Washington, DC

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

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



05/18/2016

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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).
 
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 that accepted the appeal. 

Introduction

The U.S. Office of Personnel Management’s (OPM) Merit System Accountability and Compliance accepted this position classification appeal on September 17, 2014.  The appellant occupies the position of Supervisory Grants Management Specialist, GS-1109-14, in the Headquarters Grants Administration Office (HGAO), Management Operations Directorate (MOD), at Goddard Space Flight Center (GSFC) in Greenbelt, Maryland.  (On July 20, 2015, the appellant notified OPM that as a result of a reorganization, HGAO was moved from the Institutional Support Office (Code 201) to MOD (Code 200)).  She requests reclassification of her position as GS-301-15.  We received the agency administrative report (AAR) on November 12, 2014, and the appellant's response to the AAR on November 21, 2014.  We accepted and decided this appeal under the provisions of section 5112 of title 5, United States Code.

Background

The HGAO was established and staffed in 1997.  The appellant's position at that time was classified as Grants Resources Specialist, GS-301-12, was reclassified as Lead Grants Resources Specialist, GS-301-13, in 2000, and then to Supervisory Grants Resources Specialist, GS-301-14, in 2004.  Early in 2014, the appellant requested a reassessment of her position to support upgrading to the GS-15 level and an audit of the position was subsequently conducted by NASA’s GSFC Office of Human Capital Management (OHCM).  OHCM determined that the position was properly classified as Supervisory Grants Management Specialist, GS-1109-14.  The appellant disagreed with the audit results, instead believing that the position is properly classified as GS-301-15, and therefore appealed to OPM.  Throughout this sequence of events, the functions of the HGAO did not change, and the appellant stated in her AAR response:  "There has been no reorganization which lead to increased scope or responsibilities.  The duties have not changed."  Rather, the appellant suggests that "system limitations" of the electronic position description (PD) system misrepresented the actual duties performed.     

General issues

The appellant disagrees with her agency’s classification review process.  She asserts that the agency did not consider substantive information provided in her work samples.  In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of the position based solely by comparing its 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 agency decisions, the agency’s classification review process is not germane to this decision.   

Adding to her disagreement with her agency’s classification review process, the appellant asserts that the agency provided “no justification for arbitrary point reductions on the ranking factors” of a proposed PD she drafted (draft PD #71983).  She included a copy of this proposed PD in her appeal to OPM.  A PD is the official record of the major duties and responsibilities assigned to a position or job 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 on the basis of the actual duties and responsibilities currently assigned by management and performed by the employee.  An OPM appeal decision classifies a real operating position, and not simply the PD.  Therefore, this decision is based on the work currently assigned to and performed by the appellant.  

Position information

The HGAO serves as an intermediary between the NASA headquarters (HQ) 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.  The appellant supervises a group of five employees carrying out the daily processing of NASA HQ grant transactions.  These grant transactions are for 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 staff is responsible for reviewing 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.) 

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.

As HGAO supervisor, the appellant is primarily responsible for effective review and coordination of grant transactions to support NASA HQ in accomplishing its mission.  She is responsible for providing the administrative and technical supervision necessary for accomplishing the work of the unit and provides oversight of grant related activities as they relate to HQ resource management goals and objectives.  She serves as the expert on administrative procedures and requirements for activities in the HGAO and ensures that HGAO activities are consistent with broad NASA guidance as well as the GSFC and HQ Directorate goals and objectives.  The results of our interviews, the appellant’s PD, and other material of record reveal more about the appellant’s duties and responsibilities and how they are performed, and were fully considered, and are incorporated by reference, in this decision. 

Although the appellant’s PD appears to contain the basic elements of the position, these are subsumed within the extensive verbiage that materially misrepresents the nature of the work she performs.  For example, nothing in the record suggests that the appellant must be “fully knowledgeable of environmental factors” (this is not within HGAO mission parameters); “provide management and oversight in issuing procurement policy, directives and other documents” (nothing in the record or our interviews showed any evidence of this); “makes recommendations that often serve as the basis for new systems, legislation, regulations, or programs” (nothing in the record or our interviews showed any evidence of this); “directs and ensures the conduct of grant awards” (these functions are performed by NSSC); or “provides expert advice and guidance on…interpretations of original legislative or judicial intent…” (this is not within HGAO mission parameters).  These are merely examples of duties described in the appellant’s 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 she actually performs and appear to have been selected solely to support the desired factor level assignments.

The appellant does not dispute the accuracy of her PD (#1035782) 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 her position, and her supervisor certified its accuracy. 

Series determination

The current allocation of the appellant's position to the GS-1109 Grants Management Series is 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 appellant's role as it relates to the awarding of grants is limited to supervising the subordinate staff who review 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.  Similarly, her role as it relates to grant funding is limited to supervising the subordinate staff who resolve 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 two-grade interval GS-1109 series.            

The appellant requests classification of her position to the GS-301 Miscellaneous Administration and Program Series.  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 appellant's case, she does not supervise two-grade interval work.  Additionally, her work is directly associated with work found in the GS-503 Financial Clerical and Technician Series as discussed further below, and as such the GS-301 series is not appropriate.
 
The requested classification of the aforementioned proposed PD (draft PD #71983) was Supervisory Management and Program Analyst, GS-343-15.  The GS-343 series includes positions that primarily serve as analysts and advisors to management on the evaluation of the effectiveness of government programs and operations or the productivity and efficiency of the management of Federal agencies or both.  Positions in this series require knowledge of: the substantive nature of agency programs and activities; agency missions, policies, and objectives; management principles and processes; and the analytical and evaluative methods and techniques for assessing program development or execution and improving organizational effectiveness and efficiency.  Some positions also require an understanding of basic budgetary and financial management principles and techniques as they relate to long range planning of programs and objectives.  The work requires skill in: application of fact-finding and investigative techniques; oral and written communications; and development of presentations and reports. 

The Position Classification Flysheet for the Management and Program Analysis Series specifically excludes from coverage by the GS-343 series “positions primarily engaged in conducting, supervising, or managing the line program activities or functions of the employing agency.”  Considering that the appellant supervises a staff performing essentially line function activities (i.e., processing grant transactions) and that she is not primarily serving in a staff capacity as an analyst and advisor to management on the evaluation of the effectiveness of the overall NASA grant program, her position does not warrant classification to the GS-343 series. 

Occupational series in the General Schedule are normally divided into two categories − those covering one-grade interval work, and those covering two-grade interval work.  Guidance on determining whether work is one- or two-grade interval in nature is contained in The Classifier’s Handbook (Handbook).  The Handbook explains that two-grade interval positions progress by two grade increments from GS-5 to GS-11 and include professional and administrative occupations.  One-grade interval positions include clerical and technical occupations and progress from GS-1 by single grade increments.  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 appellant’s duties involve supervising one-grade interval support work rather than two-grade interval administrative work.  Her supervisory duties require her to be  proficient in certain limited phases of the NASA grants administration function and are transactional in nature; i.e., they are 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 focus 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 appellant 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, she otherwise supervises employees who follow established methods and procedures; i.e., her unit's work is clearly defined in terms of the processes to be carried out.  The employees she supervises 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.  She does not, however, direct work requiring a high order of analytical ability and a comprehensive knowledge of management processes and functions.  For example, HGAO employees 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, HGAO employees 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 handled by the Technical Officers (TOs), NASA legal counsel, or the procurement office.   

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 appellant’s 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 Introduction cautions that in selecting the appropriate series, one must determine the paramount knowledge, i.e., the most important subject-matter knowledge required to perform the primary duties of the position.  To determine the paramount knowledge, one must consider the primary purpose for the position’s existence, the most important qualification(s) required, recruitment sources, career progression, and the background knowledge required.  The appellant’s primary duties and responsibilities involve managing a staff which coordinates financial support functions which require specialized knowledge of fund control management, cost transfers, financial terminology, fiscal guidelines, laws, regulations, and policies.  These specialized knowledges are common characteristics of work found in the GS-503 Financial Clerical and Technician Series.  The 503 series is appropriate for positions engaged in carrying out one-grade interval clerical or technician work in support of accounting, auditing, budgeting, or financial management functions when no other established series in the Accounting and Budget Group, GS-500, is appropriate.  The financial support duties described above occupy most of the appellant’s staff time and thus represent the paramount qualifications of the position, and therefore the position is properly classified to the GS-503 series.
                  
Title determination

The GS-503 series has no prescribed position titles except that positions GS-5 and above should have a “Technician” title.  Agencies may designate the official title of positions in such cases, consistent with instructions on title construction appearing in the Introduction, Section III, H, 2.  However, the title must include the “Supervisory” prefix.

Standard determination

The appellant exercises supervisory authorities and responsibilities meeting the criteria for coverage under the General Schedule Supervisory Guide (GSSG); i.e., her duties require accomplishment of work through combined technical and administrative direction of others, constitute a major duty requiring at least 25 percent of the position's time, and meet at least the minimum level of Factor 3 in the guide. 

Grade determination

The GSSG uses a factor-point evaluation approach that uses six factors common to all supervisory positions.  Each factor level in the standard 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 in any significant aspect, it must be credited at a lower level.  Conversely, the position may exceed those criteria in some aspects and still not be credited at a higher level.  Each factor level has a corresponding point value.  The total points are converted to a grade by use of the grade conversion chart in the standard.

Factor 1, Program Scope and Effect

This factor assesses the general complexity, breadth, and impact of the program areas and work directed, including its organizational and geographic coverage.  It also assesses the impact of the work both within and outside the immediate organization.  To assign a factor level, the criteria dealing with both scope and effect, as defined below, must be met.

    Scope

“Scope” addresses the general complexity and breadth of the program directed or the work directed, the products produced, or the services delivered.  The geographic and organizational coverage of the program within the agency structure is included under scope.

At Level 1-2, the work directed is administrative, technical, complex clerical, or comparable in nature.  The functions, activities, or services provided have limited geographic coverage and support most of the activities comprising a typical agency field office, an area office, a small to medium military installation, or comparable activities within agency program segments.

At Level 1-3, the position directs a program segment that performs technical, administrative, protective, investigative, or professional work.  The program segment and work directed typically have coverage which encompasses a major metropolitan area, a State, or a small region of several States; or, when most of an area’s taxpayers or businesses are covered, coverage comparable to a small city.  Providing complex administrative or technical or professional services directly affecting a large or complex multi-mission military installation also falls at this level.       

The appellant’s position meets Level 1-2 but falls short of Level 1-3 in terms of both the general complexity and breadth of the work directed.  The work directed is carried out by GS-6 technicians performing one-grade interval work of a comparable level of complexity to the “complex clerical” or lower-graded “administrative” work described at Level 1-2 rather than the primarily two-grade interval work described at Level 1-3.  Further, the work directed, which represents an internally-focused support function rather than an externally-focused program activity or service, supports “agency program segments” at NASA HQ.   The appellant’s position is comparable to the third illustration under Level 1-2 in the GSSG in terms of both the complexity of the work and its organizational coverage within the agency structure: 

Directs operating program segment activities comparable to those above [e.g., "budget, management, staffing, supply, maintenance, protective, library, payroll, or similar services"] but found at higher organizational levels in the agency, for example, the section or branch level of a bureau.

The appellant’s position is comparable to this illustration in that the work directed is of an administrative support nature and the HGAO, though organizationally located at GSFC, supports only the NASA HQ organization. 

The limited nature of the services provided by the appellant’s staff does not warrant crediting of Level 1-3.  First, the appellant does not direct a “program segment” as that term is defined in the GSSG (i.e., a subdivision of a program, such as a subdivision of an agencywide personnel or budget program) but rather a support function that serves as the conduit between the NASA technical officers and the substantive grants administration carried out at NSSC; i.e., the work directed is not a segment of the grants program but rather supports the grants program.  Second, the work directed is one-grade interval in nature and is not comparable to the “technical, administrative, protective, investigative, or professional work” described at Level 1-3.  Third, the circumscribed purpose and nature of the work limit the organizational coverage of the work directed within the agency structure.  The Level 1-3 definition for internally-focused administrative work is described within a Department of Defense setting (i.e., “a large or complex multi-mission military installation”).  The third illustration under Level 1-3 in the GSSG, corresponding to the related Level 1-2 illustration cited above, expands upon the definition and makes clear that the intent of this level exceeds the complexity and breadth of the work directed by the appellant: 

Directs administrative services (personnel, supply management, budget, facilities management, or similar) which support and directly affect the operations of a bureau or a major military command headquarters; a large or complex multimission military installation; an organization of similar magnitude, or a group of organizations which, as a whole, are comparable.

The appellant does not direct work which is comparable in complexity to the entire personnel, budget, or, relevant to her position, grants administration program of a large organization.  As noted above, she directs one-grade interval support work which is ancillary to the conduct of the NASA grants administration program.  Further, the work she directs facilitates other processes through the submission of complete grant packages and the maintenance of accurate financial records, but it does not directly affect NASA operations to the extent envisioned at Level 1-3 (i.e., through the direction of the broad program segments described).  Therefore, the appellant’s position does not meet the threshold for Level 1-3 because of the restricted nature of the work directed, and “Scope” is properly evaluated at Level 1-2.  See Digest of Significant Classification Decisions and Opinions No. 20-04, October 1997. 

   Effect 

“Effect” addresses the impact of the work, the products, and/or the programs described under “Scope” on the mission and programs of the customer, the activity, other activities in or out of government, the agency, other agencies, the general public, or others.

At Level 1-2, the services or products support and significantly affect installation level, area office level, or field office operations and objectives, or comparable program segments; or provide services to a moderate, local or limited population of clients or users comparable to a major portion of a small city or rural county.

At Level 1-3 activities, functions, or services accomplished directly and significantly impact a wide range of agency activities, the work of other agencies, or the operations of outside interests (e.g., a segment of a regulated industry), or the general public. At the field activity level (involving large, complex, multimission organizations and/or very large serviced populations comparable to the examples below) the work directly involves or substantially impacts the provision of essential support operations to numerous, varied, and complex technical, professional, and administrative functions.

The appellant’s position meets Level 1-2.  Similar to this level, the services that the HGAO provides support and affect the operations of NASA’s grants administration program; i.e., the "comparable program segments" described in the Level 1-2 illustration cited above under “Scope.”   

The appellant’s position does not meet Level 1-3.  The services and functions provided by the HGAO do not directly and significantly impact a wide range of agency activities, the work of other agencies or the operations of outside interests, or the general public.  The appellant asserts that the work produced by the HGAO affects grantees nationwide, the work of other agencies, and the general public, but this is inaccurate.  The actual awarding of grants and certain other administrative functions within the grants program may affect grantees nationwide and impact agency activities, but these duties reside with the NSSC, not the HGAO.  The appellant supervises employees performing support work impacting a limited segment of the agency’s grant administration activities and do not provide essential support functions that directly and significantly affect the wide range of agencywide programs or the work of other agencies as described at Level 1-3.  The work directed does not have an impact equivalent to that of, for example, the provision of the full range of budget and financial management services to a large, complex organization such as NASA.  In other words, although the work of the HGAO may directly affect the timely processing of grant actions, any direct impact on NASA’s line program operations through the conduct of the agency’s grants administration function would be exercised by NSSC.  Therefore, “Effect” is properly evaluated at Level 1-2.  

As both subfactors under Factor 1 are credited at Level 1-2, that level is credited (350 points). 

Factor 2 - Organizational Setting  

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

At Level 2-3, the highest level described under this factor, positions are accountable to a position that is SES level, flag or general officer military rank, or equivalent or higher level; or to a position which directs a substantial GS/GM-15 or equivalent level workload; or to a position which directs work through GS/GM-15 or equivalent level subordinate supervisors, officers, contractors, or others. 

Level 2-3 is met.  The appellant’s position is accountable to the Deputy Director of Management Operations, an SES position in her direct supervisory chain who directs work through three    GS-15 subordinate supervisors.                

This factor is credited (350 points).

Factor 3 - Supervisory and Managerial Authority Exercised

This factor covers the delegated supervisory and managerial authorities which are exercised on a recurring basis.  To be credited with a level under this factor, a position must meet the authorities and responsibilities to the extent described for the specific level. 

To meet Level 3-2c, the position must carry out at least 3 of the first 4 and a total of 6 or more of the following 10 authorities and responsibilities:

1. Plan work to be accomplished by subordinates, set and adjust short-term priorities, and prepare schedules for completion of work;
2. Assign work to subordinates based on priorities, selective consideration of the difficulty and requirements of assignments, and the capabilities of employees;
3. Evaluate work performance of subordinates;
4. Give advice, counsel, or instruction to employees on both work and administrative matters;
5. Interview candidates for positions in the unit; recommend appointment, promotion, or reassignment to such positions;
6. Hear and resolve complaints from employees, referring group grievances and more serious unresolved complaints to a higher level supervisor or manager;
7. Effect minor disciplinary measures, such as warnings and reprimands, recommending other action in more serious cases;
8. Identify developmental and training needs of employees, providing or arranging for needed development and training;
9. Find ways to improve production or increase the quality of the work directed;
10. Develop performance standards.

Level 3-2c is met.  The appellant is responsible for planning work to be accomplished by HGAO staff, and setting and adjusting short-term priorities for the five subordinate employees.  She assigns work to subordinates based on priorities, selective consideration of the difficulty and requirements of assignments, and the capabilities of employees; evaluates work performance; provides advice, counsel, or instruction to employees on both work and administrative matters; interviews candidates for positions and makes selections; hears and attempts to resolve informal employee complaints, referring formal complaints to higher-level management; takes minor disciplinary actions if warranted; identifies developmental and training needs of employees, providing or arranging for needed development and training; and finds ways to improve production or increase the quality of the work directed.  The appellant’s delegated supervisory responsibilities include all of the authorities under Level 3-2c.  

At Level 3-3, the supervisor must meet one of two conditions.  To meet the first condition (Level 3-3a), the supervisor must exercise delegated managerial authority to set a series of annual, multiyear, or similar types of long-range work plans and schedules for in-service or contracted work; determine the best approach for resolving budget shortages; and plan for long-range staffing needs.  These positions are closely involved with high level program officials (or comparable agency level staff personnel) in the development of overall goals and objectives for assigned staff function(s), program(s), or program segment(s).  For example, they direct development of data; provision of expertise and insights; securing of legal opinions; preparation of position papers or legislative proposals; and execution of comparable activities which support development of goals and objectives related to high levels of program management and development or formulation. 

Level 3-3a is not met.  Managerial is described in the GSSG as:

the authority vested in some positions under the General Schedule which direct the work of an organizational unit, are held accountable for the success of specific line or staff functions, monitor and evaluate the progress of the organization toward meeting goals, and make adjustments in objectives, work plans, schedules, and commitment of resources.  As described in section 5104 of title 5,United States Code, such positions may serve as head or assistant head of a major organization within a bureau; or direct a specialized program of marked difficulty, responsibility, and national significance.

The appellant does not exercise this level of authority.  Most positions involved in the delivery of basic program services or the execution of line program activities, as the appellant’s position is, do not meet this level.  Level 3-3a describes program management work normally delegated to higher levels in the organization, where the position is involved in making decisions related to broad staffing, budgetary, policy, and regulatory matters affecting the overall program on a national level.  The appellant's unit, by contrast, is not vested with this level of program responsibility, and the appellant has no independent authority to make the types of managerial decisions described above.  Level 3-3a is not met.     

To meet the second condition (Level 3-3b), the supervisor, in addition to exercising the authorities and responsibilities described at Level 3-2c, must meet at least 8 of the 15 authorities specified in the factor description.  As stated above, the appellant exercises 7 of 10 responsibilities described at Level 3-2c, and 3 of the 15 responsibilities listed under Level 3-3b. Specifically, she exercises responsibilities 7, 14, and 15, as discussed below:

• The appellant meets responsibility 7 in that she has authority to make selections for subordinate nonsupervisory positions.
• The appellant meets responsibility 14 since she has authority to recommend awards for nonsupervisory personnel and changes in position classification.
• The appellant meets responsibility 15 in that she finds and implements ways to eliminate or reduce significant bottlenecks and barriers to production, promote team-building, or improve business practices.  For example, she was instrumental in adding suggestions and finding ways to streamline the PI transfer process so that it could be more efficient and timely; she constantly shares information with her staff which promotes discussion and learning; and business practices are improved through her attention to regulatory detail and NASA policy.   

The appealed position does not meet responsibilities 1, 2, 3, 4, 5, 6, 8, 9, 10, 11, 12, or 13 listed under Level 3-3b for reasons discussed below.

Under Level 3-3b of the GSSG, several responsibilities (e.g., 1, 3, 5, 6, 8) are only credited to supervisors who direct two or more subordinate supervisors, team leaders, or comparable personnel.  To support these designations, these subordinate personnel must spend 25 percent or more of their time on supervisory, lead, or comparable functions.  These responsibilities may be credited only in situations where the subordinate organization is so large and its work so complex that it requires managing through these types of subordinate positions.

The GSSG uses the plural when speaking of subordinate supervisors and leaders, rather than using a phrase such as “one or more subordinate supervisors, leaders….”  This is deliberate. Level 3-3b is intended to credit only supervisors who direct at least two persons who are officially recognized as subordinate supervisors, leaders, or comparable personnel.

• Since the appellant does not direct two or more subordinate supervisors, team leaders, or comparable personnel, the appealed position cannot receive credit for responsibility 1.
• Under responsibility 3, a supervisor must assure reasonable equity among subordinate units of both performance standards and rating techniques developed by subordinates. Similarly to responsibility 1, responsibility 3 envisions that these performance standards and rating techniques are developed by at least two subordinate supervisors, team leaders, or comparable personnel.  The appellant does not direct two or more subordinate supervisors, team leaders, or comparable personnel, and, therefore, responsibility 3 cannot be credited.
• Responsibility 4 requires direction of a program or major program segment with significant resources (for instance, a multimillion-dollar level of annual resources).  While the appellant’s team provides fund control services for multimillion-dollar accounts, the program segment she directs (the HGAO) does not have this level of resources.  Since the appellant lacks direct control over a multimillion-dollar level of annual resources, responsibility 4 cannot be credited.
• Like responsibilities 1 and 3, responsibilities 5, 6, and 8 are intended to credit only supervisors who direct at least two or three subordinate supervisors, team leaders, or comparable personnel.  Therefore, credit cannot be awarded for these three responsibilities.
• Under responsibility 9, a supervisor must hear and resolve formal group grievances or serious complaints from employees.  The appellant hears and tries to resolve all grievances or complaints from her staff.  However, we cannot grant credit for responsibility 9.  Our interviews indicate that she lacks authority to resolve grievances that go beyond the initial, informal stage.  Beyond the informal stage, higher-level supervisors would become involved.  She therefore has less authority to resolve formal group grievances and serious employee complaints than intended under responsibility 9.
• Responsibility 10 requires that a supervisor review and approve serious disciplinary actions (for instance, suspensions) involving nonsupervisory subordinates.  As with responsibility 9, higher-level supervisors would become involved with serious disciplinary actions; therefore, she has less authority to deal with them than intended under responsibility 10. 
• Under responsibility 11, a supervisor must make decisions on nonroutine, costly, or controversial training needs and training requests related to the unit.  Nothing in the record suggests the appellant makes decisions of this magnitude.  Accordingly, responsibility 11 is not fully met and is not credited.
• Responsibility 12 cannot be credited because the appellant does not determine whether contractor-performed work meets standards of adequacy needed to authorize payment.
• Responsibility 13 involves approving expenses comparable to within-grade increases, extensive overtime, and employee travel.  Nothing in the record suggests that the appellant’s staff performs extensive overtime or travel.  The appellant does not have final authority to approve within-grade increases.  Because responsibility 13 is not fully met, it may not be credited.

The appellant’s position is credited with only 3 of the 15 responsibilities listed under Level 3-3b. Therefore, this level is not met.   

Level 3-2 is credited (450 points).

Factor 4, Personal Contacts

This two-part factor assesses the nature and purpose of personal contacts related to supervisory and managerial responsibilities.  The nature of contacts, credited under subfactor 4A, and the purpose of those contacts, credited under subfactor 4B, must be based on the same contacts. 

Subfactor 4A-Nature of contacts

This subfactor covers the organizational relationships, authority or influence level, setting, and difficulty of preparation associated with making personal contacts involved in supervisory and managerial work.  To be credited, the level of contacts must contribute to the successful performance of the work, be a recurring requirement, have a demonstrable impact on the difficulty and responsibility of the position, and require direct contact.  

At Level 4A-1, contacts are with subordinates within the organizational unit(s) supervised, with peers who supervise comparable units within the larger organization, with union shop stewards, and/or with the staff of administrative and other support activities when the persons contacted are within the same organization as the supervisor.  Contacts are typically informal and occur in person at the work place of those contacted, in routine meetings, or by telephone.

At Level 4A-2, frequent contacts are comparable to members of the business community, general public, high ranking managers, supervisors, and staff of program, administrative and other work units and activities throughout the field activity, installation, command (below major command level) or major organization level of the agency; representatives of local public interest groups; case workers in congressional district offices; technical or operating level employees of State and local governments; and/or reporters for local and other limited media outlets reaching a small, general population.  Contacts may be informal, occur in conferences and meetings, or take place through telephone, televised, radio, or similar contact, and sometimes require nonroutine or special preparation.

At s Level 4A-3, frequent contacts are comparable to high ranking military or civilian managers, supervisors, and technical staff at bureau and major organization levels of the agency, with agency headquarters administrative support staff, or with comparable personnel in other Federal agencies; key staff of public interest groups (usually in formal briefings) with significant political influence or media coverage; journalists representing influential city or county newspapers or comparable radio or television coverage; congressional committee and subcommittee staff assistants below staff director or chief counsel levels; contracting officials and high level technical staff of large industrial firms; local officers of regional or national trade associations, public action groups, or professional organizations; and/or State and local government managers doing business with the agency.  Contacts include those which take place in meetings and conferences and unplanned contacts for which the employee is designated as a contact point by higher management.  They often require extensive preparation of briefing materials or up-to-date technical familiarity with complex subject matter.    

The appellant’s position meets Level 4A-2.  She has frequent contacts with subordinate staff in the HGAO, as well as intermittent contacts with NASA technical officers, scientists, principle investigators, program directors, and accounting office personnel.  Her contacts occasionally require special preparation, e.g., in meetings/discussions concerning the editing of the Proposers Guide with other NASA Grants Steering committee members.

The appellant has occasional contacts with high ranking managers, supervisors, and technical staff at NASA HQ.  However, the nature of the work performed by the HGAO do not involve extensive preparation of briefing materials or technical familiarity with complex subject matter.  Rather, problems identified are generally of a processing nature and are communicated via email or telephone.  Further, they do not occur with sufficient frequency to potentially control the evaluation of this factor.
 
Level 4A-2 is credited (50 points).

Subfactor 4B-Purpose of contacts 

This subfactor covers the purpose of the personal contacts credited in subfactor 4A, including the advisory, representational, negotiating, and commitment making responsibilities related to supervision and management.

At Level 4B-2, the purpose of contacts is to ensure that information provided is accurate and consistent; to plan and coordinate the work directed with that of others outside the subordinate organization; and/or to resolve differences of opinion among managers, supervisors, employees, contractors, or others. 

At Level 4B-3, the purpose of contacts is to justify, defend, or negotiate in representing the project, program segment(s), or organizational unit(s) directed, in obtaining or committing resources, and in gaining compliance with established policies, regulations, or contracts.

The appellant’s position meets Level 4B-2 but falls short of Level 4B-3.  The purpose of contacts with technical officers, scientists, and principle investigators is to ensure that information provided is accurate and consistent.  Her contacts with accounting office personnel and program directors are to plan and coordinate the work directed with that of others outside of the HGAO. 

All three conditions listed under Level 4B-3 must be present in a position to award credit for this level.  In order to represent the organization in program defense or negotiations as found at Level 4B-3, a supervisor must necessarily have the requisite control over resources and the authority necessary to gain support and compliance on policy matters.  See Digest of Significant Classification Decisions and Opinions, August 1994, No. 19-02.  Nothing in the record suggests that the appellant defends projects or programs, or negotiates resources.  The appellant provided a work sample consisting of an email exchange between her and other NASA employees in an apparent attempt to demonstrate that she is occasionally required to question certain actions in order to gain regulatory compliance.  However, occasional exchanges like this do not meet the full purpose and intent of Level 4B-3.        

Level 4B-2 is credited (75 points).  

Factor 5, Difficulty of Typical Work Directed
  
This factor measures the difficulty and complexity of the basic work most typical of the organization directed, as well as other line, staff, or contracted work for which the supervisor has technical or oversight responsibility, directly or through subordinate supervisors, team leaders, or others.  The level is determined by determining the highest grade which best characterizes the nature of the basic (mission oriented) nonsupervisory work performed or overseen by the organization directed; and which constitutes 25 percent or more of the workload of the organization. 

As previously noted in the “Position Information” section of this evaluation, the appellant supervises four subordinate positions correctly classified at the GS-6 grade level and one at the GS-8 grade level.  Based on our review, the highest grade which best characterizes the nature of the basic (mission oriented) non-supervisory work performed in the appellant’s unit, and constitutes 25 percent or more of the workload of the organization, is GS-6.  Using the conversion chart in the GSSG for Factor 5, that base level equates to Level 5-3.

Level 5-3 is credited (340 points).  

Factor 6, Other Conditions

This factor measures the extent to which various conditions contribute to the difficulty and complexity of carrying out supervisory duties, authorities, and responsibilities.   Conditions affecting work for which the supervisor is responsible (whether performed by Federal employees, assigned military, contractors, volunteers, or others) may be considered if they increase the difficulty of carrying out assigned supervisory or managerial duties and authorities.    

At Level 6-1, the work supervised or overseen involves clerical, technician, or other work comparable in difficulty to the GS-6 level or lower.  This could vary from basic supervision over a stable workforce performing work operations that are routine, to a level of supervision which requires coordination within the unit to ensure that timeliness, form, procedure, accuracy, quality, and quantity standards are met in individual cases.

At Level 6-2:

a. The work supervised or overseen involves technician and/or support work comparable in difficulty to GS-7 or GS-8, or work at the GS-4, 5, or 6 level where the supervisor has full and final technical authority over the work, which requires coordination and integration of work efforts, either within the unit or with other units, in order to produce a completed work product or service.  (Full and final technical authority means that the supervisor is responsible for all technical determinations arising from the work, without technical advice or assistance on even the more difficult and unusual problems, and without further review except from an administrative or program evaluation standpoint.  Credit for this should be limited to situations involving an extraordinary degree of finality in technical decision making.

The required coordination at this level ensures: consistency of product, service, interpretation, or advice; conformance with the output of other units, with formal standards or agency policy. Supervisors typically coordinate with supervisors of other units to deal with requirements and problems affecting others outside the organization.

OR

b. The position directs subordinate supervisors of work comparable to GS-6 or lower, where coordinating the work of the subordinate units requires a continuing effort to assure quality and service standards, limited to matters of timeliness, form, procedure, accuracy, and quantity.

The base level of work overseen by the appellant is GS-6.  She does not have full and final technical authority over the work, as defined by the 6-2 level, or subordinate supervisors comparable to GS-6 or lower, requiring coordination of subordinate units.  As stated earlier, work samples provided show that any problems extending beyond missing documentation, conflicting information, or recurring issues and which would potentially require a high order of analytical ability or definitive regulatory interpretation are handled by the TOs, NASA legal counsel, or the procurement office.     

Level 6-1 is credited (310 points).

The instructions in the Guide indicate that, if this level is credited at 6-3 or lower, the Special Situations section must be examined.  These situations may complicate supervisory and oversight work.  If three or more of these situations are creditable, a single level may be added to that previously credited for Factor 6.

1. Variety of Work

This situation may be credited when more than one kind of work, each kind representing a requirement for a distinctly different additional body of knowledge on the part of the supervisor, is present in the work of the unit.  A "kind of work" usually will be the equivalent of a classification series.  In the appellant's case, the subordinate positions are all properly classified to the GS-503 series.  Therefore, credit is not appropriate.

2. Shift Operations

This situation may be credited when the position supervises an operation carried out on at least two fully staffed shifts.  This is not creditable.  

3. Fluctuating Work Force or Constantly Changing Deadlines

Fluctuating work force may be credited when there are large fluctuations in size, e.g., when there are significant seasonal variations in staff, and these fluctuations impose on the supervisor a substantially greater responsibility for training, adjusting assignments, or maintaining a smooth flow of work while absorbing and releasing employees.  The size of the appellant’s work force has remained constant.  This is not creditable.

Constantly changing deadlines may be credited when frequent, abrupt, and unexpected changes in work assignments, goals, and deadlines require the supervisor to constantly adjust operations under the pressure of continuously changing and unpredictable conditions.  There is no indication the HGAO is subject to these types of frequent and unanticipated workload demands.  This is not creditable.

4. Physical Dispersion

This situation may be credited when a substantial portion of the workload is regularly carried out at one or more locations which are physically removed from the main unit under conditions which make day-to-day supervision difficult to administer.  This is not creditable.  

5. Special Staffing Situations

This situation may be credited when (1) a substantial portion of the work force is regularly involved in special employment programs, (2) requirements for counseling and motivational activities are regular and recurring, and (3) job assignments, work tasks, working conditions, and/or training must be tailored to fit the special circumstances.  This is not creditable.  

6. Impact of Specialized Programs

This situation may be credited when supervisors are responsible for significant technical or administrative workload in grades above the base level credited in Factor 5, provided the grades of this work are not based upon independence of action, freedom from supervision, or personal impact on the job.  Although the appellant supervises one GS-8 employee, oversight of a single staff  year of GS-8 work is not considered a significant workload in the intended sense for crediting.   

7. Changing Technology

This situation may be credited when work processes and procedures vary constantly because of the impact of changing technology, creating a requirement for extensive training and guidance of staff.  There is no indication of constantly changing technology in the appellant’s work operation requiring extensive staff training.  This is not creditable.  

8. Special Hazard and Safety Conditions

This situation may be credited when supervision is regularly made more difficult by the need to provide for significant unsafe or hazardous conditions occurring during the performance of the organization’s work.  This is not creditable.  

None of the special situations are creditable for the appellant’s position. 

Level 6-1 is credited (310 points). 

Summary   

Factor	Level	Points
1. Program Scope and Effect	1-2	350
2. Organizational Setting	2-3	350
3. Supervisory and Managerial Authority Exercised	3-2	450
4. Personal Contacts
4a. Nature of Contacts	4A-2	50
4b. Purpose of Contacts	4B-2	75
5. Difficulty of Typical Work Directed	5-3	340
6. Other Conditions	6-1	310
Total		1925

A total of 1,925 points falls into the GS-9 range (1855-2100) on the point-to-grade conversion chart in the GSSG.  Therefore the appellant’s supervisory duties are graded at the GS-9 level. 

Decision

The appellant’s position is properly classified as GS-503-9.  Selection of an appropriate title is at the discretion of the agency but with “Supervisory” and “Technician” added to the title selected.
 

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