the general public in a moderately structured setting.  Level 3 is not met, where contacts are with persons outside the agency in their capacity as representatives of others such as attorneys and accountants, contractors, public action groups, or congressional staff members making inquiries on behalf of constituents.  The appellants have occasional minor contacts with grantees to obtain documentation, but their regular and recurring contacts with external parties are more accurately represented at level 2. 

     Purpose of contacts

The purpose of the appellants’ contacts is consistent with level b, where contacts are to plan and coordinate actions to correct or prevent errors, delays, or other complications during the transaction cycle, e.g., requesting other personnel to correct errors in documentation or data entry.  Level c is not met, where the purpose of contacts is to persuade individuals who are fearful, skeptical, uncooperative, or threatening to provide information, take corrective action, and accept findings to gain compliance with established laws and regulations.  The appellants' contacts are collegial and do not involve the conflicts described at level c.

Level 2b is credited (75 points). 

Factor 8, Physical Demands

This factor covers the requirements and physical demands placed on the employee by the work assignment.  This includes physical characteristics and abilities, as well as the extent of physical exertion involved in the work.

As at Level 8-1, which is the only level described in the JFS, the appellants’ work is sedentary and free of special physical demands. 

Level 8-1 is credited (5 points).

Factor 9, Work Environment

This factor considers the risks and discomforts in the employee’s physical surroundings. Additionally, any safety regulations related to the work assigned are considered.

As at Level 9-1, which is the only level described in the JFS, the appellant’s work environment consists of an office setting and involves everyday risks or discomforts requiring normal safety precautions typical of an office setting.

Level 9-1 is credited (5 points).

Summary

Factors         Level  Points 
Knowledge Required  1-4   550
Supervisory Controls  2-3   275
Guidelines 3-2   125
Complexity 4-3   150
Scope and Effect 5-3   150
Personal Contacts and Purpose of Contacts  2b     75
Physical Demands  8-1       5
Work Environment 9-1       5
Total   1335


The total of 1335 points falls within the GS-6 range (1105-1350) on the grade conversion table provided in the JFS.

 Evaluation using the GS-1106 Position Classification Standard (PCS)

The appellant’s work related to reviewing TRPs prior to their submission to NSSC is evaluated using the GS-1106 PCS for the Procurement Clerical and Technician Series, which is also written in FES format. 

Factor 1, Knowledge required by the position

The knowledge required by the appellants’ position generally meets Level 1-4 (the highest level described under this factor).  At this level, the work requires in-depth or broad knowledge of a body of procurement regulations, procedures, and policies including, for example, knowledge of the wide variety of interrelated steps and procedures required to assemble, review, and maintain procurement files related to complex contracts (e.g., large purchases for specialized supplies or for services and construction), and knowledge of the requirements of various contract clauses and special laws (e.g., Davis-Bacon, Service Contract, Prompt Payment Acts, progress payments, first article production/testing requirements) to ensure the inclusion of necessary information or supporting documentation in bid and solicitation packages.

This accurately represents the knowledge requirements of the position (e.g., relevant portions of the NASA Grants Handbook, NASA FAR Supplement) in reviewing complex TRPs to ensure the required information has been provided and any additional documentation to support the request is included.

Level 1-4 is credited (550 points).

Factor 2, Supervisory controls

The supervision under which the appellants operate is consistent with Level 2-3 (the highest level described under this factor).  At this level, the supervisor assigns work with standing instructions on objectives, priorities, and deadlines and provides guidance for unusually involved situations.  The employee plans and carries out successive steps necessary to perform procurement support tasks and uses accepted practices or procedures to resolve problems and deviations.  Problems include, for example, purchases that cannot be processed using standard procedures or practices because of the specialized nature of the transaction or conflicting or lacking documentation.  The supervisor reviews completed work for technical soundness, appropriateness, and conformance to policy and requirements.

This factor level is essentially similar under both the GS-1106 PCS and the GS-500 JFS above, and the same analysis applies. 

Level 2-3 is credited (275 points).

Factor 3, Guidelines

At Level 3-2, a number of established procedures and specific guidelines are available in the form of desk procedures, commercial catalogs, Federal supply code manuals, specific acquisition regulations, precedent actions, and coding and processing manuals.  Because of the number and similarity of guidelines and work situations, the employee must use judgment to identify and select the most appropriate procedures to use, choose from among several established alternatives, or decide which precedent actions to follow as a model.  There may be omissions in guidelines, and the employee is expected to use some judgment and initiative to handle aspects of the work not completely covered (e.g., when responding to vendor questions or organizing daily tasks).  The employee refers situations requiring significant judgment to the supervisor or others for guidance or resolution.

Level 3-2 is met.  As at this level, established procedures and other specific guidelines are available to the appellants.  However, based on their experience, acquired knowledge of the function, and the routinized nature of the work, the appellants do not often have to actually refer to the guidelines when making decisions.  They use judgment and past experience to select from among available alternatives.  When guidelines do not apply, they refer the matter to higher-level employees.  

At Level 3-3, guidelines are the same as Level 3-2 but are not completely applicable to many aspects of the work because of the problem solving or complicated nature of the assignments.  For example, in gathering material to respond to a contractor's protest or to resolve problems encountered in acquisition closeout, the employee determines relevant information by reviewing and reading various documents in contract files and procurement records.  When reconstructing an incomplete contract file, the employee may have to rely on experienced judgment, rather than guides, to fill in gaps, identify sources for information, and make working assumptions about what transpired.  The employee uses judgment to interpret guidelines, adapt procedures, decide approaches, and resolve specific problems.  This includes, for example, using judgment to reconstruct incomplete contract files, devise more efficient methods for procedural processing, gather and organize information for protests or inquiries, or resolve problems referred by others (e.g., ones that could not be resolved at lower levels).  The employee analyzes the results of applying guidelines and recommends changes. These changes may include, for example, suggesting the development of controls, training, or specific guidance related to the procedural handling of documents and information.

Level 3-3 is not met.  The problem solving or complicated nature of the assignments described at Level 3-3 is not found in the appellants’ work.  The appellants review TRPs for completeness and to identify potential problems that may result in their rejection by NSSC.  However, the guidelines to identify any such problems are established, and the appellants are not authorized to personally resolve issues where the guidelines are not clear.  They do not resolve problems referred by others and there is no evidence that they routinely analyze the grant guidelines and recommend changes to the procedural handling of grant transactions.   

Level 3-2 is credited (125 points). 

Factor 4, Complexity

The complexity of the appellants’ work is comparable to Level 4-3 (the highest level described under this factor).  At this level, the work involves various procurement support duties involving the use of different and unrelated procedures and methods resulting from, for example, the nonstandardized nature of the transactions or their interrelationship with other systems, requiring extensive coordination with various personnel.  The employee identifies the nature of the issue and determines the need for and obtains additional information through contacts and by reviewing regulations and manuals.  The following examples are provided in the PCS to illustrate this level:

  • assemble and review various solicitation packages that involve numerous line items, contract clauses, provisions, and attachments for incompatible information or administrative discrepancies.
  • use different established procedures to process applications for contracting officer warrants, review vendors' applications for bidder's mailing lists, screen incoming purchase request item descriptions for accuracy and adequacy, and monitor the status of purchase orders.
  • provide procurement support work throughout the procurement cycle by assembling contracts, abstracting bids, processing amendments and modifications, monitoring the status of deliveries, reconciling invoices, and preparing information for closing out contracts.

The appellants' position fully meets but does not exceed this level in that they perform analogous work in reviewing TRPs (i.e., "solicitation packages") with numerous clauses and provisions for completeness and conformance to basic administrative requirements, and in processing amendments and modifications.

Level 4-3 is credited (150 points).

Factor 5, Scope and effect

The scope and effect of the appellants’ work meet Level 5-3 (the highest level described under this factor).  At this level, the purpose of the work is to apply conventional practices to treat a variety of problems in procurement transactions.  Problems might result, for example, from insufficient information in contract files, a need for more efficient processing procedures, or requests to expedite urgently needed items.  The work results in recommendations, solutions, or reports that directly affect customer or vendor relations or operations.

The appellants' position fully meets but does not exceed this level in that the specific purpose of their work is to resolve problems identified in TRPs, such as insufficient information or documentation, and the work results in recommendations that directly affect relations with the NASA program offices concerned with the expeditious processing of their grant actions.   

Level 5-3 is credited (150 points).

Factor 6, Personal contacts
     and
Factor 7, Purpose of contacts

     Persons contacted

The appellants’ personal contacts match level 2 (the highest level described under this factor), where contacts are with employees in the same agency but outside the immediate organization, such as with personnel in other functional areas, and/or with members of the general public in a moderately structured setting.

      Purpose of contacts

The purpose of the appellants' contacts is consistent with level b (the highest level described under this factor), where contacts are to plan and coordinate actions to correct or prevent errors, delays, or other complications during the procurement cycle, such as by requesting other personnel to submit paperwork or correct errors in documentation.

Level 2b is credited (75 points).

Factor 8, Physical Demands

This factor covers the requirements and physical demands placed on the employee by the work assignment.  This includes physical characteristics and abilities, as well as the extent of physical exertion involved in the work.

As at Level 8-1, which is the only level described in the PCS, the appellants’ work is sedentary and free of special physical demands. 

Level 8-1 is credited (5 points).

Factor 9, Work Environment

This factor considers the risks and discomforts in the employee’s physical surroundings. Additionally, any safety regulations related to the work assigned are considered.

As at Level 9-1, which is the only level described in the PCS, the appellant’s work environment consists of an office setting and involves everyday risks or discomforts requiring normal safety precautions typical of an office setting.

Level 9-1 is credited (5 points).

Summary  

Factors Level Points
Knowledge Required   1-4    550
Supervisory Controls   2-3    275
Guidelines   3-2    125
Complexity   4-3    150
Scope and Effect   5-3    150
Personal Contacts and Purpose of Contacts    2b     75
Physical Demands   8-1       5
Work Environment   9-1       5
Total 1335

 

The total of 1335 points falls within the GS-6 range (1105-1350) on the grade conversion table provided in the PCS.                                                                                                                                                                            

Decision

The position is properly classified as GS-503-6, with the title at agency discretion but as “Technician.”                              

 

 

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