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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

Patrick S. Friend
Lead Auditor
Program Review Branch
Division of Financial Management
Office of Management Services
Bureau of Public Debt
Department of Treasury
Parkersburg, West Virginia

Lead Auditor

Robert D. Hendler
Classification and Pay Claims
Program Manager
Merit System Audit and Compliance



As provided in section 511.612 of title 5, Code of Federal Regulations (CFR), this decision constitutes a classification certificate which 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 5 CFR 511.605, 511.613, and 511.614, as cited in the Introduction to the Position Classification Standards (Introduction), appendix 4, section G (address provided in appendix 4, section H).


On July 28, 2011, the Chicago Oversight Office of OPM accepted a classification appeal from Mr. Patrick S. Friend.  The appeal was subsequently transferred to the Philadelphia Oversight office on February 13, 2012.  The appellant’s position is currently classified as Lead Auditor, GS-511-13, which the appellant believes should be upgraded to GS-15.  The position is located in the Program Review Branch (PRB), Division of Financial Management, Office of Management Services (OMS), Bureau of Public Debt (BPD), Department of Treasury, in Parkersburg, West Virginia.  We received the agency administrative report (AAR) on August 22, 2011 and have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C).

We conducted telephone interviews with the appellant and his supervisor on March 5, 2012, and interviewed the BPD acting Chief Financial Officer (CFO) on March 8, 2012.  In reaching our classification decision, we have carefully considered all of the information obtained from the interviews, as well as all other information of record provided by the appellant and his agency.


The appellant has worked for BPD for over 10 years and has served as a Lead Auditor since 2005.  Since 2006, he has served as the Assessment Team Project Lead for BPD’s portion of the Office of Management and Budget (OMB) A-123 Appendix A, Assessment of Internal Control Over Financial Reporting (A-123 Assessment).  The appellant contends the large scope, complexity, and deliverables of this assessment, some of which go to Treasury and the Government Accountability Office (GAO), warrant a classification of GS-511-15 for his position.  He also contends, for this assessment, he performs team leader (TL) duties over employees in positions at the GS-13, GS-14, and GS-15 grade-levels, which also warrants a classification of GS-511-15 for his position.  In January 2011, the appellant requested the Human Resources Branch, OMS review the classification of his position.  In April 2011, the HR Specialist who conducted the desk audit met with the appellant to discuss the results of the audit and explain his position was properly classified as GS-511-13 Lead Auditor.  The appellant subsequently filed this appeal with OPM.

General issues

In his appeal to OPM, the appellant raises several issues he believes should be considered in determining the classification of his position:  impact of an inaccurate position description (PD) which does not reflect all of his duties; issues not germane to the appeal process, including conduct of his management and servicing human resources (HR) staff; equal pay for equal work; classification consistency; and impact of the person on the job. 

Inaccurate PD

The appellant is one of three employees assigned to PD # 07P315, dated November 30, 2006.  While the appellant’s supervisor attests to the accuracy of his PD, the appellant does not agree his official PD accurately reflects the duties of his position.  The appellant states his PD focuses on the duties of a Lead Auditor in the PRB overseeing Federal Managers Financial Integrity Action (FMFIA) reviews of internal management controls and does not adequately address the duties of his role as PRB’s assessment team lead for the A-123 Assessment. 

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 work made up of the duties and responsibilities performed by an employee.  Position classification appeal regulations permit OPM to investigate or audit a position and decide an appeal on the basis of the actual duties and responsibilities assigned by management and performed by the employee (5 CFR 511.607(a)(1) and 609).  An OPM appeal decision classifies a real operating position, and not simply the PD.  Therefore, this decision is based on the actual work assigned to and performed by the appellant.

Issues Not Germane to the Appeal Process

In his appeal to OPM, the appellant describes what he terms as unethical behavior on the part of his management; raises concerns about his agency’s conduct, specifically his servicing HR staff’ conduct, toward him as a result of his questioning the classification of his position; describes overtime worked; alleges impropriety on the part of agency management in his non-selection for a promotion; makes various statements about his agency’s review and evaluation of his position and treatment of him; and describes health issues he alleges are the result of this treatment.

In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of the appellant’s position.  By law, we must classify positions solely by comparing his current duties and responsibilities to OPM standards and guidelines (5 U.S.C. 5106, 5107, and 5112).  Eligibility for promotion to higher graded positions, disputes concerning overtime pay, the appellant’s concerns regarding his work environment and the appellant’s assertions regarding “unethical behavior” of agency management are not germane to the position classification process.  Since our decision sets aside any previously issued agency decision, any actions previously taken by the agency in its review of the appellant’s position are not germane to this classification appeal process.

Equal Pay for Equal Work

In his response to the AAR, the appellant states because he is responsible for overseeing the A-123 Assessment team, which includes positions at the GS-13, GS-14, and GS-15 grade-levels, the principle of equal pay for equal work applies.  The classification appeal process provides for determining the proper series, title, and grade of the position under appeal.  It does not extend to resolving the compensation issues raised by the appellant.  Therefore, we will not address those issues further in this decision.

Classification Consistency

In documentation provided with his appeal, the appellant alludes to classification inconsistency.  The appellant did not list any specific positions to support his claim, but instead highlighted portions of the Introduction which he provided with his appeal.  By law, we must classify positions solely by comparing their current duties and responsibilities to OPM position classification standards and guidelines (5 U.S.C. 5106, 5107, and 5112).  Since comparison to the standards is the exclusive method for classifying positions, we cannot compare the appellant’s current duties to other positions, which may or may not be classified properly as a basis for deciding his appeal.  Furthermore, many positions perform major duties classifiable at more than one grade level.  This is addressed in the Introduction, III.J:

Some positions involve performing different kinds and levels of work which, when separately evaluated in terms of duties, responsibilities, and qualifications required, are at different grade levels.  The proper grade of such positions is determined by evaluation of the regularly assigned work which is paramount in the position.

 In most instances, the highest level work assigned to and performed by the employee for the majority of time is grade-determining. When the highest level of work is a smaller portion of the job, it may be grade-controlling only if:

-          The work is officially assigned to the position on a regular and continuing basis;

-          It is a significant and substantial part of the overall position (i.e., occupying at least 25 percent of the employee's time); and

-          The higher level knowledge and skills needed to perform the work would be required in recruiting for the position if it became vacant.

Work which is temporary or short-term, carried out only in the absence of another employee, performed under closer than normal supervision, or assigned solely for the purpose of training an employee for higher level work, cannot be considered paramount for grade level purposes.

Impact of the Person on the Job

In his appeal request to OPM, the appellant mentions his unique qualifications for his position.  He also included a copy of the Introduction in which he had highlighted sections pertaining to impact of the person of the job.  The concept of impact of the person on the job is addressed in both the Introduction and The Classifier’s Handbook.  This concept holds that, by virtue of exceptional competence, an employee may have such an impact on the duties, responsibilities, and qualification requirements of a position that it is changed to the point where its classification must also be changed.  On the other hand, the mere fact an individual in a position possesses higher qualifications or stands out from other individuals in comparable positions is not sufficient reason by itself to classify the position to a higher grade.  When determining grade level based on this concept, it is essential management recognizes and endorses the duties and the work environment allows continuing performance at a different level.  Neither the appellant nor officials of his agency provided evidence impact of the person on the job should be a factor in evaluation of the appellant’s position.  That is, his performance actually makes the duties of the appealed position materially different from what they otherwise would be.  Based on the analysis which follows, we find the appellant is performing the work described in his PD of record.

Position information

The BPD is a small agency within the Department of Treasury.  It is responsible for borrowing the money needed to operate the Federal government through the sale of Treasury bills, notes, and bonds, as well as U.S. Savings Bonds.  It also accounts for the resulting debt and provides reimbursable administrative and information technology services to Federal agencies.  There are six offices within BPD:  Administrative Resource Center (ARC), Office of Public Debt Accounting (OPDA), Office of Financing (OF), Office of Information Technology (OIT), Office of Retail Securities (Retail), and OMS.

The mission of OMS is to provide Bureau-wide policy and program direction, guidance, leadership, and advice to BPD management on matters pertaining to BPD’s administrative activities.  Within OMS is the Program Review Branch, which consists of a manager and twelve auditor/accountants, including three team leads and eight staff auditors.  A significant portion of PRB’s responsibilities involve the administration of the requirements of the FMFIA and OMB A-123, which require periodic assessments and reporting on the status of an agency’s internal controls.  According GAO, internal controls are an integral component of an organization’s management which provide reasonable assurance the following objectives are being achieved:  effectiveness and efficiency of operations; reliability of financial reporting; compliance with applicable laws and regulations; and safeguarding of assets.  There are five broad categories of internal controls including:  managerial controls; program/operational controls; administrative controls; financial controls; and accounting controls.

Within PRB, the appellant serves as a Lead Auditor for two GS-511-12 auditors.  According to his PD, the appellant’s major duties include:  leading reviews as part of BPD’s internal control and financial management programs, including reviews under FMFIA and OMB Circulars A-123 and A-127; leading and coordinating the annual review of BPD’s financial report controls in accordance with OMB Circular A-123, Appendix A; leading special studies of BPD operations or systems as requested by management; and leading or performing internal control reviews on programs or activities, such as the Public Transportation Incentive program, the Child Care Assistance Program, Specimen Securities Prompt Pay, Safekeeping Instruments, or Unissued Registered Stock. 

In his role as team leader for reviews or management requested studies, the appellant is responsible for performing the following for lower-graded auditors within the PRB:  articulating the overall and individual assignments to team members; distributing and balancing workload as necessary among team members; coaching and providing training to team members as needed; planning, developing, coordinating, guiding, directing, and critiquing the work of lower-graded auditors; establishing priorities and timeframes for completion of tasks; performing quality control reviews on work performed by team members; identifying applicable guidelines and reference materials; defining the scope, objectives, and tasks to be performed in conducting the review; presenting review results to and preparing reports for management; and working with technical staff and operating managers within BPD to facilitate required changes or implement recommendations identified in reviews.  The appellant also provides appraisal input to his supervisor, the PRB Manager, on the performance of lower-graded auditors as requested.

The appellant states his PD is inaccurate because it focuses primarily on his duties as a Lead Auditor overseeing FMFIA Management Control Reviews, rather than addressing his duties as BPD’s Team Lead for the A-123 Assessment.  The FMFIA reviews are a detailed examination of an assessable unit’s management control system to determine whether adequate management controls exist and are implemented.  For these reviews, the appellant leads a team of two to three GS-511-12 Auditors in planning and completing the review for one assessable unit within BPD, which represents approximately 1/22nd of BPD’s overall operations, using the TL duties described above.  During these reviews, the appellant and the lower-graded GS-12 auditors conduct interviews with BPD staff and develop testing controls for procurement functions.  They then provide a report of their findings to BPD management.  The entire process takes between four and six months. 

The appellant led one FMFIA review in 2010 and another in 2006.  In addition to the FMFIA reviews, the appellant has worked on some other small-scope, ad hoc assignments for management, such as reviewing financial systems, overseeing the tracking of all BPD audit findings, which are compiled by a GS-12 auditor, and doing audit coordination for other evaluations.  However, the appellant’s primary duty since 2006 has been to lead the A-123 Assessment.  The appellant and his supervisor state he spends nearly 100 percent of his time working on the A-123 Assessment, which includes overseeing the work of the other PRB auditors assigned to that project.

The A-123 Assessment is a result of the Sarbanes-Oxley Act of 2002 which set new standards for all public companies and public accounting firms, requiring strengthened processes for assessing and reporting internal control over financial reporting.  The assessment provides assurance on the effectiveness of management’s internal controls over financial reporting and is used as the basis for the BPD Commissioner’s assertion on financial controls in the Annual Assurance Statement to Treasury.  Both the appellant and his supervisor state while the testing of transactions for the assessment runs from February to July, the planning, reporting, and orchestrating of corrective actions for each assessment causes it to be nearly a year-long process.

For the A-123 Assessment, OMB provides guidance to all applicable agencies through OMB Circular A-123, Management Responsibility for Internal Control, Appendix A.  Treasury uses this guidance to develop its own annual Guidance and Implementation Plan, which includes a “five part methodology in executing the assessment that must be completed and followed.”  The five parts include:  (1) documenting and testing core financial processes; (2) reviewing the financial reporting processes; (3) self-assessing overall adherence to the internal control standards; (4) reviewing regulatory compliance; and (5) reviewing the resolution of any audit findings on financial reporting over the past year.  While this broad plan methodology is  applicable to all bureaus within Treasury, the plan also provides some specific guidance, including test types, sample transactions, and test sample size.  BPD uses the Treasury plan to develop its Implementation Plan for OMB A-123, Appendix A, Internal Control Over Financial Reporting. 

The appellant and his supervisor both state the PRB Manager is responsible for developing BPD’s A-123 Implementation Plan, initially developed it in 2006.  They also agree this document remained mostly unchanged, except for minor changes to the methodology section, which the appellant stated he updated periodically as Treasury and GAO requirements changed, until 2010 at which time the PRB Manager updated it with input from the appellant.  Both the appellant and his supervisor state BPD’s methodology cannot stray from the guidance provided by Treasury.  They may increase sample sizes or negotiate with Treasury to have some specific transactions tested every three years, as opposed to every year.  However, Treasury must approve this change in methodology.  Usually, the appellant would meet with a Treasury, or sometimes even GAO, A-123 Assessment Coordinator to get their approval on a proposed change.  While the appellant may be the one to meet with coordinators, he would discuss proposed changes with his supervisor prior to the meeting, per his supervisor and the acting BPD CFO.  The appellant and his supervisor also state the guidance from Treasury, for the most part, adequately addresses their methodology questions; however, when it does not, the appellant will contact the Treasury’s A-123 Assessment Coordinator for further guidance.  While in his appeal to OPM, the appellant stated he independently plans and oversees the entire annual assessment, the BPD Implementation Plan as well as the PRB Manager’s PD state  the PRB Manager is responsible for coordinating the assessment.  Additionally, the appellant states he reports to his supervisor  any significant or unusual circumstances concerning the A-123 Assessment.

Although BPD charges PRB with leading the A-123 Assessment, all five offices within BPD participate.  Both the appellant and his supervisor state the Senior Assessment Team, which is led by BPD’s CFO and consists of the heads of each of the offices within BPD, assigns members to the assessment team each year.  The size of the team has grown each year since the inception of the assessment in 2006.  For FY 2010, there were a total of 25 BPD employees, including the appellant and his supervisor assigned to the assessment team.  The team members include employees in the following grades from each BPD office: 

      PRB:         GS-511-13 (appellant), GS-511-14 (appellant’s supervisor), and two employees in GS-511-12 positions

      OPDA:      GS-301-15, GS-510-13, GS-343-13, and GS-510-12

      ARC:         GS-510-14, GS-505-14, and four employees in GS-510-13 positions

      RETAIL:   GS-301-14, GS-343-13, GS-510-13, and three employees in GS-510-12 positions

      OIT:          GS-2210-12

      OF:            GS-1101-14, GS343-13, and two employees in GS-1101-13 positions

The appellant contends that he performs TL duties over all the BPD employees assigned to the A-123 Assessment Team.  However, his supervisor states he only performs these duties for the two lower-graded team members from the PRB.  Additionally, the BPD Implementation Plan states the Senior Assessment Team is responsible for assigning resources and delegating specific responsibilities to knowledgeable staff in their organizations. 

In preparing for the A-123 Assessment, the appellant receives a list of transactions from the Treasury A-123 Assessment Coordinator.  These transactions are selected by Treasury because they have high dollar amounts; so much so that if they were executed incorrectly, they could affect Treasury’s consolidated financial statement.  The appellant reviews the transactions to determine if they really are appropriate for the test sample based on Treasury’s guidance.  If he determines they are not appropriate for the sample, he notifies the Treasury A-123 Assessment Coordinator and explains why he believes they should be left out of the sample.  He also reviews the transactions to determine from which of the six offices within BPD they originated.  This is how he determines which office will be responsible for reviewing the transactions, as each office may only review transactions they originated.

When the appellant’s supervisor developed the BPD Implementation Plan in 2006, he and the BPD’s CFO decided to have testing and review conducted only by the office in which the transactions originated.  According to the appellant and his supervisor, the appellant does not assign transactions to specific individuals in other offices within BPD, but merely assigns the work to the office.  It is up to the management of each office to assign the work to individuals.  OPDA tends to have the largest workload for the review.  The team members from OPDA stated they spent approximately 85-95 percent of their time working on the A-123 Assessment.  The members of the Retail office estimated they spent 20-25 percent of their time on the assessment.  The appellant estimated the ARC, OIT, and OF offices spent 5-10 percent of their time on the assessment and the lower-graded auditors in PRB spent 70-75 percent of their time on the assessment.

Upon reviewing and assigning the transactions to their originating offices, the appellant will often have a team meeting to start the A-123 Assessment in which he discusses the background and purpose of the assessment with the team.  However, in 2010, he decided in conjunction with his supervisor to forgo the meeting and instead meet individually with team members, as necessary to discuss testing methodology.  The appellant is responsible for designing test plans for the PRB to ensure the key controls within a financial process are adequate and are being complied with and for reviewing and approving the test plans and results of testing performed by other offices within BPD.  The methodology for testing varies depending on the type of transactions being tested.  However, it usually consists of a review of a transaction from its initiation to its completion and falls into one of the following test types:  (1) inspecting the evidence of a given control (e.g., looking for signatures or a reviewing official or reviewing past reconciliations); (2) observing actual controls in operation (e.g., observing a physical inventory or watching a reconciliation occur); or (3) re-performing a given control (e.g., recalculating an estimate or re-performing a reconciliation.)  While the testing techniques the appellant develops may be unique to the assessments, his supervisor and the acting CFO state they are based on existing accounting and testing techniques.

During the testing phase of the assessment, the appellant answers questions from team members in all offices of BPD on the appropriateness of their testing techniques and performs some testing of transactions himself, although he states he spends much less time doing this than he does developing and reviewing test plans.  He also answers questions from team members and reviews their testing results.  He typically reviews transactions from OF due to the extremely large transactions and associated risks involved and performs (or re-performs) some testing of transactions in other offices, particularly large transactions from OPDA to ensure the testing is being performed appropriately.  The appellant also follows up with team members to determine the status of testing to ensure BPD will be able to provide all required information to Treasury in a timely manner.  He usually gives team members a due date for their deliverables several days prior to the Treasury due date in order to give himself time to review and consolidate the data.  He then provides the deliverables to his supervisor for his review prior to forwarding the documents outside of PRB.  He sends some documents to the BPD CFO for his signature, while he sends other deliverables directly to Treasury.  The appellant also meets with GAO A-123 Assessment Coordinators upon completion of BPD’s testing to brief them on their results. 

In his appeal, the appellant cited obtaining the approval of the BPD CFO and sending deliverables to Treasury as an indicator of his higher level work.  He emphasized his interactions with BPD’s CFO and implied that he reports to the CFO.  However, as previously stated, the appellant reports to the PRB Branch Manager, a GS-511-14 Supervisory Auditor.  The appellant acts independently to resolve problems of a technical nature pertaining to the operation and administration of assigned projects.  However, he would report to his supervisor if he encountered difficult situations or if there were problems he could not solve.  His work is reviewed by his supervisor for compliance to policy.  His supervisor conducts this review prior to the appellant forwarding reports, correspondence, and other documentation to higher-level managers within BPD, the A-123 Senior Assessment Team, Treasury headquarters, or GAO.   

Series, title, and standard determination

The agency has placed the appellant’s position in the GS-511 Auditing Series and titled it Auditor based on application of the Job Family Position Classification Standard (JFS) for Professional and Administrative Work in the Accounting and Budget Group, 0500.  The agency also decided the position meets the requirements for designation as a leader under the General Schedule Leader Grade Evaluation Guide (GSLGEG) and added the prefix “Lead’ to the position’s title.  Therefore, the position is officially titled Lead Auditor.  The appellant does not contest the title, series determination, or standards used and, based on careful analysis of the record, we concur.  However, the record shows the appellant provided highlighted and annotated copies of the Introduction, the General Schedule Supervisory Guide (GSSG), and an analysis of his position which he conducted himself using the Primary Standard (PS) and the GSSG.  Additionally, the appellant provided numerous out of context references to a variety of classification standards and documents, which have no bearing on our analysis or decision.  Therefore, we will only address the larger classification issues raised by the appellant.  

            Coverage under the GSSG

By submitting an analysis of his position using the GSSG, the appellant appears to imply this standard should be used in classifying his position. 

To be covered by the GSSG, a supervisory position must meet all three of the following requirements: (1) requires accomplishment of work through the combined technical and administrative direction of others; (2) constitutes a major duty occupying at least 25 percent of the position’s time; and (3) meets at least the lowest level of Factor 3 in the GSSG based on supervising Federal civilian employees, Federal military or uniformed service employees, volunteers, or other non-contractor personnel.  The appellant does not serve as the supervisor of record for any employees and, therefore, does not meet any of the above three requirements.  The appellant’s assigned leadership responsibilities are less than the minimum supervisory authority described at Level 3-2 of Factor 3 in the GSSG.  Therefore, the work of the appellant is not covered by and may not be graded by using the GSSG. 

            Coverage under the PS

By submitting an analysis of his position using the PS, the appellant appears to imply this standard should be used in classifying his position. 

As discussed in the Classifier’s Handbook, the law requires each position be classified to the appropriate series and grade according to standards issued by OPM.  Only if no directly applicable standard has been issued, then positions must be classified consistent with OPM standards covering other occupations.  The 0511 Auditing series is incorporated into the JFS for Professional and Administrative Work in the Accounting and Budget Group, 0500.  The PS serves as a “standard-for-standards” for the Factor Evaluation System (FES).  Factor level descriptions for position classification standards are point rated against the PS.  Thus, it serves as a basic tool for maintaining alignment across occupations and may be used in conjunction with a directly applicable standard, but may not be used in lieu of it.  Therefore, the work of the appellant is properly graded through reference to the 0500 JFS and GSLGEG. 

Grade determination

As previously discussed, while the appellant implies the PS and GSSG should be applied to determine the classification of his position, he does not expressly disagree with his agency’s application of the GS-500 JFS and the GSLGEG to determine the proper grade for his position.  Therefore, we will address his position’s work in comparison to both standards. 

Evaluation using the GS-0500 JFS

The GS-0500 JFS is written in the FES format.  Grades are determined by comparing a position’s duties, responsibilities, and qualification requirements to the nine FES factors.  A point value is assigned to each factor based on a comparison of the position’s duties and responsibilities with the factor-level descriptions in the standard.  The points assigned to an individual factor level mark the lower end of the range for that factor-level.  Each factor-level description represents the minimum or threshold for that factor-level.  To warrant a given level, the position must fully equate to the overall intent of the factor-level description.  If the position fails in any significant aspect to fully satisfy a particular factor-level description, the point value for the next lower level must be assigned, 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 standard.

Occupation and specialty-specific factor illustrations provided within the GS-500 JFS are used as a frame of reference for applying factor-level concepts.  However, the JFS states that an evaluation is not to rely solely on comparison to illustrations because they may reflect a limited range of actual work experience, and the level of work described may be higher than the threshold for a particular factor-level.

The agency applied the GS-500 JFS grading criteria and credited the appellant's position with Levels 1-8, 2-4, 3-4, 4-5, 5-5, 6-3, 7-C, 8-1 and 9-1.   The appellant believes his position should be credited with Levels 1-8, 2-5, 3-5, 4-6, 5-6, 6-4, 7-D, 8-1 and 9-1.  Based on careful analysis of the entire record, we concur with the crediting of Levels 8-1 and 9-1.  We will address the remaining factors.

Factor 1, Knowledge required by the position

This factor measures the nature and extent of information or facts a worker must understand in order to do acceptable work and the nature and extent of skills needed to apply that knowledge. To be used as a basis for selecting a level under this factor, the knowledge must be required and applied.  The agency credited the position at Level 1-8, and the appellant does not disagree.  However, as discussed below, the rationale provided by the agency for its decision to credit Level 1-8 does not fully address all the requirements described at that level.

At Level 1-7, employees have a 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; and/or develop or modify methods and techniques to resolve a variety of auditing problems.

The illustrations for the Auditing series at this level describe professional, comprehensive knowledge of theories, practices, methods, and techniques of accounting and auditing; and knowledge of organizational or program practices, policies, and functions sufficient to independently plan and conduct a variety of assignments or investigations and to develop or modify methods and techniques to resolve a variety of auditing problems and to function in the following work situations (or the equivalent):

Independently audits the operations and accounts of contractors to determine the basis for cost setting under a variety of contracts, such as cost reimbursable, price determinable, fixed price, and incentive type contracts.

Reviews an organization’s appropriation accounts maintained at an installation’s finance and accounting office.  Accounts cover such activities as operations and maintenance; research, development, test, and evaluation; foreign military sales; and new construction.  Identifies any overspending, and the propriety of obligations and expenditures.

Develops methods to isolate and identify conditions affecting mission capability, susceptibility to fraud, and the potential for increased efficiency.  Assesses the potential to reduce cost in a variety of programs, projects, and functions such as information technology, financial management, acquisition, and logistics systems.

At Level 1-8, employees have a mastery of a 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; 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 illustrations for the Auditing series at this level describe required mastery of a professional knowledge of the theories, concepts, principles, and practices of accounting, financial auditing, and financial management sufficient to conduct difficult assignments involving interfaces and inter-relationships between and among programs, systems, functions, policies, and various issues and to function effectively in the following work situations (or the equivalent):

Serves as the agency technical expert in a wide variety of agency audit program management functions.  Analyzes and interprets legislation and agency policies. Coordinates with other Federal audit organizations such as GAO to develop agency guidance in audit program areas and to monitor new and interrelated agency-level systems and organizations.  Establishes review criteria to improve efficiency of audit activities.

Conducts broad audit assignments requiring integrated analysis of a number of different accounting systems.  Chooses audit areas to be covered and plans audit efforts in different locations and at different organizational management levels.  Plans often involve coordination with outside agencies.  Develops new audit approaches where no precedent exists.  Works with highly interpretive laws and regulations, and targets audits at highly controversial problems.  Audits may require an extended period of time (e.g., more than one year) to complete.  Additionally, the audits may involve shaping major programs, compliance with new legislation, or facilitating the resolution of long-standing problem areas of vital importance to the agency.

Conducts audits of the agency’s electronic information systems and information systems used by the participants of agency programs such as investment companies, contractors, lenders, and small businesses.  Identifies and targets system weaknesses.  Develops accessing methods and statistical and mathematical models to identify abnormalities and system vulnerabilities.  Devises innovative auditing techniques.  Audits cover all major financial and management aspects of agency programs.  Findings are critical for annual and long-range planning of agency functions and influence agency policies and legislative proposals.

To correctly interpret and apply Level 1-8, these illustrations must be read in conjunction with the preceding factor-level description for Level 1-8 and, when necessary with Level 1-8 as defined in the PS to confirm its intended meaning.  Level 1-8 of the PS describes work requiring a mastery of a professional or administrative field to apply experimental theories and new developments to problems not susceptible to treatment by accepted methods; or make decisions or recommendations significantly changing, interpreting, or developing important public policies or programs; or equivalent knowledge and skill.

The agency credited the appellant’s position at Level 1-8 based on his knowledge of and ability to apply a wide variety of accounting principles and his knowledge of BPD’s accounting systems and their relationship to the operations of the Federal Reserve Banks and certain government agencies.  However, this level of knowledge is described by Level 1-7, rather than Level 1-8.  As described in Level 1-7, the appellant plans, develops, and coordinates audits to comply with such legislation and regulations as the FMFIA and OMB directives.  Like Level 1-7, the appellant develops testing methods to isolate and identify conditions affecting mission capability and susceptibility to fraud and independently audits the operations and accounts of organizations within BPD, as part of the , FMFIA and A-123 Assessments.

The  appellant states his position should be credited with Level 1-8 because of the complexity and criticality of the A-123 Assessment, because he has knowledge sufficient to pioneer efforts in areas where no precedent exists, and because of issues of a Government-wide scope are of a primary focus to his work.  The complexity of the assessment will be discussed further in Factor 4.  Additionally, to properly credit a  level, it is necessary to determine the actual degree of knowledge required to perform the work assigned to and performed by the position’s occupant.  While the appellant may have knowledge sufficient to pioneer efforts in areas where no precedent exists, this is not required of his position.  Although the appellant develops testing techniques specifically for the A-123 Assessment, they are based on existing accounting and testing techniques and, therefore, do not meet the intent of Level 1-8, which describes developing new audit approaches where no precedent exists.  While the OMB A-123 Appendix A, Assessment of Internal Control Over Financial Reporting affects multiple agencies, the appellant receives guidance for this assessment from his agency in the form of the Treasury Guidance and Implementation Plan and from BPD in the form of the BPD Implementation Plan.  Thus, the appellant work does not require or permit him to resolve issues where governing laws and regulations are highly interpretive and/or precedents are non-existent, obscure or conflicting.  While the appellant states he has developed standard operating procedures (SOP) for the A-123 Assessment, he acknowledged they were for the PRB rather than all of BPD or Treasury.  Therefore, he does not develop agency guidance in audit program areas or monitor new and interrelated agency-level systems and organizations as would be expected of Level 1-8.  The record shows the appellant also does not design new and changing systems, conceive new approaches to existing programs, operate new and old systems concurrently, or establish programs central to the mission of the agency. 

The appellant’s position meets but does not exceed Level 1-7 and is credited with 1250 points.

Factor 2, Supervisory controls

This factor covers the nature and extent of direct or indirect controls exercised by the supervisor or another individual over the work performed, the employee’s responsibility, and the review of completed work.  The supervisor determines what information the employee needs to perform the assignments; e.g., instructions, priorities, deadlines, objectives, and boundaries.  The employee’s responsibility depends on the extent to which the supervisor expects the employee to develop the sequence and timing of the various aspects of the work, to modify or recommend modification of instructions, and to participate in establishing priorities and defining objectives.  The degree of review of completed work depends upon the nature and extent of the review; e.g., close and detailed review of each phase of the assignment; detailed review of the completed assignment; spot check of finished work for accuracy; or review only for adherence to policy. The primary components of this factor are:  How Work Is Assigned, Employee Responsibility, and How Work Is Reviewed.

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.  At this level, 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 and is a technical authority.  At this level, 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.

Similar to Level 2-4, the appellant carries out most work independently, consulting with his supervisor as necessary to receive initial direction and report on major problems encountered.  The appellant is responsible for planning and carrying out assignments, such as the A-123 Assessment and FMFIA reviews; directing other lower-graded auditors; resolving most of the conflicts that arise amongst those lower-graded auditors; coordinating work with others as necessary; interpreting policy and regulatory requirements; and keeping his supervisor informed of progress and of potentially controversial matters.  In addition, the appellant’s PD states his work is reviewed for compliance with policy, which is also similar to Level 2-4.

The appellant asserts his position should be credited with Level 2-5 because he receives broad guidance on the A-123 Assessment from Treasury and “the supervisor’s review (BPD CFO) of the work covers such matters as fulfillment of accounting, auditing, examination, finance, or budget program objectives.”  However, as previously stated, the appellant’s supervisor, the PRB Branch Manager, not the BPD CFO, assigns the appellant work and reviews for compliance to policy.  Level 2-5 is not met because the appellant does not exercise the extent of program and/or functional authority implicit at this level.  Level 2-5 does not merely represent a high degree of technical independence, but also a corresponding management role that is well beyond the authority vested in the appellant’s position.  It is derived not only from the technical latitude afforded, but also from the position’s role in the organization and the authority delegated to the employee to define the basic content and operation of the program beyond the technical aspects of discrete assignments.  While the appellant states he is responsible for defining the objectives of the A-123 Assessment and interprets policy promulgated by OMB and Treasury, the objectives of the assessment are defined by OMB and Treasury and further defined for his bureau under the BPD Implementation Plan, which was written by his supervisor.  Furthermore, the manner in which his work is reviewed upon completion does not exceed Level 2-4. 

The appellant’s position meets but does not exceed Level 2-4 and is credited with 450 points.

Factor 3, Guidelines

This factor covers the nature of guidelines and the judgment employees need to apply them. Individual assignments may vary in the specificity, applicability, and availability of guidelines; thus, the judgment employees use similarly varies.  The existence of detailed plans and other instructions may make innovation in planning and conducting work unnecessary or undesirable.  However, in the absence of guidance provided by prior agency experience with the task at hand or when objectives are broadly stated, the employee may use considerable judgment in developing an approach or planning the work.

At Level 3-4, guidelines and policies are scarce, very general in nature, pertain only to routine issues and matters, are stated in terms of goals to be accomplished rather than the approach to be taken, and present a number of principles and standards any one of which may reasonably apply to the broad subject matter.  Documentation of work done in earlier assignments is not available or is not applicable because of changes in subject matter, objectives, or emphasis.  Examples of such guidance include:  OMB circulars, directives, and regulations; Treasury Department regulations; judicial decisions; Comptroller General Decisions; the employing agency’s broad program goals and policy statements that describe only the purpose for which a program or system was established; requirements that define general specifications for management and financial systems or the parameters from which an accounting system is to be defined.  At this level, the employee routinely must develop specific objectives and devise new methods, techniques, and criteria pertaining to such matters as:  identifying trends and patterns; acquiring information and analyzing data; modifying systems to accept new kinds of data; and developing solutions and presenting findings.  The employee may interpret available guidance for employees at the same or subordinate levels.

At Level 3-5, guidelines consist of such items as broad policy statements, basic legislation, laws, tax regulations, and agency goals.  Often the guidelines originate with more than one Federal department or agency.  They may require extensive interpretation to effect agency-specific policy statements, regulations, and instructions that are free of ambiguous and conflicting or incompatible goals and objectives.  These interpretations generally take the form of these types of policy statements, regulations, and instructions:  financial management policy for use throughout a department or comparable organization or throughout the Executive branch of Government; and/or guidelines on auditing contracts or on auditing regulated industries or other comparable guidelines that normally apply Government-wide.  At this level, employees must use judgment and ingenuity and exercise broad latitude in interpreting the intent of applicable guidelines.  Often the employees have peer recognition as technical authorities in a field of accounting, auditing, or taxation with responsibility for developing policy, standards, and guidelines for use by other accountants, auditors, or agents within agencies or within functional areas that cross agency lines.

The appellant asserts his position should be credited with Level 3-5 because the guidance for the A-123 Assessment provided by OMB and Treasury is broadly stated and nonspecific.  However, guidance and policies that are general in nature, such as OMB circulars and Treasury Department regulations, are expressly described in Level 3-4.  Additionally, comparable to Level 3-4, the appellant must frequently devise new methods and techniques, based on existing auditing techniques and methods, in order to conduct audits and present findings.  While the appellant’s guidance from OMB and Treasury may not exclusively apply to BPD, it is specific in describing some aspects of the assessments, including test types, sample transactions, and test sample size, which the appellant cannot stray from, except with the permission of Treasury.  This type of guidance does not meet the description of ambiguous, conflicting, or incompatible guidance described in Level 3-5.  

The appellant’s position meets but does not exceed Level 3-4 and is credited with 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 4-5, 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.

At level 4-5, employees must be innovative and adept at conceiving new strategies for solving problems and 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; and/or 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.

The illustrations for the Auditing series at this level state employees may conduct audits of agency financial management programs, operations, and activities.  They may also develop individual audit programs and plans covering in detail these matters:  functional responsibilities; specific project assignments; audit objectives and requirements; references; formats for data display and reports; and special instructions covering contingencies.  At this level, employees may also provide opinions on agency financial statements and the efficiency and effectiveness of financial programs.  Employees’ decisions and actions are complicated by the sensitivity of the issues, the range of audit targets, the judgment required to define audit boundaries, and the lack of information on potential findings and their impact on audit schedules and resource allocations.

At Level 4-6, work consists of broad or highly difficult assignments typically found at the highest organizational levels.  Work often involves such breadth and intensity of effort that several phases must be pursued concurrently or sequentially with the support of others within or outside the organization.  Additionally, work requires continuing efforts to establish concepts, theories, or programs to resolve unyielding problems that are of central importance to the mission of the department or agency.  Types of duties at this level include:  determining the effect of delaying or immediately implementing department-wide accounting systems modifications; interpreting new legislation or regulations for application to a complete system and/or for shaping requirements for a regulated industry; providing expert advice that impacts program definition and solution at several organizational levels; assessing the full cost of industrial compliance under a number of alternative accounting and reporting systems designed to provide a range of data required by a number of program elements within an agency; and/or assessing long-range (three to five year) audit program requirements for a major department to support an expanded mission and management needs for vital information.  At this level, problems are particularly stubborn due to such matters as conflicting funding priorities, economic interests, public interests, constitutional protections, or equivalent concerns.  Decisions regarding what needs to be done require extensive probing and analysis.

The illustrations for the Auditing series at this level describe planning and designing short-term and long-term audit programs and analytical reviews of the Government-wide retirement, health insurance, and life insurance programs that are operated under policy direction of the agency.  The programs involve internal agency operations, the operations of private sector firms under contract to provide services to the agency, and insurance carriers.  Employees may also shape programs to facilitate auditing and to comply with new or revised legislation in an environment of conflicting goals and private sector and public interests.  At this level, work is complicated by the sensitivities and parochial interests of stakeholders, the need to integrate analysis of a number of different functions, and the need to coordinate audits involving multiple sites, outside agencies, and private sector entities.  Recommendations may impact the structure, effectiveness, and efficiency of major programs.

Comparable to Level 4-5, the appellant’s auditing work requires performing varied duties which require resolving particularly difficult and complex problems in highly responsible circumstances.  In carrying out these audits, he must often develop new techniques, based on existing auditing methods.  Also like Level 4-5, the appellant’s auditing work requires decisions and planning which are complicated by the diversity of systems, a variety of specialized functional programs involved, and the many different types of business transactions involved.

The appellant asserts his position should be credited with Level 4-6 because “the A-123 Assessment is broad in scope and highly difficult, covering the entire BPD’s financial processes, systems controls and reporting and involves complex processes and systems and the interrelationship between financial reporting systems both within BPD and with outside agencies.”  However, the appellant’s position does not meet Level 4-6 which requires work to establish concepts, theories, or programs to resolve problems that are of central importance to a department or agency.  While the A-123 Assessment affects multiple agencies and multiple departments within Treasury, the appellant is only responsible for BPD’s portion of the assessment.  Even then, he is not solely responsible for the assessment.  It is the Senior Assessment Team which is listed as responsible for the assessment in Treasury’s and BPD’s Implementation Plans.  Additionally, the appellant does not provide advice that impacts program definitions at several organizational levels.  While he has developed SOPs, they were for the PRB rather than all of BPD or Treasury.  Further, the appellant works primarily within a one-year assessment cycle rather than the three to five year cycle required by the more complicated long-term program reviews described in Level 4-6. 

The appellant’s position meets but does not exceed Level 4-5 and is credited with 325 points.

Factor 5, Scope and effect

This factor covers the relationship between the nature of work, i.e., the purpose, breadth and depth of the assignment, and the effect of the work products or services both within and outside the organization.  Effect measures such things as whether the work output facilitates the work of others, provides timely services of a personal nature, or impacts on the adequacy of research conclusions.  The concept of effect alone does not provide sufficient information to properly understand and evaluate the impact of the position.  The scope of the work completes the picture allowing consistent evaluations.  This factor only considers the effect of properly performed work.

At Level 5-4, 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.  Work involves a wide range of agency activities or the operations of other agencies or the activities of private sector entities with which the agency conducts business or provides services.  An example of the Auditing series describes employees who develop audit approaches to evaluate a variety of programs and accounting systems.  These audit approaches vary widely because of the variability of subject programs and systems due to differences in organization or mission, technological advances, or changes in regulations.  At this level, employees prepare audit reports to provide information on program operations and to identify causes of deficiencies or problems.  They also recommend corrective actions such as modifying management systems, financial and accounting systems, workflow, and lines of authority and other corrective actions.

At Level 5-4, work involves one or more of the following outcomes:  the amount and availability of funds for major substantive or administrative programs and services, such as developing strategic weapons that are part of larger systems, constructing of housing, delivering health care services to the public, researching grants, paying benefits, conducting regulatory and enforcement programs within a region or comparable area of the nation, or operating other Federal agencies, States, public organizations, large universities, or large private industrial concerns; the budgets, programs, and interests of other Federal agencies, public organizations, and/or private industrial firms when the supported programs and/or projects cut across component lines within the employing agency; the way financial information is applied in planning organizational operations or the efficient use of funds; and/or the way management control systems, financial management accounting systems and programs are structured and operated throughout an organization and/or regulated industries with which the agency conducts business or provides services.

The illustrations for the Auditing series at this level describe employees who audit the activities of health care providers that participate in nationwide health care programs on contracts to the Federal Government and assess the soundness of their financial and management practices and their compliance with the terms of their government contracts.  At this level, employees also prepare work papers and direct input to analyses and supporting material that the auditor-in-charge uses to prepare formal audit reports.  The formal audit reports serve as evidentiary bases for the proposal of corrective action against the audited entities.  Corrective actions may require the recovery of funds, changes in financial management practices, and revisions to future rates and coverage.

At Level 5-5, work involves isolating and defining unknown conditions, resolving critical problems, and developing new theories.  An example of the Auditing series describes employees who:  study and integrate the findings of a number of audit efforts to define audit targets or develop audit criteria or new approaches for use by other auditors; provide expert advice to other auditors on the interpretation of accounting and auditing regulations and their application to controversial problems; prepare audit plans or guidelines for comprehensive examination of entire functional areas, e.g.,  the agency’s information technology activity; and make recommendations or influences decisions on programs that involve matters such as:  development, acquisition, and deployment of major strategic weapons systems; administrative delivery of a national social insurance program; administration of a major national grant-in-aid program; or improvements in business processes, organizational structure, management systems, or controversial situations.

At this level, work outcomes may have an impact in any of a variety of areas and domains such as:  major aspects of programs or missions; the well-being of substantial numbers of people; the comprehensive application of accounting principles, concepts, and techniques to developing or managing complex accounting systems; and the establishment of a definitive framework for applying audit theories, concepts, and techniques.  Examples of work outcomes include:  the acquisition, amount, distribution, and sequence of funds for important, substantive national programs on a long-term (i.e., several years) basis; the funds available to carry out agency programs, the allotment of funds to agency components and sub-components, and the rate of obligation and expenditure of funds by the employing agency; the budgets and programs of other Federal agencies, State agencies, national industries such as banking, agriculture, or defense; the development, acquisition, and deployment of major strategic weapons systems; administrative delivery of a national social insurance program; or major national or international grant-in-aid programs; the comprehensive application of accounting principles, concepts, and techniques to develop or manage complex accounting systems and resolve agency financial management problems; the establishment of a definitive framework for the application of audit theories, concepts, and techniques; or service-wide changes in interpretations, methods, and techniques used in tax examination processes that may affect the financial condition of many categories of taxpayers with very large tax responsibilities.

The illustrations for the Auditing series at this level describe employees who audit the efficiency and effectiveness of work processes carried out in a number of discrete functional organizations.  Audit approaches vary widely because of the variability of subject programs and systems, mission, applied technology, and procedures and regulations.  At this level, findings and recommendations may affect modifications to systems and procedures, and to the organizational structure. When standard systems are involved, findings may have an agency-wide impact.

The appellant asserts his position should be credited with Level 5-6, because “the A-123 Assessment involves planning, developing, and carrying out an assessment vital to the success of the Department of Treasury’s financial reporting.”  The agency credited the appellant’s position with Level 5-5 because BPD’s accounting systems and diverse programs are nationwide in scope and the reviews conducted by the appellant impact not only BPD, but also operations of the Federal Reserve System and other Federal agencies.  However, this is similar to work at Level 5-4, which involves a wide range of agency activities or the operations of other agencies or private sector entities.  Like Level 5-4, the appellant develops audit approaches to evaluate a variety of programs and accounting systems through both the FMFIA and A-123 assessments, prepares audit reports to provide information on program operations on these assessments, and recommends corrective actions as necessary. 

Level 5-5 is not met.  Similar to Level 5-4, the appellant’s FMFIA assessments address parts of BPD’s operations and, while the A-123 Assessment may encompass multiple agencies, the part for which the appellant is responsible only addresses BPD.  His assessments do not involve broader audits which require defining unknown conditions, developing new theories, or resolving critical problems.  While the appellant does develop audit approaches, which may be used by other auditors within PRB, he does not routinely develop criteria or new approaches to be used outside of PRB.  Unlike Level 5-5, the appellant’s work does not provide a definitive framework for the application of audit theories, concepts, and techniques or impact major aspects of a significant agency program.   Since the appellant’s position does not even meet Level 5-5 for the reasons described above, we will not discuss Level 5-6.

The appellant’s position meets but does not exceed Level 5-4 and is credited with 225 points.

Factors 6 and 7, Personal contacts and Purpose of contacts

These factors include face-to-face and remote dialogue (e.g., telephone, email, and video conferences) with persons not in the supervisory chain.  (Note: Personal contacts with supervisors are under Factor 2 - Supervisory Controls.)  The levels of these factors consider/take into account what is required to make the initial contact, the difficulty of communicating with those contacted, the setting in which the contact takes place, and the nature of the discourse.  The setting describes how well the employee and those contacted recognize their relative roles and authorities.  The nature of the discourse defines the reason for the communication and the context or environment in which the communication takes place.  The reason for a communication, for example, may be to exchange factual information or to negotiate.  The communication may take place in an environment of significant controversy and/or with people of differing viewpoints, goals, and objectives.

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, personal 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.  Employees must recognize or learn the role and authority of each party during the course of the meeting.  Examples of contacts at this level include:  representatives of contractors; attorneys and accountants of business firms; representatives of state and local governments; administrators, professors, and staff of universities and hospitals; other Federal agencies, including OMB representatives; various levels of agency management such as policy review boards at higher levels in the agency; and/or Congressional or Executive Branch staff members making inquiries on behalf of constituents.

At Level 4, personal contacts are recurring face-to-face and remote oral (e.g., telephone) or via email with high-ranking officials from outside the employing department or agency at national or international levels in highly unstructured settings.  Examples of contacts at this level include:  Congressional appropriations committee members; Presidential advisors and cabinet level appointees of major departments and agencies; State governors, mayors of large cities, presidents of large national or international firms; presidents of national unions, governors, or mayors of large cities; and/or occasional contact with nationally recognized representatives of the news media on financial matters of national significance.

The appellant states his position should be credited with Level 6-4 because he has contact with high-ranking officials from Treasury and GAO, other federal agencies, and the Federal Reserve System.   Interviews with the appellant and his supervisor confirmed these people were usually higher-graded staff employees below the executive level.  This is comparable to Level 6-3.  Also like Level 6-3, the contacts are not routine, but occur as necessary throughout the A-123 Assessment.  Unlike Level 6-4, the appellant does not have contact with Congressional committee members, Presidential advisors, State governors, presidents of national firms or unions, or their equivalents.  While the appellant occasionally deals with BPD’s CFO, this is not the same as dealing with presidents of the major firms found at Level 6-4.  Accordingly, the appellant’s position is evaluated properly at Level 6-3.

Purpose of contacts

The purpose of contacts at Level 7-B is to plan, arrange, coordinate, or advise on work efforts and/or arrange for interviews and meetings to obtain information and, as required, to obtain data to verify questionable items.  Though differences of opinion may exist, the persons contacted are usually working toward a common goal and generally are cooperative.  Contacts involve these types of matters:  the significance of guidelines; the appropriateness of recommendations; the necessity for additional facts; the preferred course of action including preferred methods of data gathering; resolving problems related to assignment of responsibility; coordinating the technical support of subject-matter experts; and obtaining answers to questions and issues.

The purpose of contacts at Level 7-C 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 of the purpose of contacts at this level 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; 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; influencing or persuading representatives of an audited organization to accept critical or controversial observations, findings, and recommendations when representatives of audit subjects are reluctant to agree that costly errors were made, that corrective action is required, or that suggestions for change will improve operations; influencing and persuading taxpayers to comply with requirements for information to resolve outstanding problems and issues or to pay tax liability when the taxpayers or their representatives hold strong opposing views, and/or are hostile, skeptical, or uncooperative requiring the employee to use tact, persuasiveness, and diplomacy to obtain the desired results; providing skeptical and fearful individual and business taxpayers with information on agency products and services, and in-depth authoritative tax advice and assistance to increase compliance with tax laws and regulations through increased knowledge.

The appellant asserts his position meets Level 7-D because of the significance of the issues involved and because he has to motivate and persuade persons to accept opinions or take actions.  However, the significance of the issues involved does not affect this factor.  While the appellant described situations in which he negotiated with Treasury officials over the frequency of which certain transactions needed to be reviewed, this is properly credited at Level 7-B in that he is working with contacts to determine the preferred course of action including preferred methods of data gathering.  Like Level 7-B, the appellant plans, arranges, and coordinates work efforts and/or arrange for meetings to obtain.  Though some team members and/or Treasury or GAO officials may have differing opinions about some aspects of the execution of the A-123 Assessment, they are all working toward a common goal, as described in Level 7-B.  The agency credited the appellant’s position with Level 7-C.  Unlike this level, the appellant does not influence, motivate, interrogate, or control persons or groups when there is wide disagreement.  While the appellant’s PD states he negotiates for approval of recommendations, the record shows his contacts were generally working toward a common goal.  Furthermore, the BPD Implementation Plan states the Senior Assessment Team is responsible for ensuring required corrective actions are implemented properly, not the appellant.  Accordingly, the position is evaluated properly at Level 7-B.

The combined factors are credited at Levels 3B for a total of 110 points.



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 4-5 325
5.  Scope and effect 5-4 225
6. & 7. Personal contacts and 6-3
           Purpose of contacts 7-B 110
8.  Physical demands 8-1 5
9.  Work environment 9-1 5
Total 2820


 The total points fall within the GS-12 point range of 2755 to 3150 in the JFS.

Evaluation using the GSLGEG

The GSLGEG is divided into two parts.  Part I covers work leaders over three or more employees in clerical, or other one-grade interval occupations.  Part II which covers positions whose primary purpose is, as a regular and recurring part of their assignment and at least 25 percent of their duty time, to lead a team of other General Schedule employees in accomplishing two-grade interval work.  Team Leaders under Part II usually participate in the work of the team by performing work that is of the same kind and level as the highest level of work accomplished by the team led.  According to the appellant’s PD and evaluation statement, the appellant leads the work of a team of two GS-511-12 Auditors.  While the number of team members is relatively small, the appellant’s TL duties take at least 25 percent of his work time because of the technical nature of the work and the team approach to conducting audits.  The appellant provides significant coordination of team member assignments and work products; ensures consistent interpretation of policy, procedures, and the application of appropriate testing methodology; establishes priorities and timeframes for the team; reviews work for adherence to BPD, Treasury, and OMB requirements; and integrates the work of the team into overall management plans for achieving established organizational goals and objectives.  Additionally, the appellant personally performs the two-grade interval work of his team.  Therefore, his position meets GSLGEG coverage requirements.

TLs work with team members to achieve specific tasks, produce work products and services, and meet program and production goals.  They typically assist the team through knowledge and application of leadership and team building skills and techniques such as group facilitation, coordination, coaching, problem solving, interpersonal communication, integration of work processes and products, obtaining resources and liaison with the supervisor.  TLs are responsible to their supervisors and accountable for the timely delivery of quality work products and/or services produced by the team led.  To be classified by application of Part II, positions must perform at a minimum, all of the first seven coaching, facilitating and mentoring duties, and a total of at least fourteen of the twenty duties listed in Part II of the GSLGEG.  The appellant states he performs the following TL duties  for the two GS-511-12 Auditors within PRB (numbers shown correspond to TL duties as described in Part II of the GSLGEG):  1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 17, and 20.  Based on careful analysis of the entire record, we concur. 

The appellant also states he performs the same TL duties for the higher-graded A-123 Assessment team members.  As previously discussed, the A-123 Assessment team had 25 members in FY2010 with positions in a variety of series and grades, up to and including the GS-15 grade-level.  Only the GS-511-12 Auditors in PRB have a statement in their PD that they are under the general operating supervision of the Branch Manager and an Audit Lead, which is the appellant when he functions as their TL.   The GSLGEG specifically excludes positions that have functional “project” responsibility but do not lead other workers on a continuing basis.  As previously stated, the Senior Assessment Team assigns employees from each office within BPD to the A-123 Assessment team each year.  Although the Senior Assessment Team may sometimes assign the same higher-graded individuals to the assessment team year after year, the team members participate in the assessments on a project basis.  Thus, this exclusion is applicable to the non-PRB A-123 Assessment team members who report to different management chains and are under the appellant’s limited lead only for purposes of this project.  Therefore, these non-PRB employees may not be included in the application of the GSLGEG to the appellant’s position.  Therefore, we will not address the appellant’s application of the GSLGEG to the non-PRB review staff further.

Under Part II, TL positions are classified one full grade level above the base level of work led (BLWL).  The BLWL is the highest grade level of GS-9 or higher nonsupervisory/nonleader two-grade interval work led on a continuing basis, which represents 25 percent or more of the actual work performed by the team for which the TL is fully responsible.  BLWL can also be viewed as the highest grade level of work that represents the portion of the total workload of the team which accounts for 25 percent or more of the duty hours of the TL’s subordinate’s spent on work performed at or above the grade level credited.

According to the record, the two GS-511-12 Auditors within PRB spend at least 25 percent of their time on GS-12 grade controlling duties.  Therefore, the BLWL by the appellant is GS-12.  This is the highest grade level of work led which meets or exceeds 25 percent of the workload of the team.  GSLGEG, Part II, TL positions are classified one full grade level above the BLWL, in a two grade interval pattern.  Therefore, the appellant’s TL work is properly classified at the GS-13 grade level.


The appellant’s auditor duties are properly graded at the GS-12 level, and his TL duties are graded at the GS-13 level.  As provided for in the Introduction, the overall grade of the position should reflect the highest level of technical work or TL work performed.  Therefore, the position is properly classified as Lead Auditor, GS-511-13.




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