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Classification & Qualifications Appeal Decisions

Washington, DC

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

[appellant's name]
Accounting Officer
GS-510-13
Branch of Finance
Office of Regional Director
[name] Region
Bureau of Indian Affairs
U.S. Department of the Interior
[city, state]
Accounting Officer
GS-510-12
C-0510-12-03

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

07/29/2014


Date

As provided in section 511.612 of title 5, Code of Federal Regulations (CFR), 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, CFR, must be followed in implementing the 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 revised position description (PD) and a Standard Form 50 showing the personnel action taken.  The report must be submitted within 30 days from the effective date of the personnel action.

Decision sent to:

[appellant and HR addresses]

Introduction

On March 6, 2014, OPM’s Dallas Agency Compliance and Evaluation accepted a classification appeal from [appellant’s name].  The appellant’s position is currently classified as Accounting Officer, GS-510-13, but she believes it should be classified at the GS-14 grade level.  The position is assigned to the Branch of Finance (branch), Office of Regional Director, [name] Region, Bureau of Indian Affairs (BIA), U.S. Department of the Interior (DOI), in [city, state].  We received the complete agency’s administrative report on March 31, 2014.  We have accepted and decided this appeal under section 5112 of title 5, United States Code.

Background and general issues

The appellant’s position was previously classified as Supervisory Accountant, GS-510-14.  The BIA’s Central Human Resources Office, in a January 30, 2014, letter, notified her that the agency had reviewed the classification of the position; determined it was appropriately classified as Accounting Officer, GS-510-13; and assigned her to PD number [number] with that classification.  The appellant subsequently filed a classification appeal with OPM, stating the agency failed to ask for her input or participation in the classification review, unsolicited by her, for a position she has occupied since May 2001.  As she explains in her appeal request to OPM:

…I was under the direct supervision of the Regional Director, [name] Region, until 2004 when supervision of my office was realigned under Central Office, Office of Chief Financial Officer.  Recently in 2013 my office was realigned again and supervision of my office was moved from Central Office, Office of Chief Financial Officer, back to the Regional Director, [name] Region.  All this time, since May 2001, I have retained my grade even though certain duties have been added or changed over the past 13 years.

In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of the appellant’s position.  Because our decision sets aside all previous agency decisions, any concerns regarding why and how the agency evaluated the classification of her position are not germane to this decision.

Position information

The mission of the [name] Regional Office (RO) is to provide services to and enhance the quality of life of American Indian tribes and individuals while managing and protecting trust resources, supporting tribal sovereignty, and promoting self-determination and economic development opportunities.  The RO provides services to 10 tribes in [state] and [state], encompassing an area of 6,456,000 acres with approximately 74,677 enrolled tribal members, and operates field offices at the [locations].  Management of the RO falls to the Regional Director, Deputy Regional Director for Trust Services, and Deputy Regional Director for Indian Services.

The appellant’s branch provides accounting and financial services to the RO and its field offices.  The branch develops, maintains, and communicates sound financial management and accounting policies, procedures, and concepts; advises staff on regulatory accounting and financial policies; and updates and trains staff on new procedures and requirements.  The branch prepares accounting and financial reports, gathers information for data calls, identifies inconsistences and discrepancies in the accounting data reported in the financial system, and ensures entries are corrected, adjusted, and processed accurately and timely to maintain data integrity.

The branch’s major functions and a brief description of the appellant’s work follow:

Accounts Payable and Receivable.  The appellant reviews all financial documents to ensure the correct funding authorization and availability of funds for obligation.  She rectifies accounting discrepancies, resolving problems related to insufficient funds with the RO’s eight program offices (i.e., water resources, natural resources, forestry and fire, land titles and records, Indian services, self determination, budget, and property) and its field offices.  When necessary, she defines and coordinates required modifications to the Financial and Business Management System (FBMS), the DOI’s automated accounting system.  The appellant ensures invoices are paid timely by reviewing, approving, entering, and reconciling bills received for water, heat, propane, electricity, and other utilities; supplies; building; equipment; and other liabilities of the RO and its field offices.  If a payment is late, she coordinates with the program office incurring the late fees to move funding.  The appellant’s accounts receivable work entails identifying money owed to the agency (for example, when vendors are paid twice) and coordinating with DOI’s National Business Center to initiate the bill for collections.

General Ledger.  The appellant monitors accounts to ensure all business transactions are recorded completely and accurately.  She ensures corrective and adjusting entries are processed accurately and quickly to maintain the integrity, reliability, and timeliness of accounting data.

Other Duties.  The appellant prepares accounting and financial reports at the request of the program office, BIA headquarters, and others.  As the RO’s account controller, she reviews all staff requests for access to the FBMS.  Approved requests are forwarded to BIA headquarters.  The appellant may decline the request if, for example, the employee’s position does not require FBMS access.  She also responds to FBMS-related questions from staff.

The appellant’s position also serves as the immediate supervisor for the four full-time equivalent positions assigned to her branch.  Two are encumbered, while two have been vacant for the past year but are expected to be filled upon receipt of funding from BIA headquarters.  The encumbered positions are the GS-501-12 Financial Specialist and GS-525-5 (with a full performance level of GS-7) Accounting Technician positions, and the vacant positions are the GS-501-9 Financial Specialist and GS-525-7 Accounting Technician positions.  We discuss her supervisory duties later in the decision.

The appellant’s position reports directly to the Deputy Regional Director for Indian Services.  The Acting Deputy Regional Director for Indian Services, who has served as her first-level supervisor since March 2014, certified to the accuracy of the duties described in her official PD.  However, in her appeal request to OPM, the appellant asserts her current PD does not describe the duties she performs for the education, drug enforcement, and law enforcement program components, which are administered by the BIA and physically located at the RO but do not fall under management of the Regional Director.  She also states the PD does not describe her work providing financial documents to support investigations conducted by the Inspector General’s office.

Based on service level agreements, the appellant is responsible for the charge card, telephone, payroll, and other reallocations, payments, collections, and obligations for the education, drug enforcement, and law enforcement program components.  Similar to her work for the RO, she performs other accounts payable, accounts receivable, and general ledger functions for the program components.  The appellant estimates spending no more than five hours a week, i.e., 15 percent of her work time, supporting the program components.  Only duties occupying at least 25 percent of an employee’s time can affect the grade of a position (Introduction, section III.J).  Moreover, although a PD does not have to be a comprehensive and detailed narrative of the position’s duties and responsibilities, we found the appellant’s work supporting the program components described in the PD.  The final duty under the major duties and responsibilities section states, “Manages the execution of relevant service level agreements (SLAs) with [the program components] providing the full range of finance and accounting operations to these entities.”

Under the General Schedule position classification system, major duties are those occupying a significant portion of the employee’s time.  They should be only those duties currently assigned, observable, identified with the position’s purpose and organization, and expected to continue or recur on a regular basis over a period of time.  Based on these criteria, we find the appellant’s PD is adequate for classification purposes, and we incorporate it by reference into this decision.

To help decide this appeal, we conducted telephone audits with the appellant on May 22, May 27, and June 26, 2014.  On July 3, 2014, we conducted a telephone interview with the Acting Deputy Regional Director for Indian Services.  In reaching our classification decision, we carefully considered all of the information gained from these interviews, as well as the written information furnished by the appellant and her agency.

Series, title, and standards determination

The appellant’s position is properly assigned to the GS-510 Accounting Series, which covers positions advising on or administering, supervising, or performing professional accounting work.  The authorized title for positions, like the appellant’s, responsible for managing the total internal accounting function of an installation or other organization is Accounting Officer.  Official documents provided by the agency are inconsistent in the titling of the position.  For example, the PD and SF 50 show the position’s title as Accounting Officer, but the latter document improperly includes an Administrative Officer title to indicate a duty previously but no longer performed by the appellant.  The appellant’s personally performed work is properly evaluated by application of the grading criteria in the Job Family Standard (JFS) for Professional and Administrative Work in the Accounting and Budget Group, GS-500.

The agency states the appellant’s position is supervisory because she spends a minimum of 25 percent of her time supervising, meeting the requirements for coverage and evaluation by the General Schedule Supervisory Guide (GSSG).  The agency evaluated her supervisory work at the GS-12 level.  The appellant indicates she supervises five positions, but the Acting Deputy Regional Director for Indian Services said management decided to allocate four subordinate positions to her branch.

The appellant’s PD designates 30 percent of her time to supervisory work, but she estimates spending 25 percent of her time supervising the two encumbered positions to include organizing work functions and directing staff to complete tasks typically performed by the vacant positions.  Literal interpretation of the work controls described and the amount of time estimated (i.e., 10 hours a week) by the appellant would result in the crediting of the encumbered positions at Level 2-2 within the Factor Evaluation System (FES).  At this level, the supervisor is closely involved in the actual work processes, e.g., by suggesting or determining work methods, advising on available source materials, and reviewing work for compliance with instructions and established procedures.  However, the PD for the GS-12 Financial Specialist position, certified as current and accurate by competent management authority, credits the position’s supervisory controls at Level 2-4 for completing assignments independently with “minimal supervision.”  The other encumbered position, a GS-5 Accounting Technician, is a developmental position generally subject to closer review and supervision.  The developmental stage is temporary with supervisory controls lessening as the position progresses to the full performance level.  This is confirmed by a review of the full performance level GS-7 PD, also certified as current and accurate by competent management authority, crediting the position’s supervisory controls at Level 2-3 for performing routine, recurring assignments independently within established deadlines.  Crediting the subordinate positions with Level 2-2 would have a negative grade-level impact.

The appellant’s assertions that the GS-12 Financial Specialist directs team members and performs other quasi-supervisory work further undermine the estimate of spending 25 percent of her time supervising two encumbered positions.  Thus, we conclude she does not currently spend the minimum amount of time supervising to meet GSSG coverage requirements.  Regardless, her current expenditure of time on supervisory work, as it is a transitory situation, does not represent the baseline percentage of supervisory work performed on a continuing basis when the branch is fully staffed.  The agency must verify the appellant’s position spends the requisite minimum amount of time for coverage by the GSSG when all branch positions are filled, or take appropriate steps to classify it as a nonsupervisory position if the organization’s vacancies are subsequently eliminated.  For our purpose of fully addressing the classification concerns of the appellant, we presume her supervisory work will occupy at least 25 percent of her work time on the administrative and technical direction of the four branch positions, and we evaluated this work by application of the GSSG.

Grade determination

Evaluation using the GS-500 JFS

The GS-500 JFS uses the FES format, under which factor levels and accompanying point values are assigned for each of the nine factors.  Under the FES, each factor-level description demonstrates the minimum characteristics needed to receive credit for the described level.  If a position fails to meet the criteria in a factor-level description in any significant aspect, it must be credited to a lower level unless the deficiency is balanced by an equally important aspect that meets a higher level.  The total points assigned are converted to a grade level by use of a grade conversion table in the JFS.

The agency’s evaluation statement classifies the appellant’s nonsupervisory work at the GS-13 grade level, crediting her position at Levels 1-8, 2-5, 3-4, 4-5, 5-4, 6/7-3d, 8-1, and 9-1.  We concur with the agency’s determination for Factors 3, 5, 6, 8, and 9.  Our evaluation, though briefly addressing the levels assigned to the uncontested factors, will focus on the remaining factors.

Factor 1, Knowledge Required by the Position

This factor covers the nature and extent of information or facts the employee must understand to do acceptable work (e.g., steps, procedures, practices, rules, policies, regulations, and principles) and the nature and extent of the skills needed to apply the knowledge.

At Level 1-7, accounting positions require professional, comprehensive knowledge of theories, practices, methods, and techniques of accounting and, as required, auditing; and organizational or program practices, policies, and functions sufficient to:  independently plan and conduct a variety of assignments or investigations; analyze accounting systems or modify and adapt conventional accounting and analytical techniques to solve a variety of accounting problems; develop or modify methods and techniques to resolve a variety of auditing problems; and/or independently conduct the complete range of tax examinations and related investigations of a broad range of business taxpayers such as sole proprietorships, partnerships, fiduciaries, and sizable corporations.

At Level 1-8, accounting positions require mastery of professional knowledge of the theory, concepts, principles, and practices of accounting and, as required, financial and performance auditing, tax auditing, and financial management sufficient to conduct difficult assignments involving interfaces and inter-relationships between and among programs, systems, functions, policies, and various issues, e.g.:  design new and changing system and program environments due to new laws, regulations, and standards; conceive new approaches to existing programs; operate new and old systems concurrently; establish programs central to the mission of the agency; resolve problems of vital importance to the agency where there are conflicting economic and public interests; apply advanced technology, as necessary; comprehensively plan, analyze, determine cost/benefit relationships, and coordinate a great variety of functions, operations, teams, or interfacing administrative systems; resolve issues where governing laws and regulations are highly interpretive and/or precedents are non-existent, obscure, or conflicting; plan and coordinate problem resolutions that involve a number of organizational entities; develop creative solutions to controversial problems; develop new systems for tax examination, tax management control, and tax documentation systems; conduct examinations that require an integrated analysis of intricate and complex accounting systems, business activities, and financing over a broad range of industries, occupations, and specialized entities; and/or develop and apply unique or extensive probing and analysis techniques and methods.

The agency credited the appellant’s position at Level 1-8, but we find the knowledge required of her work meets Level 1-7 which describes operating accounting work characteristic of her position.  Similar to this level, the appellant’s position requires professional, comprehensive knowledge of accounting theories, practices, methods, and techniques sufficient to independently plan and conduct a variety of assignments including reviewing financial documents, verifying or establishing funding authorizations, ensuring sufficient funds for obligations or commitments, and maintaining numerous accounts.  In addition, her position is nearly identical to an illustration in the JFS at Level 1-7 of an accountant requiring professional, comprehensive knowledge of theories, practices, methods, and techniques of accounting to function in the following work situation or the equivalent:

Monitors accounting systems covering operations and expenses for such items as payroll, travel, transportation, supplies, rents, services, inventory, or commercial accounts.  Participates in decision-making sessions and advises a number of program managers on regulatory requirements, financial policies, the interpretation of data, and program improvements through analysis of program operations, monthly reports, and special systems edits.

The appellant’s position does not meet Level 1-8, which describes staff or systems accounting work, i.e., developing accounting policies, regulations, and guidelines or designing and developing complete accounting systems.  Her accounting program is operated and managed locally within the parameters of the agency’s centrally developed and controlled accounting system.  In contrast to Level 1-8, the development and promulgation of accounting policy is neither within the realm of the appellant’s authority nor is it within the scope of the RO’s mission.  Her work is limited to modifying the existing accounting system to accommodate new data elements; providing enhanced capabilities for displaying or manipulation data; addressing the adequacy of the system design, the adequacy of current data in providing financial information, or ways to use the system to satisfy information requirements; etc.  However, the appellant’s position does not require mastery of professional knowledge of the theory, concepts, principles, and practices of accounting to conduct difficult assignments, as described at Level 1-8, equivalent to designing new and changing systems and program environments due to new laws, regulations, and standards; establishing programs central to the mission of the agency; resolving problems of vital importance to the agency where there are conflicting economic and public interest; resolving issues where governing laws and regulations are highly interpretive and/or precedents are non-existent, obscure, or conflicting; or developing and applying unique or extensive probing and analysis techniques and methods.

The JFS provides illustrations at Level 1-8 of accountant positions requiring mastery of a professional knowledge of the theories, concepts, principles, and practices of accounting to conduct difficult assignments in the following work situations or the equivalent:

Serves as staff expert on foreign military sales.  Coordinates the resolution of accounting system problems arising from factors such as changes in legislation, and recent changes in the status of the country’s needs and financial condition.  Develops policies with respect to financing program operations, determining accounting system adequacy, and qualifying cooperating businesses and other aspects of the program.  Develops regulations and guidelines for program users.

Develops and maintains a complex of automated subsystems to produce accounting and financial information on a worldwide system for the acquisition, distribution, and use of oil, gasoline, and aviation fuel.  Applies knowledge of legislation, regulations, and automated systems software to define systems specifications and to evaluate proposals to integrate the accounting system with administrative support and functional program information systems.

As the agency’s technical accounting authority, develops justification for agency financial/accounting policy; provides senior level agency coordination of accounting issues such as the appropriate accounting to treat different agency business lines as if they were corporate subsidiaries; and decides whether and how to recognize and report contingent liabilities for decommission of production facilities.

The appellant coordinates with program offices to ensure compliance when a change in law, regulation, or policy occurs.  Should a question arise regarding the interpretation of a legal or regulatory issue that cannot be resolved internally, she will refer the matter to attorneys, the BIA’s Deputy Chief Financial Officer, or other appropriate authoritative source.  So unlike the first illustration of a staff expert on foreign military sales, the appellant’s position does not require developing such specialized policies on the scale of foreign military sales with respect to financing the program operations, determining accounting system adequacy, and qualifying cooperating businesses.  Further, the DOI rolled out the new FBMS accounting system in 2012.  The appellant served on a committee with representatives from the DOI, BIA, and other ROs to discuss the implementation of the system.  She specifically served on a group tasked with considering the accounts payable function in the FBMS environment.  While the agency developed computer-based training for all staff at the initial FBMS rollout phase, the appellant was responsible for ensuring RO staff completed the training and responded to questions regarding the new accounting system.  She makes suggestions for improvement to the FBMS, for example, recommending to the agency’s systems experts that the system allow staff, other than those individuals responsible for processing the action, to view the status of payments.  Unlike the second illustration, the appellant does not develop and maintain a complex of automated subsystems to produce accounting and financial information on a worldwide system, applying knowledge of legislation, regulations, and automated systems software to define systems specifications and to evaluate proposals to integrate the accounting system.  Her position entails making systems improvement recommendations, but it is not vested with responsibility for reviewing, sorting, and deciding which recommendations to adopt for implementation.  Also unlike the third illustration, the appellant is an operating accountant for one of BIA’s 12 ROs and does not serve as an agency-level technical accounting authority to develop justification for agency financial/accounting policy, providing senior level agency coordination of accounting issues.

Level 1-7 is credited for 1,250 points.

Factor 2, Supervisory Controls

This factor covers the nature and extent of direct or indirect controls exercised by the supervisor, the employee’s level of independence and personal responsibility, and how the work is reviewed or controlled.

At Level 2-4, the supervisor outlines overall objectives and available resources.  The employee and supervisor, in consultation, discuss timeframes, scope of the assignment including possible stages, and possible approaches.  The employee is fully experienced in applying concepts and methodologies and is knowledgeable in functional program characteristics and requirements.  The employee also is a technical authority with responsibility for these types of actions:  planning and carrying out the assignment, directing other functional specialists, resolving most of the conflicts that arise, coordinating the work with others as necessary, interpreting policy and regulatory requirements, developing changes to plans and/or methodology, and/or providing recommendations for improvements in order to meet program objectives.  The employee keeps the supervisor informed of progress and of potentially controversial matters.  Such matters may include these types of issues:  major problems in completing accounting systems development or installation, the possibility of fraud or items of major impact on other audit or examination efforts or agency program areas, the need for supplemental appropriations, and/or inability to meet key budget and program deadlines.  The supervisor reviews completed work for soundness of overall approach, effectiveness in meeting requirements or expected results, the feasibility of recommendations and adherence to requirements.  The supervisor does not usually review methods used.

At Level 2-5, the supervisor provides administrative and policy direction in terms of broadly defined missions or functions of the organization.  The employee is responsible for a significant program or function.  The employee defines objectives, interprets policy promulgated by authorities senior to the immediate supervisor, and determines their effect on program needs.  Additionally, the employee independently plans, designs, and carries out the work to be done.  The employee is a technical authority.  The supervisor’s review of the work covers such matters as fulfillment of accounting, auditing, examination, finance, or budget program objectives and the effect of advice, influence, or decisions on the overall program.  The supervisor usually evaluates the employee’s recommendations for new systems, methods, projects, or program emphasis in light of the availability of funds, personnel, equipment capabilities, priorities, and available resources.  Also, the supervisor rarely makes significant changes to the employee’s work.

The agency credited the appellant’s position at Level 2-5, but we find the level of responsibility under which she works meets Level 2-4 instead.  As at Level 2-4, she is fully experienced at applying concepts and methodologies and is knowledgeable in the functional program characteristics and requirements to develop and maintain the RO’s financial management and accounting procedures.  As a technical authority, the appellant is responsible for actions such as planning and carrying out the assignment, directing other functional specialists, resolving most conflicts that arise, coordinating the work with others as necessary, interpreting policy and regulatory requirements, and providing recommendations for improvements in order to meet the branch’s program objectives.  Also like Level 2-4, she keeps the supervisor informed of progress and of potentially controversial matters.  For example, she provides the supervisor with a weekly report including completion of all account receivables, payroll corrections, and other significant accomplishments; status of work; and requests for additional staff to complete the branch’s work.

The appellant’s PD describes her supervisory controls as follows:

The incumbent works under the general supervision of the Deputy Regional Director, Indian Services, within the [Region] who provides broadly defined mission goals, high level direction, and administrative supervision.  The incumbent has broad latitude for independent judgment and action, and is expected to independently plan and carry out work in all phases of accounting operations to meet deadlines.

The appellant’s supervisory controls approach Level 2-5 in that the review of her work is primarily administrative and focus on matters such as fulfillment of the branch’s accounting and finance objectives and general program direction rather than on technical aspects of the work.  The supervisor, who is an engineer rather than a professional accountant, does not make significant changes to her work.  The appellant keeps the supervisor informed of progress, potentially controversial matters, and situations requiring his assistance (e.g., to request field offices timely forward utility bills and other invoices).  Regardless, neither the absence of immediate supervision for day-to-day operations nor the fact that technical recommendations are normally accepted serves to support a level above Level 2-4.  Implicit in Level 2-5 is a degree of program management authority not delegated to the appellant’s position.  For example, she does not operate within the parameters of broadly defined missions to independently plan, design, and carry out major program activities.  The appellant serves as an operating accountant for the RO’s accounting and financial management branch.  As a result, her position does not involve such work as recommending new systems or program emphasis that would lend itself to the administrative direction described at Level 2-5.  In short, Level 2-5 does not merely represent a high degree of technical independence but also a corresponding management role, beyond the authority vested in the appellant’s position, to define the basic content and operation of the program beyond the technical aspects of discrete assignments or groups of assignments.

Level 2-4 is credited for 450 points.

Factor 3, Guidelines

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

The appellant’s position meets Level 3-4, where the guidelines and policies are scarce, very general in nature, pertain to routine issues and matters, and are stated in terms of goals rather than approach.  Documentation of work done in earlier assignments is not available or applicable because of changes in subject matter or objectives.  The employee devises new methods and techniques for acquiring information and analyzing data or modifying systems to accept new kinds of data.  Likewise, the appellant’s work involves constantly changing lines of accounting and appropriations, thus precedent work is often inapplicable.  She responds to frequent requirements to accommodate new data elements or provide additional accounting capabilities.

The appellant’s position does not meet Level 3-5, where guidelines consist of broad policy statements, basic legislation, laws, regulations, and agency goals.  Often the guidelines originate from more than one Federal department or agency.  They may require extensive interpretation to effect agency-specific policy statements, regulations, and instructions.  The employee exercises broad latitude to interpret the intent of applicable guides.  Often the employee has peer recognition as a technical authority in a field of accounting with responsibility for developing policy, standards, and guidelines for use by other accountants within agencies or within functional areas that cross agency lines.  Unlike the appellant’s position, Level 3-5 describes assignments where the employee is responsible for developing agency-level policies, regulations, and guidelines.

Level 3-4 is credited for 450 points.

Factor 4, Complexity

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

At Level 4-4, work consists of varied duties that require applying many different and unrelated processes and methods to a broad range of activities or to activities that entail substantial depth of analysis.  The employee must originate new techniques, establish criteria, and develop new information to carry out the following types of assignments:  analyzing program operations for impact upon the accounting or financial management system; analyzing program trends or anomalies in accounting system transactions and their significance to ongoing agency programs or commercial operations; analyzing specific problem areas arising within the accounting system or program operations and devising solutions through accounting system redesign; planning, coordinating, and conducting audits and developing reports on work processes and accounting systems; evaluating the current status of accounting or reporting systems or operating programs; conducting examinations that involve accounting systems peculiar to a particular market segment or industry; and/or researching and analyzing information to establish the proper interpretation and application of pertinent tax laws.

The employee at Level 4-4 must also make decisions and resolve problems that require considerable innovation and origination such as in the following examples:  determining the nature and extent of problem areas; developing recommendations that fit particular situations given that there may be a variety of solutions; effectively presenting alternative solutions and/or critical findings to management; deciding which aspects of program operations to evaluate and report on and the approaches to use in collecting and structuring data; and/or applying specialized tax laws and investigative techniques, and applying standard methods to find information pertaining to taxpayer income and financial operations.  The employee must make these decisions in a work environment characterized by these types of conditions:  complex and variable programs; the resistance of program officials or participants to findings; variability in the way programs and systems are set up or operated; the resistance of taxpayers to audit findings and information presented; the need to sort out convoluted factual situations and to apply a variety of tax laws and regulations to determine discrepancies; and/or new requirements, regulations, or legislation.

At Level 4-5, work consists of performing varied duties that require resolving particularly difficult and complex problems in highly responsible circumstances.  Work involves such functions as problem definition, intensive planning, coordination of many activities, and comprehensive analysis of a great variety of functions and operations.  The employee is engaged in a wide variety of activities, including:  advising a number of directors and preparing a number of regular and recurring special purpose reports; working with a variety of accounting systems or environments where there is significant interface with automated management systems; serving as an expert or authority in some aspect of accounting or in the application of accounting to some mission-related program(s); developing audit plans and defining problem areas for the comprehensive analysis of the overall operations of an organizational entity to predict the effects of proposed policies; conducting examinations that include investigating accounting records reflecting the complete range of reorganizations, mergers, leveraged buyouts, capitalization, or other similar business transactions; and/or conducting examinations that involve points of law, that are without precedent and that require intensive and extensive legal research to locate cases and evaluate potential effects of decisions or interpretations.

The employee at Level 4-5 must be innovative and adept at conceiving new strategies for solving problems.  The employee must make decisions that are complicated by the presence of these types of issues, conditions, and matters:  the diversity of systems that must be integrated into a single system; the need to interpret administration policies and legislation covering highly sensitive programs; the number and variability of administrative support and specialized functional programs serviced; the extreme diversity of functional programs and operations and their related accounting and control systems; the conflicting requirements inherent in balancing cost against requirements when addressing major agency programs having numerous goals or end products; the need to establish criteria when advising other accountants and/or auditors on the application of accounting and auditing principles and practices in a major functional area; and/or the many business transactions engaged in by the taxpayer, points of law without precedent, conflicting legal requirements, and undefined issues requiring extensive probing and analysis.

The agency credited the appellant’s position at Level 4-5, but we find the complexity of her position meets Level 4-4 instead.  Similar to Level 4-4, she performs a range of activities including reviewing and reconciling the RO’s commitments and obligations in a complex, dynamic program environment with many lines of accounting and multiple sources of funding to include appropriated and non-appropriated (e.g., revolving, reimbursable, and administrative fee account) funds.  Her work requires accommodating different types of data within the automated system when resolving frequent discrepancies related to funding authorizations.  In addition, the appellant’s work is comparable to the illustration in the JFS at Level 4-4 of an accountant, involved in one accounting system, analyzing system effectiveness, and trends or anomalies in accounting system transactions and their significance to ongoing agency programs and commercial operations.  Also like this illustration, her work entails advising management on changes to functional program workflow practices or procedures; better internal controls, greater detail, redesign of reports, or faster consolidation of data; and how to satisfy regulatory requirements, reduce costs, eliminate waste and fraud, or improve operations.  The appellant’s decisions require assessing a variety of conditions inherent in the operation of the accounting system, the complexity and variability of support programs, user transactions, new requirements, and the various accounting approaches available as described in this illustration.

The complexity of the appellant’s position does not meet Level 4-5.  Unlike her position, Level 4-5 describes work involving accounting systems design and development (i.e., in “highly responsible circumstances”) and serving as an expert and resource for other accountants.  Accountants at this level generally work with a number of different programs utilizing different accounting systems and advise both the directors of those programs and their operating accountants on broad accounting policies and requirements.  In contrast, the appellant analyzes accounting and financial data to identify and resolve specific rather than broad issues relating to, e.g., monitoring program funds to prevent shortages resulting in rejection of payments, ensuring the validity of requests for payment from vendors and contractors, and confirming payments collected are placed into the appropriate fund.  The appellant regularly uses the FBMS accounting system incorporating payroll, charge card, miscellaneous pay, motor pool, accounts receivable, general ledger, and other functions.  While she may use the U.S. Department of the Treasury’s Invoice Processing Platform for electronic payments to vendors, the General Services Administration’s Telecommunication Ordering and Pricing System for electronic payment of telephone services, and the non-trust transaction platform in the legacy accounting system as the FBMS has yet to establish functionality for such transactions, unlike Level 4-5, the appellant primarily works within the one FBMS total accounting system covering all her supported programs.

The appellant is also not responsible for the broad systems design and development work expected at Level 4-5, nor is she considered an accounting expert in the sense of advising other accountants at lower levels in the organization.  In contrast to her position, an illustration in the JFS at Level 4-5 describes an accountant providing expert and authoritative advice on the application of accounting principles, and the design and development of accounting systems for specialized agency missions and programs.  Also unlike this illustration, the appellant does not solve accounting problems in particularly difficult and responsible circumstances where difficulties are due to the operation of a variety of accounting systems interfacing with automated management information systems and where the accounting systems require continual revision due to changing program information needs and interfaced system requirements.  Instead, the appellant deals with accounting problems and issues, typical of an operating rather than advisory setting, relating to the research of charge card transactions and bills for services; review of charge card statements, payment vouchers, obligations and de-obligations, and utility payments; and update of accounts and the effects of accounting transactions on the operation of program offices found at Level 4-4.  Other work she performs reflective of Level 4-4 complexity includes gathering and forwarding financial documents to support investigations conducted by the Inspector General’s office, responding to Congressional inquiries regarding status of payments and other matters, and monitoring accounts and coordinating when necessary with program offices to ensure the adequacy and appropriateness of fund status.  This and other work does not require being innovative or adept at conceiving new strategies for solving problems as described at Level 4-5.

Level 4-4 is credited for 225 points.

Factor 5, Scope and Effect

This factor covers the relationship between the nature of the work; i.e., the purpose, breadth, and depth of the assignments, and the effect of work products or services both within and outside the organization.

The scope and effect of the appellant’s position meets Level 5-4, where work involves executing modifications to systems, programs, and/or operations, and/or establishes criteria and other means to assess, investigate, or analyze a variety of unusual problems and conditions.  Accounting work at this level involves planning and executing modifications to these types of activities and programs:  accounting systems, accounting program operations; and the management, control, and flow of accounting system input documents and source data.  At Level 5-4, the work affects the amount and availability of funds for major substantive or administrative programs and services, e.g., conducting regulatory and enforcement programs within a region or comparable area.  Similarly, the appellant’s work involves developing and maintaining the RO’s financial management and accounting procedures, which entails executing modifications for accounting program operations to accommodate different types of data and reporting requirements, coordinating the resolution of problems and conditions from the conventional to the unusual, and controlling and managing the flow of accounting system input documents and source data.  Her work affects the reliability and timeliness of accounting data and ultimately the availability of funds for the RO’s programs and services.

The appellant’s position does not meet Level 5-5.  At this level, work involves isolating and defining unknown conditions, resolving critical problems, and developing new theories.  Accounting work at this level involves solving significant problems in the development of accounting systems or coordinating the work of other accountants and computer specialists in developing and installing new systems or managing accounting programs.  Level 5-5 applies to positions at higher levels in an organization’s accounting hierarchy where the employee is responsible for systems development or for providing staff-level guidance to operating accounting officials.  In contrast, the appellant is an operating accountant and, as such, her position does not require her to perform work of Level 5-5 scope and effect.

Level 5-4 is credited for 225 points.

Factors 6 and 7, Personal Contacts and Purpose of Contacts

Personal contacts include face-to-face and telephone contacts with persons not in the supervisory chain.  Levels described under this factor are based on what is required to make the initial contact, the difficulty of communicating with those contacted, and the setting in which the contact takes place.  These factors are interdependent.  The same contacts selected for crediting Factor 6 must be used to evaluate Factor 7.  The appropriate level for personal contacts and the corresponding level for purpose of contacts are determined by applying the point assignment chart for Factors 6 and 7.

Personal Contacts

At Level 3, contacts are with executives, officials, managers, professionals, and/or taxpayers including corporation officials, and employees of other agencies and outside organizations and businesses.  Contacts are not routine or recurring at Level 3 and require recognizing or learning the role and authority of each party during the course of the contact.  Similar to the examples provided in the JFS at Level 3, the appellant’s contacts are with other Federal agencies, representatives of State and local Government, various levels of agency management such as policy review boards at higher levels in the agency, and Congressional staff members making inquiries under the conditions described at that level.  Her personal contacts meet but do not exceed Level 3.

Purpose of Contacts

The agency credited the appellant’s position at Level d.  However, we find her position meets Level c, where the purpose of contacts is to influence, motivate, interrogate, or control persons or groups when there is wide disagreement on the merits of a proposed action, or when persons contacted are fearful or uncooperative.  Examples provided in the JFS at Level c include:  persuading program managers and other officials in positions of decision-making authority with widely differing goals and interests to follow a recommended course of action consistent with established budget/financial management policies, objectives, or regulations.  Another example includes influencing or persuading others to the employee’s point of view regarding the merits of a technical accounting method, concept, or procedure when others hold strongly opposed points of view.  Similar to Level c, the purpose of the appellant’s contacts is to influence, persuade, and control persons where opposing viewpoints on a proposed action exist when, for example, dealing with higher-level managers, administrative officers, and others to resolve disagreements related to funding authorizations and availability.

The appellant’s position does not meet Level d where the purpose of contacts is to present, justify, defend, negotiate, or settle matters involving significant or controversial issues.  The persons contacted typically have diverse viewpoints, goals, or objectives.  This situation requires that the employee work with the contacts to achieve a common understanding of the problem.  Often the employee must negotiate a compromise or develop suitable problem resolution alternatives.  Generally, the topics under discussion involve long range issues or problems.

In contrast, the purpose of the appellant’s contacts does not involve presenting, justifying, defending, negotiating, or settling significant or controversial matters as described at Level d.  As the accountant for the RO, her position is not vested with the level of authority required to perform duties characteristic of the examples provided in the JFS of significant or controversial issues typical of Level d, to include:  defending alternative methods of financing substantive program operations or the redistribution of appropriated funds and programs among components immediately below agency or equivalent level; negotiating and resolving controversial financial and program issues of considerable significance that are not susceptible to resolution at lower echelons in Government; justifying the overall direction to be given for the organization’s financial management, budgeting, accounting, or auditing programs; justifying proposed changes to achieve major economies; or justifying proposed revisions to standards and guides for complex programs or activities.  Further, the purpose of the appellant’s contacts typically involves resolving specific technical accounting or financial management issues rather than the long-range issues or problems expected at Level d.

Level 3c is credited for 180 points.

Factor 8, Physical Demands

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

Similar to Level 8-1, the appellant’s work is primarily sedentary and does not involve any special physical effort.  Some work may require periods of walking, bending, carrying of light items, or driving an automobile.  Level 1-8 is credited for 5 points.

Factor 9, Work Environment

This factor considers the risks and discomforts in the employee’s physical surroundings or the nature of the work assigned and the safety regulations required.

Similar to Level 9-1, the appellant’s work environment consists of an adequately lit, heated, and ventilated area.  Her work involves the everyday risks or discomforts of an office or automobile setting and requires normal safety precautions.  Level 9-1 is credited for 5 points.

Summary
Factor Level Points
1.  Knowledge Required by the Position 1-7 1250
2.  Supervisory Controls 2-4 450
3.  Guidelines 3-4 450
4.  Complexity 4-4 225
5.  Scope and Effect 5-4 225
6. & 7.  Personal Contacts and Purpose of Contacts 3-c 180
8.  Physical Demands 8-1 5
9.  Work Environment 9-1 5
Total 2,790

 

A total of 2,790 points falls within the GS-12 range (2,755 to 3,150) on the grade conversion table provided in the JFS.

Evaluation using the GSSG

The GSSG is used to determine the grade of supervisory positions in grades GS-5 through GS-15.  The GSSG employs a factor-point evaluation method that assesses six factors common to all supervisory positions.  To grade a position, each factor is evaluated by comparing the position to the factor-level description for that factor and crediting the points designated for the highest factor level which is fully met, in accordance with the instructions specific to the factor being evaluated.  The total points assessed under all factors are then converted to a grade by using the grade conversion table in the GSSG.

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 credit a particular factor level, the criteria for both scope and effect must be met.  Each successively higher factor-level description represents additional demands beyond those expressed at the next lower level.

In evaluating the population affected under this factor, we may only consider the total population serviced directly and significantly by a program.  We cannot count the total population in the geographic area potentially covered by a program.

            Scope

At Level 1-2, the program segment or 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 multimission military installation also falls at this level.

The scope of the appellant’s position meets Level 1-2.  Similar to this level, she directs work of an administrative and technical nature, directly affecting the approximately 500 employees assigned to the RO and its field offices.  The appellant directs the financial and accounting services provided to the RO’s eight program offices, its field offices, and the population supported from the SLAs.  Like her position, the illustration at Level 1-2 describes directing budget, management, staffing, supply, maintenance, protective, library, payroll, or similar services which support a small Army, Navy, or Air Force base with no extensive research, development, testing, or comparable missions, a typical national park, a hospital, or a nondefense agency field office of moderate size and limited complexity.

The appellant’s position does not meet the intent of Level 1-3 given the total population serviced.  Her branch is a staff support function for the RO; thus, the population directly and significantly impacted by the branch is the RO and field office workforce with its estimated 500 employees.  Unlike Level 1-3, the work directed by the appellant does not involve providing complex administrative services directly affecting a large or complex multimission military installation or the equivalent as defined by the GSSG (i.e., a total serviced employee-equivalent population exceeding 4,000 personnel engaged in a variety of serviced functions).

Scope is evaluated at Level 1-2.

            Effect

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), the work directly involves or substantially impacts the provisions of essential support operations to numerous, varied, and complex technical, professional, and administrative functions.

The effect of the appellant’s position meets Level 1-2.  As at this level, her work significantly affects the accounting and financial operations, functions, and activities of the RO.  Her branch provides financial and accounting services to a moderate, local, or limited population of customers equal to a major portion of a small city or rural county or small to medium size agency field office described at Level 1-2.

The effect of the appellant’s position does not meet Level 1-3 in that the work does not significantly impact a wide range of agency activities, the work of other agencies, or the actual operations of outside interests such as segments of an entire industry as expected at Level 1-3.  Instead, the effect of the branch’s work is limited to the activities of the RO, local businesses, or small segments of a particular industry.  The appellant’s position also falls short in terms of the diversity and scale of functions envisioned by the Level 1-3 requirement that work involve or substantially impact operations to numerous, varied, and complex technical, professional, and administrative functions.  Her work affects an RO with coverage in Montana and Wyoming, engaged in water resources, natural resources, forestry and fire, and other types of work.  However, the impact of this type of engagement falls short of Level 1-3 where work involves operations characterized as “numerous, varied, and complex” technical, professional, and administrative functions such as that carried out at a large military installation with large-scale and diverse technical functions (e.g., contracting for depot-level repair and overhaul of complex weapons systems).

Effect is evaluated at Level 1-2.

Since both Scope and Effect are credited at Level 1-2, 350 points are assigned.

Factor 2, Organizational Setting

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

At Level 2-2, the position is accountable to a position that is one reporting level below the first SES, flag or general officer, or equivalent or higher level position in the direct supervisory chain.

At Level 2-3, the position is 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.

The agency credited the appellant’s position at Level 2-3, but we find her position meets Level 2-2.  As at Level 2-2, she is directly accountable to the Deputy Regional Director for Indian Services, a GS-340-15 position that is one level below the first SES position (i.e., the Regional Director).

Level 2-2 is credited for 250 points.

Factor 3, Supervisory and Managerial Authority Exercised

This factor considers the delegated supervisory and managerial authorities 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.

In order to meet Level 3-2, a position must meet any one of the conditions described in paragraphs a, b, or c under this factor level.  Supervisors at Level 3-2c must carry out at least three of the first four, and a total of six or more of the 10 responsibilities listed at that level in the GSSG.  Based on our review of the record, we agree the position fully meets Level 3-2c; as this is contested by neither appellant nor agency, we will not address the responsibilities further but incorporate them by reference into this decision.

In order to fully meet Level 3-3, a position must meet the conditions described in paragraphs a or b, under this factor level.

Level 3-3a describes managerial positions, unlike the appellant’s position, with authority to devise long-range staffing needs, and are closely involved with high-level program officials (or comparable agency-level staff personnel) in developing overall goals and objectives related to high levels of program management and development or formulation.  The appellant serves as a first-level supervisor for an organization without the subordinate organizational units or subordinate supervisors envisioned of an organizational setting at Level 3-3a and does not exercise the significant and extensive program authority defined at that level.

At Level 3-3b, a supervisor must exercise all or nearly all of the supervisory responsibilities and authorities described at Level 3-2c, plus at least 8 of the 15 responsibilities listed under Level 3-3b of the GSSG.  The appellant’s position exercises all 10 of the responsibilities described at Level 3-2c.  Of the 15 responsibilities listed under Level 3-3b, her duties and responsibilities are compared below.

Responsibilities 1, 3, 5, 6, and 8 refer to situations where work is accomplished through subordinate supervisors, team leaders, or other similar personnel.  Supervisors at this level exercise these responsibilities through multiple subordinate supervisors or team leaders.  Further, the supervisor’s organizational workload must be so large and work so complex that it requires using two or more subordinate supervisors, team leaders, or comparable personnel to direct the work.  The appellant is a first-level supervisor and the record confirms her staff does not include such positions.  Given the organizational workload of 4.0 staff years is not so large and the work is not so complex that it requires using subordinate supervisors, team leaders, or comparable personnel to direct the work.  Therefore, the appellant’s position is not credited with these responsibilities.

Regarding the remaining authorities, responsibility 2 is credited because the appellant exercises significant responsibilities when dealing with the branch chiefs, administrative officers, and others from the RO’s program offices and advising management officials of higher rank as discussed in the PD of record.

Responsibility 4 is not credited because the appellant does not direct a program with multi-million dollar resources directly under her discretion and control.  Instead, she controls the branch’s operating budget estimated for fiscal year 2014 at $304,458 which accounts for the salary of staff and training, supplies, and other discretionary funds.

Responsibility 7 is credited to positions making or approving selections for subordinate nonsupervisory positions.  When filling vacancies, the appellant conducts interviews with applicants and makes recommendations.  Her supervisor is the selecting official with authority to approve selections for the branch.  Since the appellant does not make or approve selections, responsibility 7 is not met.

The size of the organization directed by the appellant precludes her from exercising responsibilities 9, 10, and 11 on a regular basis at the level intended by the GSSG; i.e., hearing and resolving group grievances or serious employee complaints; reviewing and approving serious disciplinary actions (e.g., suspensions); and making decisions on nonroutine, costly, or controversial training needs and training requests.  Even putting aside the rarity of such situations occurring, the appellant’s position lacks authority to independently approve suspensions and other serious performance- or conduct-based actions.  Beyond the informal level, higher-level supervisors would become involved.

Responsibility 12 is not credited because the appellant does not oversee the work of contractor personnel.

Responsibility 13 is credited because the appellant has authority to approve expenses equal to within-grade increases, extensive overtime, and employee travel.  The immediate supervisor explained the Regional Director delegated to the appellant’s position and other branch heads with authority to approve all overtime.  The appellant confirmed her staff works overtime to offset the branch’s vacancies.  Since she has authority to also approve within-grade increases and employee travel, responsibility 13 is met.

Responsibility 14 is credited to positions recommending awards or bonuses for nonsupervisory personnel and changes in position classification, subject to approval by higher level officials, supervisors, or others.  Although she recommends awards or bonuses for nonsupervisory personnel, the appellant’s organization does not present the opportunity for making regular and recurring recommendations regarding classification changes to branch positions.  Responsibility 14 is not met.

Responsibility 15 involves finding and implementing ways to eliminate or reduce significant bottlenecks and barriers to production, promote team building, or improve business practices.  The size of the appellant’s team, to currently include two encumbered and two vacant positions, precludes her from the need to fully exercise responsibility 15 on a regular basis as intended by the GSSG.  Her responsibility does not exceed that described under authority 9 credited at Level 3-2c (i.e., find ways to improve production or increase the quality of the work directed).  Responsibility 15 is not met.

Based on the information above, the appellant performs only 2 of the 15 responsibilities listed under Level 3-3b.  Because her position does not meet Level 3-3a, or are 8 of the 15 responsibilities listed in Level 3-3b, Level 3-2 is assigned and credited 450 points.

Factor 4, Personal Contacts

This is a two-part factor assessing 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 the personal contacts.  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.

The appellant’s contacts meet Level 4A-2.  At this level, frequent contacts are comparable to any of the following:  (1) members of the business community or the general public; (2) higher 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; (3) representatives of local public interest groups; (4) case workers in Congressional district offices; (5) technical or operating level employees of State and local Governments; and (6) 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 contacts, and sometimes require nonroutine or special preparation.  Similar to Level 4A-2, the appellant has frequent contact with higher ranking managers, supervisors, and staff of program, administrative, and other work units throughout the RO, its field offices, and the SLA-supported components; members of the business community; and counterparts representing State, local, or county Government.  Her contacts occasionally require special preparation in order to explain operations, problems, and available options.

The appellant’s contacts do not meet Level 4A-3.  At this level, frequent contacts are comparable to any of the following:  (1) 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; (2) key staff of public interest groups (usually in formal briefings) with significant political influence or media coverage; (3) journalists representing influential city or county newspapers or comparable radio or television coverage; (4) Congressional committee and subcommittee staff assistants below staff director or chief counsel levels; (5) contracting officials and high level technical staff of large industrial firms; and (6) 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.

In contrast, the appellant’s frequent contacts are with RO branch chiefs including two GS-14, five GS-13, and one GS-12 positions; GS-12 and GS-13 administrative officers at the field offices; administrative assistants; contract specialists; and procurement staff.  She also has regular contact with vendors and other members of the business community, treasurers of tribal organizations, and technical accounting and finance personnel at the BIA and other Federal agencies.  Unlike Level 4A-3, her contacts are not frequently with high ranking civilian managers, supervisors, and technical staff at bureau and major organization levels of the agency, with agency headquarters administrative support staff, or comparable personnel in other Federal agencies.  The appellant’s contacts do not often require extensive preparation of briefing materials or up-to-date familiarity with complex subject matter as described at Level 4A-3.

Level 4A-2 is credited for 50 points.

Subfactor 4B:  Purpose of Contacts

This subfactor includes the advisory, representational, negotiating, and commitment responsibilities related to the supervisor’s contacts.

The appellant’s position meets Level 4B-2, where the purpose of contacts is to ensure that information provided to outside parties 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.  Similar to this level, the purpose of her contacts is primarily to resolve technical issues concerning specific finance and accounting matters.

The appellant’s position does not meet Level 4B-3, where the purpose of contacts is to justify, defend, or negotiate in representing the project, program segment(s), or organization unit(s) directed, in obtaining or committing resources, and in gaining compliance with established policies, regulations, or contracts.  Contacts at this level usually involve active participation in conferences, meetings, hearings, or presentations involving problems or issues of considerable consequence or importance to the program or program segment(s) managed.  In contrast, the purpose of the appellant’s contacts is normally to resolve technical issues and questions concerning, e.g., regulatory interpretations, documentation requirements, coordination of work with program offices, and resolution of operating problems.  Her contacts may involve interpretations as to whether Federal funds may be used, but these and other contacts do not reflect the frequent need to justify, defend, or negotiate over policies and regulations or significant resource questions at conferences, meetings, hearings, or presentations expected at Level 4B-3.  The appellant occasionally attends conferences, meetings, hearings, or presentations concerning significant issues, but the frequency of the meetings and the authority to commit resources required for crediting Level 4B-3 are not present in her position.

Level 4B-2 is credited for 75 points.

Factor 5, Difficulty of Typical Work Directed

This factor measures the difficulty and complexity of the basic work most typical of the organization directed, as well as other line, staff, or contracted work for which the supervisor has technical or oversight responsibility.

To evaluate first-level supervisors, the GSSG instructs determining the highest grade of basic (mission oriented) nonsupervisory work performed that constitutes 25 percent or more of the workload of the organization.  The following types of work are specifically excluded from the workload calculation:  work graded on the basis of supervisory or leader duties, work for which the supervisor does not have the minimum supervisory and managerial authorities defined under Factor 3, and lower-level support work primarily facilitating the basic work of the unit.

The following list shows the workload currently assigned to the branch and supervised by the appellant:

             GS-12

1          Financial Specialist, GS-501

             GS-9

1          Financial Specialist, GS-501

             GS-7

2          Accounting Technician, GS-525

Total nonsupervisory mission-oriented workload is 4.0.  The percentage of nonsupervisory mission-oriented workload potentially at each grade level is as follows:

GS-12:             25%

GS-9:               25%

GS-7:               50%

The agency concludes the base level of work for the appellant’s organization is GS-9, stating in its evaluation of her supervisory work:  “Majority of mission oriented work is performed at the GS-7 level, GS-9 Financial Specialist requires more supervisory time spent on oversight than GS-12 level.”  Since the GS-12 grade level appears to represent 25 percent of the nonsupervisory work performed by the branch as indicated above, we carefully considered the GS-12 PD which shows the position directs and develops team members and performs other leader type responsibilities.  The appellant confirms the GS-12 position performs such quasi-supervisory work, which the GSSG instructs such work is specifically excluded from the workload calculation.  Since the GS-12 level only minimally meets the 25 percent threshold to establish that as the base grade level of the branch, that the position performs any leader work, regardless of amount, would take it below the 25 percent threshold it had minimally met.  Thus, we find the GS-9 work, at 25 percent, fully representative of the highest level of nonsupervisory work performed by the appellant’s branch.

Level 5-5 is credited for 650 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.  If the level selected under this factor is 6-1, 6-2, or 6-3, and if three or more of the eight Special Situations described are met, the original level selected is increased by one level.  If the level selected is 6-4, 6-5, or 6-6, the Special Situations do not apply and the original level selected is credited.

The appellant’s position meets Level 6-3a, where supervision and oversight requires coordination, integration, or consolidation of administrative, technical, or complex technician or other support work comparable to GS-9 or 10.  The work directed requires the coordination and integration of work efforts, ensuring consistency of product, service, interpretation, or advice; conformance with the output of other units, with formal standards or agency policy.  As at Level 6-3a, the appellant’s supervisory work requires coordination, integration, and consolidation of administrative and technical work equivalent to the GS-9 grade level.

The appellant’s position does not meet Level 6-4a, where supervision requires substantial coordination and integration of a number of major work assignments, projects, or program segments of professional, scientific, technical, or administrative work comparable in difficulty to the GS-11 level.  As discussed under Factor 5, we find the base level of work for the appellant’s branch is the GS-9 level, not the GS-11 level as expected at Level 6-4a.

Since Level 6-3 was selected, the Special Situations section was considered as required.  Because the appellant’s position meets none of the eight complicating situations identified (Variety of Work, Shift Operations, Fluctuating Work Force or Constantly Changing Deadlines, Physical Dispersion, Special Staffing Situations, Impact of Specialized Programs, Changing Technology, and Special Hazard and Safety Conditions), we will not discuss them further.

Level 6-3a is credited for 975 points.

Summary
Factor Level Points
1.  Program Scope and Effect 1-2 350
2.  Organizational Setting 2-2 250
3.  Supervisory & Managerial Authority Exercised 3-2 450
4.  Personal Contacts
A.  Nature of Contacts 4A-2 50
B.  Purpose of Contacts 4B-2 75
5.  Difficulty of Typical Work Directed 5-5 650
6.  Other Conditions 6-3 975
Total 2,800

 

The total of 2,800 points falls within the GS-12 range (2,755 – 3,150) on the grade conversion table provided in the GSSG.

Decision

By comparison with the GS-500 JFS and the GSSG, the appellant’s position is properly classified as Accounting Officer, GS-510-12.

 

 

 

 

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