Washington DC

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

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


01/06/2023

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Date

As provided in section 511.612 of title 5, Code of Federal Regulations, this decision constitutes a certificate that is mandatory and binding on all administrative, certifying, payroll, disbursing, and accounting officials of the Government. The agency is responsible for reviewing its classification decisions for identical, similar, or related positions to ensure consistency with this decision. There is no right of further appeal.  This decision is subject to discretionary review only under conditions and time limits specified in the Introduction to the Position Classification Standards (Introduction), appendix 4, section G (address provided in appendix 4, section H).

 As discussed in this decision, our findings show the appellant’s official position description (PD) does not meet the standard of adequacy described in section III.E of the Introduction. Since PDs must meet the standard of adequacy, the agency must revise the appellant’s PD to reflect our findings. The servicing human resources office must submit a compliance report containing the corrected PD within 30 days of the date of this decision to the Office of Personnel Management (OPM), Merit System Accountability and Compliance, Agency Compliance and Evaluation, Washington, DC, office.

Introduction

The appellant’s position is currently classified as Supervisory Accounting Technician, GS-0525-09, but she believes it should be graded at the GS-10 level.  The position is assigned to the Accounting Operations Division, Financial Center (FINCEN), Directorate of Financial Operations-Comptroller, Commandant (CG-8), U.S. Coast Guard (USCG), Department of Homeland Security (DHS), in Chesapeake, Virginia.  We have accepted and decided this appeal under section 5112 of title 5, United States Code.

General issues

The appellant’s third-level supervisor (i.e., Payables Branch Chief) certified to the accuracy of the appellant’s PD number 00003681.  However, he proposed changes in terminology (e.g., replace references to unit chief with first-line supervisor and remove references to obsolete financial systems) to her standardized PD, dated November 1998.  In her appeal to OPM the appellant also believes her PD is inaccurate and provided a “running list of the additional duties [she is] performing and have been performing for the past seven years which are not reflected in [her] Current PD…”  For example, she states she researches and resolves operational and procedural problems encountered; initiates and leads process improvement projects/teams to enhance work products, services, payment systems, and processes; evaluates and analyzes work outputs to identify material weaknesses; evaluates internal payment policies, procedures, controls, and work outputs; and ensures compliance with payment policies and directives.

We note the appellant’s PD mentions similarly described duties from the above list.  For example, the PD describes a typical assignment as follows, “Researching, analyzing, interpreting, examination, and classifying unusual and complex accounting transactions/documents or special conditions/adjustments requiring thorough interpretation and analysis of the reasons and justification of the action…”  A PD does not have to be a comprehensive and detailed narrative of the tasks assigned to a position.  Rather, 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.  Major duties are normally those occupying a significant portion (at least 25 percent) 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 time.  OPM considers a PD to be accurate for classification purposes when the major duties and responsibilities of the position are identified, and proper classification can be made when the description is supplemented by otherwise accurate, available, and current information on the organization’s structure, mission, and procedures.

Regardless, classification appeal regulations permit OPM to investigate or audit a position and decide an appeal on the basis of the actual duties and responsibilities currently assigned by management and performed by the employee.  An OPM appeal decision classifies a real operating position and not simply the PD.  This decision is based on the work currently assigned to and performed by the appellant.

After careful review, we find the appellant’s official PD does not meet the standard of adequacy addressed on pages 11-12 of the Introduction.  Specifically, her PD assigns her position to the U.S. Department of Transportation (FINCEN was subsequently moved upon creation of the DHS) and refers to obsolete financial systems such as the Departmental Accounting and Financial Information System and its various interface systems.  In addition, in contrast to our findings the PD inaccurately describes under Factor 7., Purpose of Contacts, that comparable to Level 7-a in the GS-0500 JFS.  However, as discussed in the “Grade determination” section of this decision, we find the purpose of the appellant’s contacts meets Level 7-b.  Because her PD is outdated and incorrectly identifies basic information such as agency, organization name, accounting systems, and the purpose of her contacts, the agency must revise the PD to accurately reflect our findings.

Position information

The appellant’s position is assigned to the FINCEN, which is responsible for accounting functions including the processing and payment of invoices for the USCG, Transportation Security Administration (TSA), and other DHS organizations.  The appellant serves as the first-level supervisor for the Purchase Order Payment Processing Team (Team), which is charged with the processing and payment of purchase orders and maintenance of accounting records for units assigned to the USCG worldwide.  Her first-level supervisor is the Commercial Payments Unit Chief (GS-0510-12 Supervisory Accountant), and second-level supervisor is the Commercial Payables Section Chief (GS-0510-13 Supervisory Accountant).

When a unit of the USCG (hereafter referred to as “unit”) requests purchase of cellular phone or cable services, uniforms, or other goods and services, the contracting or other official for the unit is responsible for the procurement.  Once a business is selected, the vendor will receive a purchase order, which explains the terms of agreement, to buy the goods or services.  Purchase orders are entered into the procurement data system for approval.  When the vendor delivers the goods or services, the unit will enter the receiving report into the procurement system.  The vendor will subsequently mail the invoice to the FINCEN for payment.  Upon receipt, an accounting technician on the Team will prepare the invoice by scanning it and entering data such as document number, invoice number, and amount into the relevant financial system.  The invoice will then enter a work queue to be further reviewed and processed by an accounting technician.  If all required information is complete, the technician will forward the invoice to an Authorized Certifying Officer (ACO), who will forward it to the U.S. Department of the Treasury (Treasury) for payment.  If the invoice is missing information or unacceptable (e.g., discrepancy in product, quantity, or price between the purchase order and invoice), it will be returned to the unit, vendor, or both for further action.

The appellant estimates spending 25 percent of her time personally performing accounting technician work for the Team.  She processes a variety of routine, unusual, and complex accounting transactions and documents.  The appellant estimates processing 20 invoices a week.  Such work requires applying experienced knowledge of accounting principles, appropriations laws, procurement regulations, and other regulatory guidance to the accounting transactions and documents.  In addition, her position requires completing the Financial Management Services Certifying Officers course, which is an annual requirement of the Treasury.

The appellant estimates spending approximately 75 percent of her time on supervisory work, which includes providing technical and administrative supervision to all employees assigned to her Team.  The Team includes the following positions:  eight Accounting Technicians, GS-0525-07; two Accounting Technicians, GS-0525-08; and two Lead Accounting Technicians, GS-0525-08.  The four GS-8 accounting technician positions serve as ACOs, who are responsible for the accuracy and legality of all payments approved to be paid from Federal funds.  The appellant states that she also has 4 full-time contractors performing the work of GS-07 accounting technicians to deal with the current backlog; however, she is unaware of how long the contractors will continue supporting her Team on an intermittent basis.  The appellant’s supervisory duties include, but are not limited to, setting performance standards and evaluating performance including overseeing the work performed by the accounting technicians who process invoices and provide customer service; planning and establishing work schedules, priorities, and deadlines; evaluating internal policies, procedures, controls, and work outputs; resolving system problems (e.g., if a technician is unable to access a financial system); participating on hiring panels for recruitment actions; explaining management needs; and ensuring the Team’s compliance with payment policies and directives.  She monitors the work of each technician to maintain production reports, which identify the number of invoices processed, percentage of invoices, total errors vs. total invoices, and accuracy rates for each technician.  Production reports are provided daily to management.  ACOs check all invoices and identify when a technician makes an error.  Technicians are required to maintain an accuracy rate between 92 and 97 percent.  If the rate falls below the acceptable range, the appellant discusses such issues with the technician to determine if additional training is required on the process, payment review, suspected duplicates, etc.  She maintains and, when necessary, updates desk guides and standard operating procedures for enhancing detection and correction of errors, uniformity of procedures, and improving the Team’s production.  She counsels employees, resolves simple employee complaints, referring more serious issues to her supervisor. 

In reaching our classification decision, we carefully considered all information provided by the appellant and her agency including her official PD which, although not completely accurate, we have incorporated by reference into this decision.  In addition, to gain more information about her work, we conducted a telephone audit with the appellant and a telephone interview with the first-level supervisor.

Series, title, and standards determination

The agency classified the appellant’s position in the Accounting Technician Series, GS-0525, titling it Supervisory Accounting Technician, and the appellant does not disagree.  We concur with the agency’s series and title determination as the appellant performs work typical of GS-0525 positions which include account maintenance clerical and accounting technician support work requiring a basic understanding of accounting systems, policies, and procedures in performing or supervising the examination, verification, and maintenance of accounts and accounting data.  In addition, the position fully meets the coverage requirements for titling and evaluation as a supervisor specified in the General Schedule Supervisory Guide (GSSG).

To evaluate the appellant’s personally performed work we applied the grading criteria in the Job Family Standard (JFS) for Clerical and Technical Accounting and Budget Work, GS-0500.  To evaluate the grade of her supervisory duties we applied the grading criteria in the GSSG.  Our evaluation of the grade of the position follows. 

Grade determination

Evaluation of supervisory duties using the GSSG

The GSSG is a cross-series guide used to determine the grade level of supervisory work in the General Schedule.  The GSSG has six evaluation factors, each with several factor-level definitions and corresponding point values.  Positions are evaluated by crediting the points designated for the highest level met under each factor and converting the total to a grade by using the point-to-grade conversion chart in the guide.

The appellant’s agency credited her supervisory work as follows:  Levels 1-1 for Factor 1 (Program Scope and Effect), 2-1 for Factor 2 (Organizational Setting), 3-2c for Factor 3 (Supervisory and Managerial Authority Exercised), 4A-1/4B-1 for Factor 4 (Personal Contacts), 5-4 for Factor 5 (Difficulty of Typical Work Directed), and 6-2 for Factor 6 (Other Conditions).  In her appeal to OPM, the appellant only disagrees with the agency’s evaluation of Factors 1 and 4.  After careful review, we concur with the agency’s evaluation of the remaining factors and have credited the position accordingly.  Therefore, we have confined our analysis to Factors 1 and 4.

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 geographical coverage.  It also assesses the impact of the work both within and outside the immediate organization.  To assign a factor, the criteria dealing with both scope and effect, as defined below, must be met.

             Scope

This element addresses the general complexity and breadth of the program (or program segment) directed; or the work directed, the products produced, or the services delivered.  The geographic and organizational coverage of the program (or program segment) within the agency structure is included under this element.

At Level 1-1, work directed is procedural, routine, and typically provides services or products to specific persons or small, local organizations.

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

The agency credited the appellant’s position at Level 1-1, stating in its evaluation statement that the “[w]ork directed is procedural, routine, and typically provides services or products to specific persons or local sub-agencies of an organization.”  The GSSG provides an illustration at Level 1-1, which describes messenger, guard, clerical, or laboratory support work below grade GS-5 or equivalent.  It further describes providing local services to an organizational unit, small field office, or comparable activity.  In contrast, the work directed by the appellant significantly exceeds the staff support functions characteristic of Level 1-1.

We considered the appellant’s position in comparison to the descriptions at Levels 1-2 and 1-3.  The types of work represented at both levels would appear to overlap in that both cover technical work.  Technical work extends across a range of grades, and the nature of such work described at Level 1-3 would be expected to represent the higher end of the range.  The association of technical work with “professional” and “investigative” work at Level 1-3 requires a corresponding grade association.  Since the GS-09 grade level is considered the first full performance level for two-grade interval professional and investigative work, then the technical work represented at Level 1-3 would also be expected to be of the same complexity, i.e., at grade GS-09 or higher.  In contrast, the technical work represented at Level 1-2 is associated with “complex clerical” work.  Clerical work is one-grade interval in nature, and “complex clerical” work (otherwise known as “technician” work) does not exceed the GS-8 grade level.  This is reinforced by illustrations provided in the GSSG:

Level 1-2:  Directs 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 services provided directly or significantly impact other functions and activities throughout the organizations supported and/or a small population of visitors or users.

Level 1-3:  Directs administrative services (personnel, supply management, budget, facilities management, or similar) which support and directly affect the operations of a bureau or a major military command headquarters; a large or complex multimission military installation; an organization of similar magnitude, or a group of organizations which, as a whole, are comparable.

The complexity of the work directed by the appellant’s position meets Level 1-2.  The base grade level of work supervised by her (as determined under Factor 5) is the GS-07 grade level, which is aligned with the Level 1-2 complexity of work directed.  Although the complexity of work directed is consistent with Level 1-2, we recognize the geographic coverage of such work is characteristic of the Level 1-3 illustration describing positions that support operations of a bureau, major military command headquarters, or organizations of comparable magnitude.  Because the FINCEN is responsible for performing USCG-wide accounting functions, the services provided by her Team extend beyond the more limited geographic coverage described at Level 1-2.  Regardless, the appellant’s position does not meet Level 1-3 as the complexity of the work directed aligns with Level 1-2, not Level 1-3.

Scope is evaluated at Level 1-2.

            Effect

This element addresses the impact of the work, the products, and/or programs described under “Scope” on the mission and programs of the customer(s), the activity, other activities in or out of Government, the agency, other agencies, the general public, or others.

At Level 1-1, work directed facilitates the work of others in the immediate organizational unit, responds to specific requests or needs of individuals, or affects only localized functions.

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.

The effect of the work directed by the appellant’s position fully meets Level 1-1, where work facilitates the work of others in the immediate organizational unit and responds to specific requests or needs of individuals.  She directs the activities of her Team, which supports the processing of invoices to ensure that goods and services procured through purchase order by USCG are paid accurately and timely.

The appellant’s position does not fully meet Level 1-2.  Criteria at Level 1-2 address two different scenarios: (1) positions involved in the provision of services or products internal to an organization (where effect is on the installation, area office, or field office level), and (2) positions involved in the delivery of externally oriented line functions within a designated geographic area (where effect is on a moderate, local, or limited population of clients or users).  Because her Team provides staff, not line, functions, we considered the effect of the work she directs in comparison to scenario (1) concerning internally serviced organizations.  However, consideration of the size of the organizations serviced under this element is intertwined with consideration of the degree of impact the work supervised has on the serviced organization.  This is evident in the illustration cited above at Level 1-2, where services provided “directly or significantly impact other functions and activities throughout the organizations supported…”

We recognize the appellant’s position directs the work provided by her Team, which has the responsibility of processing invoices for units across USCG.  We also recognize her work is vital as she, e.g., regularly monitors work queues to flag invoices that require processing immediately to ensure timely payment and prevent interest penalties.  In addition, the Team ensures documentation and other critical checks are performed so that only invoices meeting all requirements are paid.  Regardless, neither the purchase order payment processing functions nor the advice and assistance provided by the Team “directly” or “significantly” affect operations of the serviced population as expected at Level 1-2.  Major operational mission programs of the USCG include maritime law enforcement, response (search and rescue), prevention, transportation system management, security operations, and defense operations.  After careful consideration, there is no “direct” or “significant” impact evident between the mission programs of the USCG to the actual services provided by the Team.  The effect of the Team’s functions are restricted in that a combination of staff external to the Team are responsible for the budgeting, contracting, and purchasing work necessary to the procuring of goods and services for the units.  Her Team’s responsibilities are limited to processing the resulting invoices, ensuring all requirements are met prior to forwarding to Treasury for payment.  It is also noteworthy the Level 1-2 illustration connects the direction of budget, management, staffing, supply, maintenance, protective, library, payroll, or similarly extensive service to the “direct” and “significant” impact to be expected on the serviced population.  We conclude that because the breadth of work and services she directs fall short of the broader service type envisioned at this level, the work of the appellant’s Team has neither direct nor significant impact on the operations and objectives of the serviced population as expected at Level 1-2.

Effect is evaluated at Level 1-1.

To assign a particular factor level, the full intent of the criteria for both scope and effect components must be fully met.  Since only scope is credited at Level 1-2, Level 1-1 is credited for 175 points.

Factor 4, Personal Contacts

This is a two-part factor which assesses the nature and the purpose of personal contacts related to supervisory and managerial responsibilities.  The nature of the contacts credited under Subfactor 4A and the purpose of those contacts credited under Subfactor 4B must be based on the same contacts.  The agency credited Levels 4A-1 and 4B-1 under this factor.

Subfactor 4A – Nature of Contacts

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

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

At Level 4A-2, frequent contacts are with any of the following:  (1) members of the business community or the general public; (2) high-ranking managers, supervisors, and staff of program, administrative, and other work units and activities throughout the field activity, installation, command (below major command level) or major organization level of the agency; (3) representatives of local public interest groups or case workers in congressional district offices; (4) technical or operating level employees of State and local governments; and/or (5) reporters for local and other limited media outlets reaching a small, general population.  These contacts may be informal or may occur in meetings and conferences and may require special preparation.

At Level 4A-3, frequent contacts are with any of the following:  (1) high-ranking military or civilian managers, supervisors, and technical staff at bureau and major organization levels of the agency, administrative support staff at agency headquarters, or 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; (6) local officers of regional or national trade associations, public action groups, or professional organizations; and/or (7) State and local government managers doing business with the agency.  These contacts take place in meetings and conferences or may be unplanned where the employee is designated as a contact point by higher management, and often require extensive preparation of briefing materials or up-to-date technical familiarity with complex subject matter.

The agency credited the appellant’s position at Level 4A-1, stating in its evaluation statement that she has “regular and recurring contacts with potentially all employees in the [FINCEN], employees at [USCG] commands, and vendors.”  We find the contacts associated with her supervisory work exceed Level 4A-1, which describes contacts with her subordinate employees, peers who supervise comparable units within the FINCEN, union stewards, and/or staff of administrative and other support activities within the same organization.

The appellant’s supervisory contacts are characteristic of Level 4A-2.  Similar to this level, her routine contacts, given FINCEN’s agency-wide scope of responsibility, are with military and civilian technical staff, contracting and financial officers, and others throughout USCG; vendors and members of the worldwide business community; and all FINCEN employees including peers, systems employees responsible for the automated financial systems, and high-ranking supervisors and managers.  Her contacts may be informal or may occur in meetings and may require special preparation as described at Level 4A-2.

Even though she has contact with high-ranking managers and supervisors at the FINCEN, unlike Level 4A-3 the appellant does not have regular contact with high-ranking managers, supervisors, and technical staff at the bureau and major organization levels of the agency, administrative support staff at agency headquarters or comparable personnel in other Federal agencies, contracting officials and high-level technical staff of large industrial firms, and/or local officers of regional or national trade associations, public action groups, or professional organizations as described at Level 4A-3.  Moreover, most of her contacts are informal and involve the processing of invoices for units of the USCG.  In addition to not having the types of formal contacts expected at this level, none of her contacts take place in meetings and conferences requiring the types of in-depth technical briefings required at Level 4A-3.

This subfactor is evaluated at Level 4A-2 for 50 points.

Subfactor 4B – Purpose of Contacts

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

At Level 4B-1, the purpose of contacts is to discuss work efforts for providing or receiving services; to exchange factual information about work operations and personnel management matters; and to provide training, advice, and guidance to subordinates.

At Level 4B-2, 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.  Any one of the three elements at Level 4B-2 would merit credit for this level. 

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

The agency credited the appellant’s position at Level 4B-1, stating in its evaluation statement that the purpose of her contacts is to “obtain, clarify, or provide information, documentation or interpretation on the status of payments, funds, expenditures, cost, reports, interpretations of data and reports, etc. conform to existing practices.”  However, we find her contacts exceed the factual-based information exchange typical of Level 4B-1 and instead fully meets the purpose of contacts at Level 4B-2. 

Similar to Level 4B-2, the purpose of the appellant’s contacts credited under Subfactor 4A above is to plan and coordinate the operations of her Team internally with other FINCEN components and externally with vendors and units of the USCG.  For example, she has routine contact with other FINCEN staff to resolve technical issues concerning specific accounting transactions and matters.  She works with the Vendor Maintenance Systems Team to resolve issues, e.g., if a vendor is missing a tax identification number; information technology specialists and other systems staff to resolve issues when a technician on her Team is unable to access a financial system or other request (e.g., she worked with systems staff to implement a systems-based notification to flag any potential or suspected duplicate invoice for the technician to specifically research); and other FINCEN supervisors and managers serving as participants on hiring panels.  As at Level 4B-2, the appellant resolves any differences of opinion between ACOs and accounting technicians.  If an ACO flags an error on a transaction, the technician, if he/she disagrees with the decision, can notify the appellant who will research the action and decide whether it should or should not be included in the production report.  As the Team’s only supervisor, she receives calls from outside parties such as vendors, members of the business community, and the units to resolve issues concerning the disbursement of funds and associated documentation requirements.  These types of planning and coordination contacts are characteristic of Level 4B-2.

Level 4B-3 describes three conditions that must be present in a position to credit that level.  Unlike this level, the appellant has neither responsibility nor authority to obtain or commit resources for the Team.  In addition, the primary function of her Team is to support USCG entities by facilitating payment of goods and services procured via purchase orders.  Thus, her contacts are essentially collegial in nature and do not involve the types of conflict resolution expected at Level 4B-3.  Because she does not meet the intent of this level, Level 4B-2 is assigned.

This subfactor is evaluated at Level 4B-2 for 75 points.

Summary
Factors	Level	Points
1.  Program Scope and Effect	1-1	175
2.  Organizational Setting	2-1	100
3.  Supervisory & Managerial Authority Exercised	3-2c	450
4.  Personal Contacts
A.  Nature of Contacts	4A-2	50
B.  Purpose of Contacts	4B-2	75
5.  Difficulty of Typical Work Directed	5-4	505
6.  Other Conditions	6-2	575
Total		1930

A total of 1,930 points falls within the GS-09 range (1855-2100) on the grade conversion table provided in the GSSG.

Evaluation of nonsupervisory duties using the GS-0500 JFS

The GS-0500 JFS uses the Factor Evaluation System (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 appellant’s agency credited her nonsupervisory work as follows:  Levels 1-5 for Factor 1 (Knowledge Required by the Position), 2-3 for Factor 2 (Supervisory Controls), 3-3 for Factor 3 (Guidelines), 4-4 for Factor 4 (Complexity), 5-3 for Factor 5 (Scope and Effect), 6-2 for Factor 6 (Personal Contacts), 7-a for Factor 7 (Purpose of Contacts), 8-1 for Factor 8 (Physical Demands), and 9-1 for Factor 9 (Work Environment).  In her appeal to OPM, the appellant only disagrees with the agency’s evaluation of Factor 7.  After careful review, we concur with the agency’s evaluation of the remaining factors and have credited the position accordingly.  Therefore, we have confined our analysis below to Factor 7.

Factor 7, Purpose of Contacts

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

At Level a, the purpose of contacts is to obtain, clarify, or provide information related to the accounting, budget, or financial management support assignments.  This may involve answering a simple question, such as whether information has been received.  It may also involve explaining more technically oriented subject matter questions, such as providing factual information, interpreting processing procedures, or similar information about a transaction.

At Level b, the purpose of contacts is to plan and coordinate actions to correct or prevent errors, delays, or other complications occurring during the transaction cycle.  This may involve obtaining a customer’s cooperation in submitting paperwork or other information, requesting other personnel to correct errors in documentation or data entry, or assisting others in locating information.

At Level c, the purpose of contacts is to persuade individuals who are fearful, skeptical, uncooperative, or threatening to provide information, take corrective action, and accept findings in order to gain compliance with established laws and regulations.

The appellant’s agency credited her position at Level a.  We note, however, that her PD states she performs “technical accounting at a complexity level above subordinates.”  Our interviews confirmed the appellant typically resolves the most complex technical accounting issues for her Team, e.g., she corrects and prevents errors and validates accounting transactions for others.  When an invoice is submitted late and funds have been de-obligated as a result, she notifies the contracting officer for the unit of the de-obligation and requests approval for the re-obligation of funds.  She resolves issues when the amount on the invoice differs from the obligated fund amount, ensuring the problem is corrected either by the vendor submitting a corrected invoice or the financial officer initiating the appropriate amendment.  Given the appellant performs the most complex technical accounting work for her Team, we find the purpose of her contacts substantially exceeds Level a where contacts tend to be for informational purposes.  Similar to Level b, the purpose of her contacts requires obtaining cooperation from vendors and others to gather source documents or other necessary information, correcting and preventing errors or delays, and reconciling discrepancies.

In contrast to Level c, the purpose of the appellant’s contacts does not entail persuading skeptical, fearful, or uncooperative individuals nor does she have to convince individuals to accept findings in order to gain compliance with established requirements.  Her contacts are usually with individuals typically working towards the same goal.  The purpose of her contacts meets but does not exceed Level b.

Factors 6 and 7 are interdependent.  The contacts selected for crediting Factor 6 are used to evaluate Factor 7, and 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.  We agree with the agency’s crediting of Factor 6 at Level 6-2.  When that level is combined with Level 7 b, a total of 75 points is assigned for these two factors.

Summary
Factors	Level	Points
1.  Knowledge Required by the Position	1-5	750
2.  Supervisory Controls	2-3	275
3.  Guidelines	3-3	275
4. Complexity	4-4	225
5.   Scope and Effect	5-3	150
6&7. Personal Contacts and Purpose of Contacts	2-b	75
8. Physical Demands	8-1	5
9. Work Environment	9-1	5
Total		1760

A total of 1,760 points falls within the GS-08 range (1605-1850) on the grade conversion table provided in the GS-0500 JFS.

Summary

By application of the grading criteria of the GSSG we find the appellant’s supervisory work meets the GS-09 level.  In applying the GS-0500 JFS her personally performed work does not exceed the GS-08 level.  Therefore, by application of mixed grade principles the grade-controlling work and final grade of the appellant’s position is GS-09. 

Decision

The appellant’s position is properly classified as Supervisory Accounting Technician, GS-0525-09.

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