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In This Section

Classification & Qualifications Appeal Decisions

Washington, DC

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

Katherine L. Flournoy
Health Technician
Ambulatory Care Service
Veterans Health Administration
U.S. Department of Veterans Affairs
Richard L. Roudebush VA Medical Center
Indianapolis, Indiana
Title at agency discretion

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



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, appendix 4, section G (address provided in appendix 4, section H).

As indicated 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 and a Standard Form 50 showing the personnel action taken.  The report must be submitted within 30 days from the effective date of the personnel action to the OPM office that accepted the appeal.

Since this decision lowers the grade of the appealed position, it is to be effective no later than the beginning of the sixth pay period after the date of this decision, as permitted by 5 CFR 511.702.  The applicable provisions of parts 351, 432, 536, and 752 of title 5, Code of Federal Regulations, must be followed in implementing the decision.  If the appellant is entitled to grade retention, the two-year retention period begins on the date this decision is implemented.  The servicing human resources office must submit a compliance report containing the corrected position description and a Standard Form 50 showing the personnel action taken.  The report must be submitted within 30 days from the effective date of the personnel action to the OPM office that accepted the appeal.


On October 9, 2014 OPM’s Agency Compliance and Evaluation (ACE) Chicago accepted a classification appeal from Ms. Katherine L. Flournoy.  The appellant’s position is currently classified as Health Technician (Ophthalmology), GS-0640-07 and is located in the Eye Clinic, Ambulatory Care, Richard L. Roudebush VA Medical Center, Department of Veterans Affairs, Veterans Health Administration, Department of Veterans Affairs Indianapolis, Indiana. The appellant believes her position should be upgraded to the GS-08 grade level.  OPM received the agency’s completed administrative report on December 29, 2014 and have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).  To help decide the appeal, we conducted a phone audit with the appellant on January 9, 2015, and with her first and second level supervisor on January 13, 2015.  In reaching our decision, we have carefully considered all of the information obtained from the interviews, as well as all other information of record provided by the appellant and her agency.

General issues

The appellant believes her position warrants a higher grade due to the complexity of work, responsibility for patient care and treatment, and complexity of medical equipment operated.  However she did not provide any rationale referring to published OPM position classification standards (PCSs) to support upgrading her position.  She questions the accuracy of her current PD, compares her position to a higher graded position within her department, and identifies high volume of work performed as reasons for the requested increase in grade. 

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 all warrant the same classification, she may pursue the matter by writing to her regional 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.

By law, we must classify positions solely by comparing their duties and responsibilities to OPM standards and guidelines (5 U.S.C. 5106, 5107, and 5112). Since comparison to standards and guidelines is the exclusive method for classifying positions, we cannot compare the appellant’s position to others as a basis for deciding the appeal. Therefore, we have considered the appellant’s statements only insofar as they are relevant to making that comparison. 

Volume of work cannot be considered in determining the grade of a position (The Classifier’s Handbook, chapter 5).

The appellant and the supervisor initially certified the accuracy of the Health Technician (Ophthalmology) PD however, during subsequent telephone interviews, both the appellant and supervisor made statements of work which were inconsistent with those identified in the official position description.  For example:  Under major duties it states that the appellant is expected to modify, maintain, and trouble shoot equipment, however we found that the appellant does not actually modify equipment, but rather uses designed adjustment features to apply equipment contact surfaces to specific patients (i.e. chin height adjustment etc.) or inputting specific patient information into equipment to establish test parameters. We also found that troubleshooting does not actually occur.  If equipment is not operating correctly, the technician might turn it off and back on, or check to see if it is plugged in.  If this has no effect, the equipment is taken out of service and a work order is submitted.   Under Factor 1 we found a list of test equipment which the appellant is expected to operate, yet some of the equipment is not used (i.e. Goldman or Humphrey Visual Field Machine) and at least one test actually being performed (i.e. Fluorescein Angiography Photography Machine) is not listed.  Under Factor 2 it states that the incumbent works independently, rarely consulting the physician for technical advice, but in actuality the incumbent regularly consults with peers, supervisor, and physicians regarding technical processes and issues associated with tests and results.  It also states the technician independently plans, designs, and carries out the work of the clinic, yet we found that, although independent work does take place, guidance and protocol direct the daily work processes.  Additionally, the supervisor reviews appointments a week in advance, discusses key issues and challenges, and assigns patients and technicians to specific physicians.  Under Factor 3 the PD identifies typical guidance used by technicians such as; clinic structure, process manual, equipment operating manuals, technical manuals, and drawings and schematics, however we found that the PD does not mention Veterans Health Administration and Medical Center policies nor does it mention Medical facility and eye clinic standard operating procedures (SOPs) which are also readily available within the clinic.  It also states guidance is available however technicians must always search for state-of-the-art changes in the field, such as: reading journals, technical manuals, and attending continuing education courses, yet we found that standard guidance (i.e. rules, regulations, policies, SOPs, and procedure and technical manuals) cover all requirements for daily work in the eye clinic and that searching for guidance outside these readily available sources is not performed, or expected. Under Factor 4 the PD states that work performed by the technician requires variations of technical factors to accommodate the patients’ condition, extend standard test methods, or change procedure to affect expected results, however we found the majority of tests and screens were standard by nature and were clearly associated with specific conditions or specifically requested by the attending physician, and that any deviation from this protocol must be considered and approved by the supervisor and attending physician.  Under Factor 7 the PD states the technician coordinates activities of the clinic, however we found that the appellants’ supervisor and the nurse manager are responsible for coordination of clinic activities. Under Factor 8 the PD states the technician moves from one exam room to another many times a day, experiences prolonged standing, walking, and sitting, lifts moderate weights when moving charts and supplies, must maneuver wheelchairs and litters when transporting patients, and lifts and positions patients for tests and procedures.  However, we found that the appellant does not spend prolonged periods of time in any position or posture, rarely lifts anything heavier than ten pounds, positions patients by turning head, and on the rare occasion when patient transfer is needed they utilize mechanical lifts or assistance. 

Because the appellant’s PD is inaccurate it does not meet the standard of adequacy addressed on pages 10-11 of the Introduction, and therefore the agency must revise the PD to reflect our findings. 

Assignments that constitute a position are the duties and responsibilities assigned by management (see 5 U.S.C. 5102(a)(3) and 7106(a)(2)(B) and actually performed on a regular and recurring basis by the occupant of the position.  In adjudicating appeals, 5 U.S.C. 5112(a) requires that positions be classified on the current facts as to the duties, responsibilities, and qualifications required.

Position information

The appellants’ position is located within the eye Clinic at the Richard L. Roudebush VA Medical Center, which has teaching affiliations with the Indiana University medical center.  The eye clinic provides optometric and ophthalmic care and treatment for both inpatients and outpatients. 

The appellants’ position involves performing basic patient intake and a variety of optometric and ophthalmic tests using typical instruments and equipment for the specialty.  In performing basic patient intake, the appellant reviews the patients’ medical notes looking for indications of current and past conditions and physician notes identifying treatment protocols.  Then the appellant interviews the patient or caregiver to obtain a subjective history, chief complaint, current medications, vital signs, and other information which may be helpful in identifying areas of concern or appropriate tests to be performed.  In the case of un-scheduled patients, such as walk-ins and transfers from the emergency room, the appellant would perform the aforementioned intake and advise the physician of findings.  The appellant also reviews for indications and contra indications for administering standard ocular medications, such as drugs to dilate the eye.  The appellant uses basic knowledge of first aid and cardio pulmonary resuscitation (CPR) to address unexpected emergencies and to perform minor tasks such as changing bandages and dressings.  The appellant may assist in training or instructing new employees, interns, and medical residents on equipment use and eye clinic processes and procedures. The appellant uses knowledge of basic medical terminology as well as optometric and ophthalmic terminology to understand patient notes and physician orders and to communicate with medical and non-medical personnel. 

The appellant performs a variety of specialized optometric and ophthalmic tests and studies using both stationary and mobile equipment.  The appellant must regularly demonstrate the knowledge, skill and ability to operate each piece of testing equipment competently and safely.  All tests are performed in accordance with established policy, SOPs, and clinic protocols.  Testing equipment includes; Humphrey Zeiss Ocular Coherent Tomography, Pachyemetry ECT, Potential Acuity Meter (PAM) test, Auto-refractor/Kerotometer, Corneal Topography, Brightness Acuity Test (BAT), Applanation Tonometry with Goldman or Tonopen, Fundus Photography, Flourescein Angiography Photography (essentially the same as Fundus Photography), and performs a variety of visual field testing. When performing tests, the appellant must ensure proper alignment of both patient and equipment, and performs the test.  Some tests require the appellant to adjust settings or input parameters unique to each patient.  Once the test is completed, the appellant then records the results in the patients’ electronic medical record and shares the results with the physician who, depending on the results, may re-order the test, or order additional tests.  If the appellant finds unusual or unexpected results or conditions, she reports them to the physician for possible additional testing.  Some equipment, like the Argon and YAG lasers, are not operated by the appellant, but she does turn them on and initiate safety protocols by using signs to indicate the laser is in use.

The appellant is responsible for cleaning equipment and instruments after each patient.  Most cleaning consists of wiping surfaces with alcohol, or replacing protective paper coverings.   Instruments which come in contact with human tissue are sprayed with a sterilizing solution, packaged, and sent to the sterile processing department for processing.  The appellant ensures that exam rooms are stocked with supplies and instruments at the end of each day, advising responsible parties of dwindling supply levels and completes all quality insurance sheets (i.e. list of required tasks) each day.

The appellant performs minor calibration on Tonometers by inputting accurate weight, and Lane Acuity Projectors by inputting exam room length.  These are very basic procedures and only take a few minutes to perform.  The appellant also changes light bulbs, batteries, and scratched or damaged lenses in some of the equipment as needed.  When equipment does not operate correctly, the appellant may attempt rebooting, turning the equipment off and back on, or checking to see if the equipment is plugged in, or processes of similar complexity.  If these attempts do not work, the appellant takes the equipment out of service and initiates a work order for repair.

Series, title, and standard determination

The agency has classified the appellants’ position in the Health Aid and Technician Series GS-640.  Neither the appellant, nor the supervisor, disagree with this determination, and we concur.

The GS-0640 position classification standard (PCS) does not prescribe specific title however the standard suggests Health Technician for GS-04 and above. The agency may construct a title in keeping with the work performed.  In doing so, the agency should adhere to the titling guidance in section III.H.2 of the Introduction.

The GS-640 standard contains no grade level criteria. It directs that nonsupervisory positions be evaluated by reference to grade level criteria in standards for other nonprofessional technical positions in the GS-600, Medical, Hospital, Dental and Public Health Group. To grade the appellant’s position, we have cross referenced to the grading criteria contained in the classification standard for the Medical Instrument Technician Series.

Similar to the appellants’ position, work in the GS-649 series performs diagnostic examinations or medical treatment procedures as part of the diagnostic or treatment plan for patients, which involves operating or monitoring diagnostic and therapeutic medical instruments and equipment, and performing related patient care activities. Incumbents of such positions apply knowledge of the operating characteristics of the equipment, and a practical knowledge of basic medical sciences such as human anatomy and physiology. Although the appellant does not operate the types of medical instruments and equipment discussed in the GS-649 standard (e.g., cardiac, ultrasound, hemodialysis), she does perform a variety of ophthalmology tests and procedures using specialized instruments and equipment to perform diagnostic tests of patients vision and must have a practical understanding of medical data generated by patient/equipment connections, and have a basic understanding of the anatomy and physiology of the eye and of eye disease. Using equipment to perform diagnostic examinations occupies about 90% of her work time.  Her remaining duties (occupying about 10% of her work time) consist of reviewing supply levels, restocking examination rooms, cleaning and sterilizing durable medical equipment, and clerical and administrative support functions which are neither series nor grade controlling.  Only duties that occupy at least 25% of an employee’s time typically affect the grade of a position, as specified in the Introduction, section III.J. Therefore, these duties will not be evaluated in this decision.

Grade determination

The GS-649 standard uses the Factor Evaluation System (FES) that employs nine factors. Under the FES, each factor level description in a standard or guide describes the minimum characteristics needed to receive credit for the described level. Therefore, if a position fails to meet the criteria in a factor level description in any significant aspect, it must be credited at a lower level. Conversely, the position may exceed those criteria in some aspects and still not be credited at a higher level.

Factor 1, Knowledge required by the position  

This factor measures the nature and extent of information or facts that a worker must understand to do acceptable work, such as the steps, procedures, practices, rules, policies, theories, principles, and concepts, and the nature and extent of the skills needed to apply this knowledge. The agency assigned Level 1-4 for this factor based on required knowledge and skill in operating medical equipment to perform screens and tests on eye clinic patients, and we agree.

At Level 1-4, employees have a practical knowledge of instruments used in the specialization to make adaptations and adjustments and interpret test results based on previous experience and observation. This level requires a practical knowledge of intricate examination or treatment procedures, a basic knowledge of anatomy and physiology, and common diseases and their effect associated with the specialization. Employees use skill to apply knowledge in adapting instruments to perform a full range of specialized tests or non-routine diagnostic or treatment procedures requiring many steps, and various approaches and procedures to findings from the early steps. They have knowledge of pharmacology and chemistry to understand drug action, effects, and method of administration. They have skill to prepare summaries of test results, workload reports, and related documents.  

At Level 1-5, employees must possess all knowledge described at level 4 as well as possess knowledge of the instruments and complex procedures of the specialization to perform special complicated examinations or treatments for which there are no standard instructions and procedures; have knowledge of anatomy and physiology including an in-depth understanding of the functioning of the major systems and internal organs to interpret requests and to recognize the need for additional tests or a different position; knowledge of a variety of related acute disorders and diseases, their effects on the organs, and methods of treatment; knowledge of pharmacology including the classification and administration of drugs, patient responses, and common dosages; skill to apply such knowledge to perform relatively new diagnostic or treatment procedures involving very fine distinctions or many delicate and exacting steps, the instruments are complex and the setting and measurements are fine; skill to change and adapt parts of the instrument to meet especially difficult situations; knowledge of and skill to start emergency cardiac arrest procedures and monitor vital signs during examinations; and skill to prepare and analyze quality control of test results.

Level 1-4 is met. Similar to this level, the work requires a thorough understanding of typical procedures and tests in order to set up equipment and to ensure they are sterile and function properly.  Only two machines require calibration, but when doing so, the appellant ensures they are set to manufacturers’ parameters. The appellant makes equipment adjustments for specific tests based on SOPs, process parameters, desires of the physician, patient needs, or other appropriate considerations.  Like Level 1-4, the work requires the appellant to recognize possible inconsistencies of test results and make equipment or patient position adjustments to ensure more accurate readings and results or to recommend different approaches based on observations and practical knowledge of equipment, testing procedures and patients’ physical characteristics. She coaches resident physicians and others not familiar with the clinic’s equipment on settings, operation, and techniques for use. She also responds to physicians’ questions about the test result and follows suggestions on how to improve consistency and accuracy of product.  The work requires knowledge of common eye diseases and their effect on optometric and ophthalmic concerns, knowledge of the anatomy, physiology, and pathophysiology of the eye and vision processes, and knowledge of medical terminology sufficient to identify and apply written orders and requests. The appellant also must prepare and enter notes describing medical and diagnostic screens and tests, findings, and test results into the automated record system.

Level 1-5 is not met.  Level 1-5, employees regularly perform special complicated examinations or treatments for which there are no standard instructions and procedures. They use knowledge of anatomy and physiology including an in-depth understanding of the functions of the major systems and internal organs to interpret requests and to recognize the need for additional tests or different position. They use knowledge of a variety of related acute eye disorders and diseases, their effects on vision as a whole, methods of treatment, and knowledge of pharmacology to perform relatively new diagnostic or treatment procedures involving very fine distinctions or many delicate and exacting steps. They also have skill in changing and adapting parts of the instruments to meet especially difficult situations. 

Unlike Level 1-5, the appellant performs a variety of typical screens and tests using standard equipment and techniques, which are covered by specific instructions and well established procedures.  Non-standard screens and tests require permission or instruction from the supervisor or the physician, and the need for additional testing does not originate from the appellant’s in-depth understanding of the components of the eye and related systems, but rather from indications derived from established protocols, standard operating procedures, or direction from senior medical professionals.  The appellant does not change or adapt parts, instruments or equipment in the true sense, but rather uses designed adjustments and interchangeable instruments to perform screens and prepare equipment to fit the height, width, depth and contour of each patient, and in most cases, positioning the patient is no more complicated than turning the head.

Level 1-4 is credited for 550 points.

Factor 2, Supervisory controls

This factor covers the nature and the extent of direct or indirect controls exercised by the supervisor, the employee’s responsibility and the review of completed work. The supervisor exercises controls in the way assignments are made, instructions are given to the employee, priorities and deadlines are set, and objectives are defined. Responsibility of the employee depends upon the extent to which the employee is expected to work independently as instructed and use of initiative in the performance of routine assignments.  The agency assigned Level 2-3 based on general supervision and independence of work with occasional consultation, and we agree.

For work at Level 2-3, the highest level described in the PCS, the supervisor defines work goals, priorities and deadlines. When working as a member of a team, physicians accept the technician’s knowledge of complex procedures. Instructions include what is to be done, medical conditions expected and what equipment is available for particular special procedures. The technician uses judgment and initiative that include selecting appropriate instruments and methods, recognizing conditions that cause erroneous results and troubleshooting complex instruments. The supervisor helps the employee with unusual situations that have no clear precedents.

 Level 2-3 is met.  Like this level, the supervisor or, clinic nurse manager, has weekly and daily meetings with the appellant to define goals, prioritize workload and provide additional instruction for unique or difficult patients.  the appellant works as a member of a team and, although the physician is responsible for reviewing all test results, the appellants’ quality and consistency of work is generally trusted and relied upon. Once patient workload has been assigned and any specific medical conditions, exceptions or instructions have been provided, the appellant performs her work with a fair amount of independence using SOPs, protocol, and familiarity with individual physicians’ style and requirements to determine which tests and screens to perform.  The appellant brings unusual situations and issues to the supervisor or attending physician for guidance and direction.

Level 2-3 is credited for 275 points.

Factor 3, Guidelines

This factor considers the nature of guidelines and the judgment needed to apply them.  The agency assigned Level 3-3 claiming guidelines were available, but not always applicable, requiring the appellant to use judgment for unexpected patient responses.  However we determined that the actual use of guidelines most closely matches Level 3-2.

At Level 3-2, well-established procedures for doing the work are available. Specific guidelines include written descriptions of standard tests or treatment procedures; written or oral instruction from the physician; instrument manuals containing instructions for the assembly and maintenance of the medical instrument; and instructions for procedural and administrative aspects of the assignment (e.g., sterilizing and testing equipment, transport equipment, documenting patient records of tests or treatment, ordering and storing equipment and supplies). The number and similarity of guidelines and work situations require the technician to use judgment in identifying and selecting the most appropriate guidelines, reference, or procedure (e.g., using appropriate methods to calibrate or standardize instruments); making minor deviations to adapt guidelines in specific cases (e.g., manipulating or changing instruments to meet test requirements); and determining which of several established alternatives to use in checking and correcting a problem.

At Level 3-3, guidelines are available but not completely applicable to the work. The employee must frequently search textbooks, journals, and technical manuals for application to individual cases. Decision criteria do not cover every situation (e.g., confirming unusual test results; using an altered technique; assessing and correcting unexpected reactions or errors; or the complexity of patients’ illness and physical condition). The technician uses judgment to adapt and change procedures, adopt or develop new procedures or techniques for individual problems. The technician uses initiative in learning new developments in the field and in recommending changes to improve service, correct deficiencies, and improve reliability of test and treatment results. The procedures and techniques adapted or developed by the technician form the basis for hospital standardization.

Level 3-2 is met. Like this level, numerous guidelines in the form of equipment operating manuals, policies, standard operating procedures, procedure manuals, and other written and verbal guidance are readily available and directly applicable to screens, tests, and procedures performed by the appellant.  Similar to Level 3-2, the appellant uses judgment in selecting and applying the most appropriate guidance. Like Level 3-2, the supervisor meets daily with all technicians (including the appellant) to assign work, answer questions, and provide additional information and direction for particularly difficult or unusual patients.  The supervisor or nurse manager also hosts weekly meetings to identify deficiencies and needs, and discusses appropriate processes, procedures, and protocols.  In cases where new and unusual issues and circumstances arise the appellant is expected to consult the supervisor or attending physician for guidance and direction before proceeding.

Level 3-3 is not met.  Although the appellant uses judgment to decide which guidance to use for a particular situation, guidelines are readily available and cover the majority of daily work.  The appellant does not adapt or change procedures nor does she adopt or develop new procedures or techniques for individual problems.  Unlike Level 3-3, the appellant is not allowed to deviate from available guidance without authorization.  The appellant does not perform extraordinary searches for guidance outside those readily available to her within the eye clinic, and although the appellant is encouraged to keep abreast of new developments and make recommendations for improvements, she states this is not required and she rarely performs this type of search.  The appellant’s individual actions do not serve as the basis for clinic-wide standardization as expected at Level 3-3.

Level 3-2 is credited for 125 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. The agency assigned Level 4-3 for complexity of work, claiming the appellant performs a wide variety of duties involving different specialized tests, procedures and diagnostic methods.  However, we determined that complexity of work most closely matches Level 4-2.

At Level 4-2, work consists of standardized and related duties involving several sequential steps, processes, and methods to perform a variety of diagnostic or treatment tasks of limited difficulty. Decisions about what needs to be done involve various choices requiring the technician to recognize the existence of and differences among a few easily recognizable alternatives (e.g., the technician considers factors which are clear, comparable, and readily checked to adjust diagnostic or treatment equipment and procedures to a patient’s medical condition). At Level 4-2, work includes such tasks as discriminating between normal and abnormal test results, recognizing factors affecting results, and identifying technical or instrument related problems.

At Level 4-3, work includes a variety of duties involving performance of different specialized diagnostic and treatment procedures, methods, and techniques. Decisions about what needs to be done depend on instruments, examination and treatment procedures, and other variables. Work typically requires interpreting a variety of conditions and elements such as patient condition, medication, or instrument performance to be sure of test results. For example, the technician may change settings based on a sudden onset of physical signs or symptoms of distress by the patient. The chosen course of action is selected from several alternatives (e.g., the technician selects a different procedure when a test yields unacceptable results). The technician must identify and analyze factors related to the equipment operation and patient responses to discern their interrelationships. At this level, emergency situations require precise timing and coordination of action with others while making quick and accurate adjustments to the instrument in response to physician orders or patient condition.

Level 4-2 is met. Similar to this level, the work includes performing a variety of standard patient screening, tests, and examinations such as: OCT, Visual Fields, photography, etc. in preparation for visit with medical professional. The appellant’s work also requires recognizing abnormal test results and repeating tests for more accurate readings and identifying and reporting equipment and instrument malfunctions to the facility biomedical equipment repair technicians for further action.  The appellant asserts that adding fluorescein angiography photography to her current optometric and ophthalmic tests and screens, qualifies as more complex work.   Although this test requires security access, the test its’ self is very similar to the fundus test already being performed by the appellant.  It is also important to note that this test is only performed as needed, and only during the last hour of each work day (12% of the work week).  All tests and screens (including fluorescein angiography photography) follow a distinct and clear course of action, and variables impacting the decisions on when and how to set equipment for each patient are typically easy to recognize based on current guidance, experience gained from past precedents, or direction from the supervisor or physicians. 

Level 4-3 is not met.  At this level, the technician has more responsibility to determine the patient’s condition, administer medication, and modify instruments and equipment than is demonstrated by the appellant.  The appellant normally performs a basic patient intake  (i.e. reviews medical notes, obtains vital signs, performs subjective medical history, determines chief complaint and current medications, etc.), identifies appropriate tests typically associated with certain conditions, or in accordance with established procedure and protocol, and checks with attending physician when questions or issues arise.  Unlike Level 4-3, the appellant rarely performs tests on urgent or emergent patients.  When urgent or emergent situations occur, the appellant is expected to immediately alert the clinic nurse or the attending physician to ensure appropriate care.  Patients seen by the appellant undergo screens and tests clearly defined by policy, protocol, and standard operating procedures therefore decisions on which tests to perform are more clear-cut than expected at Level 4-3 where the technician bears greater responsibility for deciding which tests, examinations and treatments to perform, and has more latitude and responsibility for reacting to patient emergencies.    

Level 4-2 is credited for 75 points.

Factor 5, Scope and Effect

This factor covers the relationship between the nature of the work (i.e., purpose, breadth, and depth of the assignment) and the effect of work products or services both inside and outside the organization.  The agency assigned Level 5-3 due to a variety of different diagnostic tests and procedures performed.  However we determined that the actual scope and effect of work performed most closely matches Level 5-2.

At Level 5-2, work involves performance of a variety of specific diagnostic procedures and treatment techniques which represent a significant segment of the total diagnostic and treatment plan for the patient. Work has a significant impact on the accuracy and reliability of further treatment.

At Level 5-3, work involves performance of a variety of specialized diagnostic and treatment procedures. Positions at this level provide diagnostic and treatment services during regular and recurring critical care situations. Work has a significant impact on the patient’s well-being.

Level 5-2 is met. Similar to this level, the appellants’ performs a variety of standard diagnostic screens and tests.  The results of these are used by the attending physician to treat the patient.  The appellant’s work directly impacts the accuracy and reliability of test results. 

Unlike Level 5-3, the screens and tests performed by the appellant are standard, and non-invasive.  This does not meet the intent of Level 5-3 where technicians are regularly involved in critical care situations where patients regularly have acute, even life-threatening conditions.

Level 5-2 is credited for 75 points.

Factor 6, Personal contacts

Personal contacts include face-to-face contacts and telephone dialogue with persons not in the supervisory chain. Levels described under this factor are based on what is required to make the initial contact, the difficulty of communicating with those contacted, and the setting in which the contact takes place (e.g., the degree to which the employee and those contacted recognize their relative roles and authorities).  The agency assigned level 6-2, stating the primary contacts of the appellant were with medical center staff, patients and family members, and students and faculty from affiliated universities, and we agree.

Like Level 6-2, the appellant’s primary contacts are with patients, patient family members, professional and non-professional staff throughout the local medical center, and professional and non-professional staff and students from Indiana University medical center.

Level 6-2 is credited.

Factor 7, Purpose of contacts

The purpose of the contacts ranges from factual exchange of information to situations involving significant or controversial issues and differing viewpoints, goals or objectives. The personal contacts that serve as the basis for the level selected for this factor must be the same as the contacts which are the basis for the level selected for Factor 6.  The agency assigned Level 7-b, claiming that the appellant coordinates work and resolves problems of the eye clinic.  However we found that the actual purpose of contacts most closely match Level 7-A.

At Level 7-a, the primary purpose of contacts is the exchange of facts and information.

At level 7-b, the primary purpose of contacts is to coordinate work efforts and resolve technical problems.

Level 7-a, is met. Similar to this level, the appellant’s contacts are primarily to provide information to patients, their family and staff within her medical center, as well as Indiana University medical center staff; performs standard patient intake, determines the purpose for the visit, identifies current medications being taken and the chief complaint; performs prescribed screens and tests and provides this information to the physician; provides the patient and caregivers with information associated with their clinic visit, medication, and which signs and symptoms would warrant urgent or emergent care; and assists medical residents and other staff with questions on how to perform typical eye clinic processes and tests.

Unlike Level 7-b, the appellant is not expected to actively and regularly work with others to identify operational and procedural issues and problems and coordinate with others to resolve them.  The appellant’s primary work involves performing screens and tests within approved parameters, reporting the results, and passing information to patients and caregivers.  When she identifies inconsistencies and concerns she passes the information onto the appropriate individual or group, such as; supervisor, clinic nurse manager, physicians, sterile processing unit, supply, patient scheduling, and biomedical equipment repair technicians, for resolution. 

Level 7-a is credited.

The combined factors are credited at Level 2a for 45 points.

Factor 8, Physical demands

This factor covers the requirements and physical demands placed on the employee by the work assignment. The agency assigned Level 8-2 due to regular and recurring physical exertion required.  However, we determined that the actual physical demands most closely match Level 8-1.

At Level 8-1, the work requires no special physical demands. It may involve some sitting, walking and standing for short periods or carrying light instruments and supplies.

At Level 8-2, the work involves long periods of moving about the work unit. Work requires regular and recurring bending, lifting, stooping, stretching, lifting, and repositioning patients, or similar activities.

Level 8-1 is met.  Like Level 8-1, the appellant performs a variety of activities including sitting, bending, reaching, walking, standing, or carrying light instruments and supplies.  The appellant stands and sits to perform screens and tests and to gather and enter data into patients’ medical records and computer data storage tools, walks to and from the waiting room and exam rooms, and occasionally push a wheelchair for short distances.  Although there is a variety of activities and postures, none are performed for prolong periods of time.

Level 8-2 is not met.  Although the physical demands placed on the appellant include periods of standing during the evaluation of patients, walking to various work stations within the eye clinic, sitting during intakes, tests, and computer work, and reaching for charts, supplies, and to operate equipment, these activities evenly are mixed so that the appellant experiences a variety throughout the course of the work day rather than any activity being disproportionately prolonged.  It is also worth noting that objects in excess of 10 pounds are rarely handled by the appellant.  Unlike Level 8-2, the appellant seldom exerts herself in positioning and transferring patients as the patient typically follows voice commands and transfers requiring assistance are typically performed with a mechanical lift. Therefore the regular and recurring physical demands of the appellant do not meet Level 8-2

Level 8-1 is credited for 5 points.

Factor 9, Work Environment

This factor considers the risks and discomforts in the employee’s physical surroundings or the nature of the work assigned and the safety regulations required. Although the use of safety precautions can practically eliminate a certain danger or discomfort, such situations typically place additional demands upon the employee in carrying out safety regulations and techniques.  The agency assigned Level 9-2 due to the requirement for above average safety precautions and risk of exposure to infectious diseases, and we agree.

At Level 9-2, Technicians perform the work in a setting involving regular and recurring exposure to infectious and contagious diseases, odors and other risks which require special health and safety precautions such as wearing protective clothing such as gloves, masks, or, lead aprons.

The appellant’s position fully meets but does not exceed Level 9-2.  The appellant regularly wears gloves and masks to protect her from exposure to infections and contagious diseases. 

Level 9-2 is credited for 20 points.

Factor Level Points
1.  Knowledge Required by the Position 1-4 550
2.  Supervisory Controls 2-3 275
3.  Guidelines 3-2 125
4.  Complexity 4-2 75
5.  Scope and Effect 5-2 75
6.  Personal Contacts 6-2
7.  Purpose of Contacts 7-a 45
8.  Physical Demands 8-1 5
9.  Work Environment 9-2 20
Total Points 1170



The appellant’s position is properly classified as GS-640-6. The position title is at the agency’s discretion.


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