Washington DC
U.S. Office of Personnel Management
Classification Appeal Decision
Under section 5112 of title 5, United States Code
G-8 Field Budget Division
U.S. Army Reserve Command
Fort Bragg, North Carolina
(Parenthetical title at agency discretion)
Damon B. Ford
Acting Classification Appeals and FLSA Claims
Program Manager
08/13/2019
Date
As provided in section 511.612 of title 5, Code of Federal Regulations (CFR), this decision constitutes a certificate that is mandatory and binding on all administrative, certifying, payroll, disbursing, and accounting officials of the Government. The agency is responsible for reviewing its classification decisions for identical, similar, or related positions to ensure consistency with this decision. There is no right of further appeal. This decision is subject to discretionary review only under conditions and time limits specified in the Introduction to the Position Classification Standards (Introduction), appendix 4, section G (address provided in appendix 4, section H).
Since this decision lowers the grade of the appealed position, it is to be effective no later than the beginning of the fourth pay period following the date of this decision, as permitted by 5 CFR 511.702. The applicable provisions of parts 351, 432, 536, and 752 of title 5, CFR must be followed in implementing the decision. If the appellant is entitled to grade retention, the two-year retention period begins on the date this decision is implemented. The servicing human resources (HR) office must submit a compliance report containing the corrected position description (PD) and a Standard Form 50 showing the personnel action taken. The report must be submitted within 30 days from the effective date of the personnel action to the Office of Personnel Management (OPM), Agency Compliance and Evaluation, Washington, DC, office.
Introduction
The appellant’s position is currently classified as Budget Analyst (Civilian Pay), GS-0560-13, but she believes it should be classified in the Miscellaneous Administration and Program Series, GS-0301, and graded at the GS-14 level. The position is assigned to Operations and Maintenance Field Execution Team, G-8 Field Budget Division, U.S. Army Reserve Command (USARC), at Fort Bragg, North Carolina. We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).
Background and general issues
In response to the appellant’s request for a desk audit of her position, the servicing Civilian Personnel Advisory Center conducted a review of her position. In its August 27, 2018, evaluation, the agency concluded the position was appropriately classified as GS-560-13, and explained that a review of her official PD had already been in process with her first-level supervisor prior to her desk audit request. The agency revised her official PD to include specific civilian pay duties and responsibilities identified during the desk audit process, amended the position title to include the “Civilian Pay” parenthetical, and reassigned her to the revised PD, number DE504541, effective on May 13, 2018.
The appellant compares some of her duties and knowledge to those described in PDs of higher graded budget analyst positions in her agency. In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of her position. By law, we must make that decision solely by comparing her current duties and responsibilities to OPM position classification standards and guidelines (5 U.S.C. 5106, 5107, and 5112). Since comparison to standards is the exclusive method for classifying positions, we cannot compare the appellant’s position to others, which may or may not be classified correctly, as a basis for deciding her appeal.
Like OPM, the appellant’s agency must classify positions based on comparison to OPM standards and guidelines. The agency also has primary responsibility for ensuring that its positions are classified consistently with OPM appeal decisions. If the appellant considers her position so similar to others that they both warrant the same classification, she may pursue the matter by writing to her headquarters human resources office. In doing so, she should specify the precise organizational location, classification, duties, and responsibilities of the positions in question. If the positions are found to be basically the same as hers, the agency must correct their classification to be consistent with this appeal decision. Otherwise, the agency should explain to her the differences between her position and the others.
The appellant states the loss of other positions performing civilian pay has increased her workload. However, volume of work cannot be considered in determining the grade of a position (The Classifier’s Handbook, chapter 5).
The appellant also appears to ask OPM to consider the concept of impact of the person on the job, explaining in her appeal request that she is the “impact person on the job for civilian pay,” has been performing the work since 2006, and that she is the only person within the USARC who does civilian pay. The concept of impact of the person on the job is addressed in both the Introduction and The Classifier’s Handbook. The concept holds that an employee, by virtue of exceptional competence 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. The mere fact that 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 that management recognizes and endorses the duties and also that the work environment allows continuing performance at a different level. Because there is no evidence her work performance actually makes the duties of the appealed position materially different from what they otherwise would be, thus affecting the classification of the position, the impact of the person on the job concept is not applicable to the appellant’s position.
Position information
The appellant’s position is assigned to the Operations and Maintenance Field Execution Team, Budget Division, which is responsible for managing and overseeing the execution of all Operation and Maintenance funding distributed to the USARC. Her position is supervised by the Budget Division Chief, whose position is classified as Supervisory Budget Analyst, GS-0560-14. The appellant’s position serves as the principal civilian pay analyst, advisor, and administrator for the USARC’s approximately 10,000 civilian employees and military technicians assigned to its headquarters and subordinate commands worldwide. The civilian pay program is comprised of an estimated 734 million dollars for salaries; 40 million dollars for awards, overtime, and other non-pay expenses; and 3.4 million dollars for injury compensation.
The appellant’s position performs civilian pay program analysis, execution, planning, and advisory functions for USARC’s 25 commands and 27 directorates. Her duties include, but are not limited to, coordinating budget services, managing resources, and forecasting budgetary trends and activities. She reviews and monitors budget execution to ensure funds are properly allocated and obligated, submits civilian pay budget estimates to the Office of the Chief, Army Reserve (OCAR) for review and approval, analyzes expenditures and trends to identify and resolve program shortfalls or excesses, makes recommendations for reprogramming actions, and determines any unexecuted funding to be returned at the end of the fiscal year. The appellant analyzes the civilian pay budgets to calculate funding targets for awards and overtime, in addition to making recommendations on requests from organizations to exceed those targets based on funds availability. She maintains close liaison with program managers in the management of funding for awards, overtime, and permanent change of station (PCS) moves. She monitors civilian pay transaction activity, e.g., reviewing unliquidated obligations, unmatched disbursements, and reimbursable orders. She coordinates vendor, recruitment bonus, workers’ compensation chargeback, and other payments. She communicates with the Defense Finance and Accounting Services (DFAS), U.S. Department of Labor (DOL), and multiple organizations and agencies, providing data and information when necessary, to resolve issues and ensure accuracy of payments and records.
The appellant serves as the technical authority for the General Fund Enterprise Business System (GFEBS) HR Mini-master, the USARC’s web-enabled financial, asset, and accounting management system. She updates lines of accounting (LOA), creates and deletes employee records, and updates master data records. She reviews reports in the Defense Civilian Personnel Data System (DCPDS) and Defense Civilian Payroll System (DCPS), which maintain personnel and payroll data on civilian employees and provide leave and earnings statements, time and attendance, and other services. The appellant reviews payroll-related reports generated by DCPDS/DCPS to ensure all transactions interface appropriately in GFEBS to avoid unmatched transactions, and when necessary coordinates reconciliation or reconstruction of discrepancies to ensure flow of accurate information to GFEBS.
The appellant’s official PD and other material of record furnish much more information about her duties and responsibilities and how they are performed. The first-level supervisor certified to the accuracy of the duties described in the appellant’s official PD, but the appellant focused her discussion on disputing the assignment of certain factor levels in her PD rather than its accuracy. A PD is the official record of the major duties and responsibilities assigned to a position or job by an official with authority to assign work. OPM considers a PD to be accurate for classification purposes when the major duties and responsibilities of the position are listed 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. We find the PD contains misleading statements regarding Factor 2, Supervisory Controls, by stating the appellant works under only the administrative supervision of the Division Chief. As a Supervisory Budget Analyst, the first-level supervisor’s control over the appellant’s position exceeds administrative oversight (e.g., approving leave requests) as he also provides technical oversight over her position by providing advice or input, when necessary, on funding for awards, overtime, PCS moves, and other requests or on civilian pay-related recommendations she makes. Therefore, the appellant’s PD does not meet the standard of adequacy addressed on pages 11-12 of the Introduction, and the agency must revise the PD to reflect our findings.
To help decide this appeal, we conducted a telephone audit with the appellant and a telephone interview with her first-level supervisor. We also conducted a telephone interview with the G-8’s Accounting Division Chief, who, as the senior accountant managing and reporting all financial transactions for the USARC, coordinates with the appellant on various civilian pay reporting issues. In reaching our classification decision, we carefully considered all information gained from these interviews, as well as written information furnished by the appellant and her agency, including her official PD which, although not completely accurate, we have incorporated by reference into this decision.
Series, title, and standard determination
The appellant believes her position should be classified in the Miscellaneous Administration and Program Series, GS-0301, stating her work involves various functions including budget analysis, program analysis, manpower, and HR. However, in contrast to her duties, the GS-0301 series includes positions the duties of which are to perform, supervise, or manage nonprofessional, two-grade interval work for which no other series is appropriate, and which requires analytical ability, judgment, discretion, and knowledge of a substantial body of administrative or program principles, concepts, policies, and objectives. The GS-0301 flysheet instructs that if the basic subject matter knowledge and skills for a position are covered by other specific series, then the position should be assigned to that series rather than the GS-0301 series. It also instructs that mixed positions, i.e., positions involving work classifiable in more than one series, should be classified to the series that represents the paramount qualifications required.
The primary duties of the appellant’s position are directly associated with the Budget Analysis Series, GS-560. As defined in the Job Family Position Classification Standard (JFS) for Professional and Administrative Work in the Accounting and Budget Group, GS-0500, positions in the GS-0560 series perform, advise on, or supervise work in any of the phases of budget administration when such work requires knowledge and skill in applying budget-related laws, regulations, policies, precedents, methods, and techniques. Our review of her official PD and performance plan, as well as our interviews, confirm her position serves as the principal analyst, advisor, and administrator for the USARC on civilian pay cost and execution of funds aligned under multiple program evaluation groups and funded through Operational and Maintenance appropriations. Her PD identifies major duties including, but not limited to, conducting comprehensive analysis of civilian pay resources, maintaining budgetary records to monitor obligations and expenditures throughout the execution phase of the annual operating budget, managing civilian pay transaction activity and coordinating with multiple organizations and agencies by providing data and information to resolve issues and ensure accuracy of payments and records, and serving as the technical authority for the GFEBS HR Mini-Master to establish new hires and update LOAs.
Our review of the appellant’s performance plan supports her position’s budget analyst role and responsibilities, identifying the following five elements: Financial Management (interpret budgetary policy, manage resources, forecast budget trends, review budget requirements); Budget Analysis (operational oversight and management of the civilian pay program); Timely and Accurate Management of GFEBS Human Resource Information System (conduct comprehensive analyses by identifying all incorrect transactions and errors posted in GFEBS and monitor payroll and personnel data feeds into GFEBS to ensure LOA is correct and payroll is posted to the correct program and appropriation); Customer Service/Respond to data calls (communicate orally and in writing effectively, timely and professionally with program budget officials and other agencies); and Training and Professional Development (complete required training in order to maintain Department of Defense (DOD) Financial Management Certification and Certified Defense Financial Management). We also found the purpose of the work, identified by the appellant as related to HR, manpower, and program analysis, is clearly to facilitate her budget analysis work, i.e., she applies her knowledge of GFEBS to perform her civilian pay responsibilities by ensuring USARC’s civilian employees and military technicians are paid appropriately. Therefore, based on our fact-finding we conclude the paramount knowledge and skills required to perform the appellant’s primary budgetary duties are typical of positions classified in the Budget Analysis Series, GS-0560, and, as such, classification to the Miscellaneous Administration and Program Series, GS-0301, is inappropriate.
As prescribed in the GS-0500 JFS, positions classified in the GS-0560 series are titled Budget Analyst. While the GS-0500 JFS does not prescribe any authorized specializations for GS-0560 positions, the agency may supplement official titles with parenthetical titles as provided for in the Introduction. The appellant’s position is properly evaluated by application of the grading criteria in the GS-500 JFS. Our evaluation by application of the criteria follows.
Grade determination
The GS-0500 JFS is written in the Factor Evaluation System (FES) format, under which factor levels and accompanying point values are assigned for each of the nine factors. The total is converted to a grade level by use of the grade conversion table provided in the JFS. 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 at a lower level unless an equally important aspect that meets a higher level balances the deficiency. Conversely, the position may exceed those criteria in some aspects and still not be credited at a higher level.
In her appeal request to OPM, the appellant only disagreed with the agency’s evaluation of Factors 1 (Knowledge Required by the Position) and 3 (Guidelines). She subsequently expressed disagreement with the agency’s evaluation of Factor 5 (Scope and Effect) during her telephone audit with OPM. We have reviewed the agency’s crediting of Levels of 3-c for Factors 6 and 7 (Personal Contacts and Purpose of Contacts), 8-1 for Factor 8 (Physical Demands), and 9-1 for Factor 9 (Work Environment),and concur and have credited the position accordingly. Therefore, our evaluation focuses on the remaining factors, i.e., Factors 1, 2 (Supervisory Controls), 3, 4 (Complexity), and 5.
Factor 1, Knowledge Required by the Position
This factor covers the nature and extent of information or facts the employee must understand to do acceptable work, e.g., steps, procedures, practices, rules, policies, regulations, and principles) and the nature and extent of the skills needed to apply the knowledge.
At Level 1-7, budget analyst positions require detailed, intensive knowledge of the policies, precedents, goals, objectives, regulations, and guidelines of a functional area such as financial oversight, budget formulation, and/or budget execution sufficient to analyze and evaluate continual changes in program plans and funding and their effect on financial and budget program milestones. At Level 1-7, budget analyst positions require such knowledge to analyze financial and budgetary relationships to develop recommendations for financial and/or budgetary actions under these types of conditions and time pressures: uncertainty due to short and rapidly changing program and financial/budgetary deadlines and objectives; gaps and conflicts in program and financial/budgetary information; lack of predictive data; conflicting program and financial/budgetary objectives; and/or changing guidelines for the work. Level 1-7 is also the highest level for salary and expense budgeting of a support nature in a Federal agency.
At Level 1-8, budget analyst positions require mastery of the concepts, principles, practices, laws, and regulations of budgeting and/or financing; and the financial and budgetary relationships between subordinate and most senior levels of financial management and budgeting within the employing entity and/or between the organization and programs of other Federal, State, and local governments, private industry, and large public organizations sufficient to: analyze national level programs, exceptionally large and complex programs (e.g., multi-million dollar research grants, contracts, and/or cooperative acquisition agreements); develop, recommend, and implement budgetary and financial policies; interpret and assess the impact of new and revised Congressional legislation on the formulation and execution of budgets; project and analyze the potential effects of budgetary actions on program viability and attainment of program objectives; develop and render authoritative interpretations of executive orders, Office of Management and Budget (OMB) guidelines and directives, and policies and precedents within and across agency lines; develop new methods and techniques of budgeting for the forecasting of long-range funding needs (e.g., 3 to 5 years or more into the future); and/or develop timetables for obtaining needed funding for new or modified substantive government programs.
The appellant’s position meets Level 1-7. She manages the centralized civilian pay program, in addition to serving as technical authority for the GFEBS HR Mini-master, the Civilian Injury and Illness Compensation Program (including death gratuity payments), and civilian PCS moves. As at Level 1-7, her position requires a thorough knowledge of DOD, the U.S. Army, OCAR, and other budget policies, regulations, guidelines, and processes to manage the day-to-day operations of the civilian pay program. Her position requires knowledge of the missions, policies, and objectives of the various USARC programs such as the Family, Drug Demand, Army Substance Abuse, Physical Security, Army Security, Anti-Terrorism, and Sexual Harassment/Assault Response programs. Her work requires extensive knowledge of Congressional, OMB, and other budget processes, procedures, and requirements to analyze and formulate requirements, justify and monitor the execution of the civilian pay budget program, advise program managers and higher-level managers on potential and actual funding matters that may impact the accomplishment of program objectives, identify potential funding deficiencies based on observation of trends, and analyze funding changes for impact on program operations and recommend ways to balance deficiencies. As fund holder, the appellant conducts a triannual review in compliance with DOD Financial Management Regulation (FMR) and DFAS Regulation, certifying to the accuracy, validity, and need for the balances reviewed for commitments, obligations, and disbursements. She applies root cause analysis for any deficiencies identified. The appellant is also responsible for the USARC’s fund designated to reimburse DOL for injury and illness compensation and medical costs paid to civilian employees and military technicians. Her duties include making payment to DOL for bills received for workers’ compensation chargeback costs, forecasting future year requirements, and assessing past year requirements. As at Level 1-7, the appellant analyzes and evaluates continual changes in program plans and funding and their effect on financial and budget program milestones.
Similar to Level 1-7, the appellant’s position requires detailed, intensive knowledge of the concepts, principles, practices, laws, and regulations of civilian pay budgeting in order to develop recommendations for actions under uncertain conditions due to short and rapidly changing program deadlines, to facilitate the resolution of controversial civilian pay problems, and to ensure proper interfacing between financial and HR automated systems. She reviews and acts on requests from program offices for funding of PCS moves, ensuring that requests comply with all Joint Travel Regulations (JTR) requirements, start date and other information is correct, the employee has not received PCS in the last 12 months, adequate funds are available to cover PCS expenses, and estimates for per diem, lodging, reimbursement for purchasing a home, relocation income tax, and miscellaneous costs are appropriate. She is responsible for the preparation and internal control checks required of PCS orders. The appellant’s position favorably compares to an illustration in the JFS at Level 1-7, which describes a budget analyst applying detailed, intensive knowledge of the policies, precedents, goals, objectives, regulations, and guidelines of a functional area (e.g., financial oversight, budget formulation, and/or budget execution). The knowledge is sufficient to analyze and evaluate continual changes in program plans and funding and their effect on financial and budget program milestones; and analyze financial and budgetary relationships to develop recommendations for financial and/or budgetary actions. The budget analyst at Level 1-7 monitors the execution of a budget with many different sources and types of funding such as direct multi-year appropriations, allotments from many different appropriations, transfers of funds from other agencies, reimbursements for services performed, revenue from working capital funds, and trust accounts. The budget analyst also identifies and analyzes trends in the receipt, obligation, or expenditure of funds to ensure that objectives of the annual financial plan are being met on a timely basis, and that funds are available and being properly and effectively used to support program objectives. Similar to the Level 1-7 illustration, the appellant’s civilian pay program and activities are characterized by diverse funding arrangements such as appropriations, reimbursements, reprogramming between subordinate commands, and transfers with other commands and Federal agencies. She identifies and analyzes trends to ensure funds are available; and in the event she identifies a funding deficiency for a program after conducting an analysis, she reviews the budgets of other programs to identify any excess funds that may be reprogrammed to cover the funding shortage.
The appellant seeks to credit her position at Level 1-8. However, her position does not require the mastery of concepts, principles, practices, laws, and regulations of budgeting or financing and the financial and budgetary relationships between subordinate and most senior levels of financial management and budgeting within the employing entity and/or the programs of other organizations as expected at Level 1-8. Because of the USARC centralized civilian pay program responsibilities in her position, the appellant performs all budget formulation, execution, monitoring, and other work related to the civilian pay program. She establishes award, quality step increase (QSI), and overtime targets and provides instructions to the program office staff preparing civilian pay-related requests for her review. However, because there are no subordinate budget analyst or other positions performing civilian pay work, her position does not require developing budgetary policies or interpreting legislation to determine possible impact on agency-level budgeting processes or financial operations as described at Level 1-8. Guidance of this nature is prepared by higher organizational levels within OCAR, Army, DOD, etc. The JFS provides an illustration at Level 1-8 of a budget analyst position applying mastery of the concepts, principles, practices, laws, and regulations of budgeting and financing for mission-related programs and services sufficient to analyze national-level programs and/or exceptionally large and complex programs. The illustrated position at Level 1-8 requires skill in applying expert knowledge of the financial and budgetary relationships between the subordinate and the most senior level of financial management and budgeting within the employing entity sufficient to function effectively in work situations equivalent to, e.g., managing the formulation, justification, and execution of the budget for an entire agency or major component conducting a substantive program or recognizable segment thereof. In contrast, the appellant’s position is characteristic of an operating-level budget analyst performing the day-to-day procedural and transactional work required of a civilian pay program, rather than as an agency-level technical authority developing agency financial policy or providing senior-level agency coordination of financial issues.
Also unlike Level 1-8, the appellant’s position does not require analyzing exceptionally large and complex programs; interpreting and assessing the impact of new and revised Congressional legislation on the formulation and execution of budgets; developing and rendering authoritative interpretations of executive orders, OMB guidelines and directives, and policies and precedents within and across agency lines; developing new methods and techniques of budgeting for the forecasting of long-range funding needs; or developing timetables for obtaining needed funding for new or modified substantive Government programs. While the appellant is responsible for correcting all payroll processing errors for the USARC’s civilian employees and military technicians; queries the financial and HR automated systems weekly to ensure all HR personnel actions are entered and correct; and resolves most USARC civilian pay problems (e.g., death benefits, debt collections); unlike Level 1-8 the civilian pay-related issues she regularly deals with do not require projecting and analyzing the potential effects of budgetary actions on program viability and attainment of program objectives.
Level 1-7 is credited for 1,250 points.
Factor 2, Supervisory Controls
This factor considers the nature and extent of direct or indirect controls exercised by the supervisor, the employee’s responsibility, and the review of completed work.
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 conflicts that arise; coordinating the work with others as necessary; interpreting policy and regulatory requirements; developing changes to plans and/or methodology; and/or providing recommendations for improvements in order to meet program objectives. The employee keeps the supervisor informed of progress and of potentially controversial matters. Such matters may include these types of issues: major problems in completing accounting systems development or installation; the possibility of fraud or items of major impact on other audit or examination efforts or agency program areas; the need for supplemental appropriations; and/or inability to meet key budget and program deadlines. The supervisor reviews completed work for soundness of overall approach, effectiveness in meeting requirements or expected results, the feasibility of recommendations and adherence to requirements. The supervisor does not usually review methods used.
At Level 2-5, the supervisor provides administrative and policy direction in terms of broadly defined missions or functions of the organization. The employee is responsible for a significant program or function. The employee defines objectives, interprets policy promulgated by authorities senior to the immediate supervisor, and determines their effect on program needs. Additionally, the employee independently plans, designs, and carries out the work to be done. The employee is a technical authority. The supervisor’s review of the work covers such matters as fulfillment of accounting, auditing, examination, finance, or budget program objectives and the effect of advice, influence, or decisions on the overall program. The supervisor usually evaluates the employee’s recommendations for new systems, methods, projects, or program emphasis in light of the availability of funds, personnel, equipment capabilities, priorities, and available resources. Also, the supervisor rarely makes significant changes to the employee’s work.
The agency credited the appellant’s position at Level 2-5, but we find her position fully meets Level 2-4. Similar to Level 2-4, she independently carries out assignments with little or no review by the supervisor while work is in progress. She is experienced at applying concepts and methodologies and is knowledgeable in functional program characteristics and requirements to maintain USARC’s centralized civilian pay processes and procedures. As the technical authority in the civilian pay area, the appellant is responsible for actions such as planning and carrying out the assignment, resolving most conflicts that arise, coordinating the work with others as necessary, interpreting policy and regulatory requirements, and providing recommendations for improvements in order to meet budgetary program objectives. She keeps the supervisor informed of potentially controversial matters that may adversely impact the civilian pay program, e.g., when an organization requests overtime exceeding established targets. Also like Level 2-4, her supervisor reviews completed work for effectiveness in meeting requirements of expected results, the feasibility of recommendations, and adherence to requirements.
The appellant’s position does not meet Level 2-5. While she independently plans and carries out her work involving USARC’s civilian pay program, the nature of the appellant’s duties do not necessitate the level of decisions, commitments, and judgment typical of positions at Level 2-5. Implicit in Level 2-5 is a degree of program management authority not delegated to the appellant’s position. Although she serves as USARC’s technical advisor on civilian pay-related issues and activities, her position does not involve such work as recommending new systems or program emphasis that would lend itself to the administrative direction anticipated at Level 2-5. In short, Level 2-5 does not merely represent a high degree of technical independence but also a corresponding management role, beyond the authority vested in the appellant’s position, to define the basic content and operation of the program exceeding the technical aspects of individual assignments. Moreover, the appellant is responsible for a portion of a significant program (i.e., the civilian pay operation) as opposed to the overall budget program managed by her supervisor for the USARC.
Level 2-4 is credited for 450 points.
Factor 3, Guidelines
This factor considers the nature of guidelines and the judgment needed to apply them.
At Level 3-4, the employee typically works in situations where guidelines and policies are scarce and 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. At this level, 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 guidelines are: (1) OMB circulars, directives and regulations, and Treasury Department regulations; (2) judicial decisions and Comptroller General Decisions; (3) the employing agency’s broad program goals and policy statements that describe only the purpose for which a program or system was established; (4) requirements that define general specifications for management and financial systems or the parameters from which an accounting system is to be defined. At Level 3-4, the employee routinely develops specific objectives and devises 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, developing solutions and presenting findings; and examining returns for which there are no precedents. 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; guidelines on auditing contracts or on auditing regulated industries or other comparable guidelines that normally apply Government-wide; and/or tax examination policy applicable throughout the Internal Revenue Service. At Level 3-5, employees must use judgment and ingenuity and exercise broad latitude in interpreting the intent of applicable guidelines.
The appellant’s position meets Level 3-4. Like this level, her guidelines are varied and provide an outline of the concepts, methods, and goals to be followed but are also characterized as being of limited use and requiring her to develop methods when performing day-to-day work involving, e.g., establishing criteria for reprogramming funds, formulating estimates covering the civilian pay budget and operations for the USARC, and ensuring compliance with budget criteria, policy, and reporting requirements. The appellant interprets and applies civilian pay budget and financial policies, directives, precedents, and regulations, in addition to legislation regarding appropriations, in the management of USARC’s civilian pay funding and execution. Similar to Level 3-4, she exercises initiative and judgment in devising new methods of planning for and estimating budgetary needs, acquiring information, analyzing data, or modifying systems to accept new kinds of data. For instance, Public Law 116-6, dated February 15, 2019, authorized a 1.4 percent across-the-board increase for statutory pay systems and a .5 percent locality pay increase, retroactive to the first pay period in 2019. The appellant estimated the cost of implementing the appropriations bill, both prospectively and retroactively, for the USARC’s approximately 10,000 civilian employees and military technicians assigned worldwide. Level 3-4 is also descriptive of a situation where an employee uses a great deal of judgment and discretion and has broad latitude in interpreting and applying guidelines. Likewise, the appellant interprets and provides civilian pay guidance, procedures, and instructions to program managers USARC-wide. For example, she establishes instructions, as well as deadlines, for information she requires from managers submitting PCS, award, overtime, and other requests to her. The relatively general nature of the guidelines, exemplified by the interpretive issues addressed by the appellant, creates an environment reflective of Level 3-4 in which applicable precedents or detailed instructions from higher echelons are unavailable or of limited use.
The appellant seeks to credit her position at Level 3-5. As manager of USARC’s civilian pay program her guidelines include, but are not limited to, various budgetary and financial policies, directives, precedents, laws, and regulations; the JTR; Army Regulation 1-1 (Planning, Programming, Budgeting, and Execution), 37-49 (Budgeting, Funding, and Reimbursement for Base Operations Support of Army Activities), 672-20 (Incentive Awards), etc.; DFAS regulations, manuals, and policy memorandums; DOD FMR; GFEBS-related job aids; and other guidelines issued by OCAR, OMB, and OPM. These guidelines are more definitive and applicable to her work than the broad policy statements, basic legislation, laws, and agency goals described at Level 3-5. Also unlike the appellant’s position, Level 3-5 describes assignments where the employee is responsible for developing agency-level policies, regulations, and guidelines. While she provides guidance to program managers on award, QSI, overtime, and other targets; responds to civilian pay-related requests and issues; and provides interpretations of the guidelines when requested, her position does not require developing and implementing civilian pay guidelines to be used across the USARC. Because all civilian pay work is centralized and performed by her, the appellant’s position is not required to provide guidance to positions at the basic operating level performing civilian pay and other budget work as expected at Level 3-5.
Level 3-4 is credited for 450 points.
Factor 4, Complexity
This factor covers the nature, number, variety, and intricacy of tasks, steps, processes, or methods in the work performed; the difficulty in identifying what needs to be done; and the difficulty and originality involved in performing the work.
At Level 4-4, work consists of performing a variety of analytical, technical, and administrative work for substantive programs and support activities. These programs and activities are funded through a number of sources such as appropriations, allotments, reimbursable accounts, and transfers of funds between organizations. Programs and funding are unstable and subject to change throughout the fiscal year. The budget typically includes a wide range of object classes and line items for one or a few substantive programs and organizations. Alternatively, the budget may include fewer object classes and accounts, but through which a wide range of programs is funded. The employee identifies and analyzes changes in budgetary and/or financial policies, regulations, constraints, objectives, and available funds that affect the accomplishment of program objectives. The employee conducts research, identifies, and analyzes trends in the use of funds, and recommends adjustments in program spending that require the rescheduling of program workloads. At Level 4-4, the employee must choose the analytical technique appropriate for the task. Unpredictable short-term deadlines that vary according to financial/budgetary objectives, available funding, program goals, and workload make it difficult for the employee to identify trends in the use of funds, recommend program spending adjustments that require rescheduling of program workloads, and assist program managers and staff officials in interpreting the impact of, and planning for, multi-year financial/budgetary and program changes.
At Level 4-5, work consists of selecting and using many different and unrelated analytical techniques and methods relative to substantive agency programs with widely varying needs, goals, objectives, work processes, and timetables. This level includes budget execution work involving the most difficult funds control activities. These activities may include efforts to adapt budgetary policies, analytical methods, and regulatory procedures for use by subordinate echelons, and their centralized or consolidated equivalent. Work covers such matters as multi-year procurement of major weapons systems, construction projects, law enforcement activities, and delivery of payments and benefits to the public. Employees at this level recommend changes in funding and budget plans that if accepted may require management to revise substantive programs; develop proposals concerning alternative methods, sources, and timing of financing for substantive programs; and evaluate the mutual effects and interrelationships between program goals and accomplishments and budgetary resources and policies. At Level 4-5, the employee encounters difficulty in formulating, presenting, and/or defending budget requests. The employee must devise and apply innovative criteria to evaluate the progress and cost effectiveness of program plans, goals, and objectives. The employee encounters and resolves issues in work environments characterized by conditions such as continually changing program objectives, plans, and funding requirements resulting from new legislation, revised policies, and shifting demand for goods and services; conflicting program and budgetary requirements such as reduction in budget authority coupled with expansion of services to the public; implementation of a new substantive program that is complicated by the lack of productivity data upon which to base budget forecasts; varying economic and fiscal circumstances such as fluctuations in the exchange rate of the U.S. dollar against foreign currencies; and/or technological developments that have significant cost impact upon substantive agency programs.
The agency credited the appellant’s position at Level 4-5, but we find her position fully meets but does not exceed Level 4-4. Similar to this level, she performs a variety of analytical, technical, and administrative work for the substantive programs and activities of the USARC. Her work includes evaluating the different categories of civilian pay costs (e.g., salaries, awards, overtime, PCS, and other benefits), monitoring civilian pay policies and practices, recommending the distribution and reprogramming of financial resources, and identifying trends, deficiencies, and imbalances with program budgets. Like this level, the funding arrangements for the appellant’s civilian pay program and activities include appropriations, reimbursements, reprogramming between subordinate commands, and transfers with other commands and Federal agencies. Characteristic of Level 4-4, her work requires conducting research, identifying, and analyzing trends in the use of funds, and recommending adjustments in program spending. She develops phase plans for OCAR’s review and approval by analyzing the USARC programs’ current onboard strength, applying pay raises and awards percentages, estimating overtime percentages, and projecting the fill of vacant positions. After setting the award, QSI, and overtime targets for each organization, she monitors the current balance and execution rate for the estimated 10,000 civilian employees and military technicians assigned to the USARC’s 25 commands and 27 directorates. As expected at Level 4-4, the appellant’s work is critical to ensuring USARC’s civilian pay processes and procedures conform to applicable laws and regulations, and involves identifying and analyzing changes to financial policies, regulations, constraints, objectives, and available funds affecting the accomplishment of civilian pay program objectives.
Like Level 4-4, the appellant also evaluates resource needs requiring continual adjustments. This dynamic program environment makes it difficult for her to recommend program spending adjustments, identify trends in the use of funds, and assist management in interpreting the impact of, and planning for, multi-year budgetary and program changes. The appellant’s position favorably compares to the illustration in the JFS at Level 4-4, which describes a budget analyst that provides analytical services to support the formulation, justification, presentation, enactment, and execution stages of the budget process for a substantial segment of the agency’s budget for personnel salaries and expenses. The budget analyst illustrated by the JFS at Level 4-4 analyzes a wide range of past and present program and employment statistics and financial data; reviews requests for funding and proposed staffing levels in relation to current obligations and expenditures; determines the need to vary the sources and methods of obtaining information; and assesses the impact of changes in programs and regulations on salaries, travel, benefits, overtime, and related expenses on the agency’s budget. The illustrated position must use sound judgment to forecast the effects of revised levels of obligations and expenditures on current and future budget estimates. Similarly, the appellant’s position is responsible for returning the USARC’s unexecuted funding, establishing the amount by analyzing the status of funds and current execution rates, clearing unmatched transactions, and applying the anticipated awards and overtime amounts. She also resolves situations involving unfinanced requests, such as grievance settlements, and coordinates with OCAR and higher echelons when additional funding is required.
The appellant’s position does not meet Level 4-5. Unlike this level, her position does not require selecting and using many different and unrelated analytical techniques and methods relative to substantive agency programs with widely varying needs, goals, objectives, work processes, and timetables. The most critical function of her position is to ensure that civilian pay funding for USARC employees is adequate and appropriate. To avoid violation of the Anti-deficiency Act, the appellant ensures employees are paid correctly by verifying that the assigned cost center, activity type, activity and sub-activity group, civilian type, etc. are appropriate. When necessary, she fixes errors in GFEBS and other systems. The appellant regularly makes decisions and recommendations on whether to fund overtime and award requests based on current execution rates, payment of PCS costs, amount of unexecuted funding to be returned at the end of the year, and if and how funding should be reprogrammed so all programs may be fully executed. However, her work does not require devising and applying innovative criteria to evaluate the progress and cost effectiveness of program plans, goals, and objectives as expected at Level 4-5. In contrast, typical of the lower factor level, she formulates the execution of long-range budget forecasts and plans in support of OCAR’s Program Objective Memorandum (POM) recommendations on program fund allocations. In support of the POM process, the appellant provides estimates to OCAR on required funding related to DOL’s Office of Workers’ Compensation Programs. She considers the average number of past and current claims, applies the inflation rate, and calculates the current payment owed to DOL in reimbursement for costs associated with work-related injuries, diseases, and deaths. Unlike Level 4-5, because civilian pay is considered a must-fund requirement, she does not encounter the level of difficulty in formulating, presenting, and/or defending budget requests inherent in, for example, multi-year procurement of major weapons systems, construction projects, law enforcement activities, and delivery of payments and benefits to the public.
The JFS provides an illustration at Level 4-5 of a budget analyst position responsible for formulating, justifying, presenting, and executing the agency’s budget for its information technology program. The budget analyst described reviews, analyzes, consolidates, and revises budget estimates, justification statements, and budget execution plans submitted by subordinate organizational segments and field components, as well as advises program officials and budget staffs at lower echelons of the necessity for and type of budgetary action to be implemented to meet agency needs for computer hardware, software, and trained personnel. In contrast, since her budget execution work involves the USARC’s centralized civilian pay fund program and does not constitute the most difficult funds control activities, the appellant does not encounter and resolve issues in the work environment such as technological developments having significant cost impact upon substantive agency programs or other equivalent conditions.
Level 4-4 is credited for 225 points.
Factor 5, Scope and Effect
This factor covers the relationship between the nature of the work; i.e., the purpose, breadth, and depth of the assignments, and the effect of work products or services both within and outside the organization.
At Level 5-4, the scope of the work involves executing modifications to systems, programs, and/or operations, and/or establishing 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. For example, employees working in budget analysis formulate and/or monitor the execution of long-range (i.e., 3 to 5 years or longer) detailed budget forecasts and plans to fund the implementation of substantive agency programs and projects. The work includes establishing financial and budgetary goals, timetables, milestones, and other criteria against which the relative costs and benefits of program achievements can be measured. Programs supported involve such matters as the production and distribution of goods, construction, or the delivery of services to the public. Budget analysis at Level 5-4 may include planning the timely acquisition and use of funds through time-phased allotments and transfers of funds; adjusting long-range budget forecasts and monitoring their execution for assigned substantive programs; and analyzing costs, benefits, and trends in rates of obligation and expenditure funds. The effect of the work involves outcomes such as the amount and availability of funds for major substantive or administrative programs and services; or the budgets, programs, and interests of other Federal agencies.
At Level 5-5, the scope of the work involves isolating and defining unknown conditions, resolving critical problems, and developing new theories. For example, employees working in budget analysis analyze, advise on, and recommend solutions to budgetary problems in all phases of budget/financial administration. Often, officers, managers, analysts, and specialists at subordinate echelons either have been unable to resolve these problems or lack delegated authority to act on them. Characteristic problems include conflicts between established budgetary and/or financial policies or regulations and these types of matters: substantive missions and programs, Federal or State laws, Congressional intent, and national economic and social policies. Work often involves adapting new or revised methods of budgeting or financial management to substantive appropriated fund programs. At Level 5-5, 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.
The appellant seeks to credit her position at Level 5-6. The agency credited her position at Level 5-5 stating that as the technical authority and principal civilian pay administrator for the USARC, she prepares and secures approval of budget requests that adequately support the desired level of operations and meet financial and budgetary policy objectives, manages civilian pay costing and execution of funds aligned under multiple organizations, and reprograms funds as needed to ensure civilian pay costs are met. The agency also states her position serves to control the obligation and expenditure of funds in approved budgets.
We find the appellant’s position meets Level 5-4. Like this level, the appellant’s work involves a wide range of agency activities as her position has sole responsibility in the USARC for the administration of the day-to-day civilian pay program, which entails interpreting regulations and directives to analyze and resolve civilian pay issues ranging from the conventional to the unusual and advising program managers on operations. As at Level 5-4, her work includes establishing financial and budgetary goals, timetables, milestones, and other criteria against which the relative costs and benefits of program achievements can be measured. She analyzes costs, benefits, and trends in rates of obligation and expenditure of funds, and recommends ways to improve the utilization of funds. For example, in addition to determining the award, QSI, and overtime targets for each organization within the USARC, the appellant monitors usage to ensure targets and deadlines are met and makes recommendations when requests for amounts exceeding targets are submitted. Her civilian pay program work affects the reliability and timeliness of financial data, efficient use of funds, and ultimately the timely and accurate payment for the approximately 10,000 civilian employees and military technicians assigned to the USARC. The effect of her work is characteristic of Level 5-4, where work outcomes involve the amount and availability of funds for major substantive or administrative programs and services, or the way financial information is applied in planning organizational operations or the efficient use of funds. As opposed to the agency’s assessment, the appellant’s work is comparable to the Level 5-4 work illustration in the GS-0500 JFS, which describes a budget analyst position responsible for formulating, justifying, and monitoring the execution of long-range budget plans to fund the implementation of major substantive programs and services. Similar to the illustration, the appellant controls the obligation and expenditure of funds in approved budgets and assists in the internal planning and evaluation of organizational budgets and programs.
The appellant’s position does not meet Level 5-5. Unlike this level, there is no evidence the appellant develops new theories to analyze, advise on, and recommend solutions to budgetary problems in all phases of budget administration. In addition, her position is not responsible for resolving problems of the breadth or depth expected at Level 5-5. On the contrary, functioning at the operating level she resolves a variety of immediate civilian pay problems resulting from conflicts due to individual circumstances or discrepancies between payroll, HR, and financial systems. She ensures the payroll is executed correctly by resolving discrepancies as a result of the systems failing to interface correctly. She updates LOAs, creates and deletes employee records, and updates data records in GFEBS. She also develops recommendations for budgetary adjustments to support unanticipated changes in operations and/or funding (e.g., as a result of military technician over hires) and prepares documents to request increases or decreases in funds requiring approval of budget or program officials at higher echelons. Unlike Level 5-5, these and other problems she regularly encounters are not characteristic of Level 5-5 where problems involve conflicts between budget policies or regulations and the mission and program, Federal or State laws, Congressional intent, and/or national economic and social policies. The JFS provides an illustration at Level 5-5 of a budget analyst position at agency headquarters, providing expert analytical services, staff advice, and assistance to managers and administrators on acquisition and use of appropriated funds. The work of the illustrated position affects the timely, effective, and efficient accomplishment of specific nationwide multi-year program objectives and also affects the availability of funds for a variety of requirements such as building maintenance, contractual procurements, operating supplies, and personnel salaries. Contrary to the illustration, the appellant’s position solely impacts civilian pay program funds and does not affect the availability of a variety of requirements such as building maintenance, contractual procurements, operating supplies, and personnel salaries.
In order for the appellant’s position to be considered for assignment of Level 5-6, it must first fully meet the elements described in Level 5-5. However, as discussed above, we find the position fails to meet Level 5-5. Therefore, it is neither necessary nor appropriate to address Level 5-6 in this decision.
Level 5-4 is credited for 225 points.
| Summary | ||
| Factor | Level | Points |
| 1. Knowledge Required by the Position | 1-7 | 1250 |
| 2. Supervisory Controls | 2-4 | 450 |
| 3. Guidelines | 3-4 | 450 |
| 4. Complexity | 4-4 | 225 |
| 5. Scope and Effect | 5-4 | 225 |
| 6. & 7. Personal Contacts and Purpose of Contacts | 3-c | 180 |
| 8. Physical Demands | 8-1 | 5 |
| 9. Work Environment | 9-1 | 5 |
| Total | 2,790 |
This point total falls within the GS-12 range (2755-3150) on the grade conversion table provided in the GS-0500 JFS.
Decision
The appellant’s position is properly classified as Budget Analyst, GS-560-12. Assignment of a parenthetical title is at the agency’s discretion.