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Classification & Qualifications Appeal Decisions

Washington, DC

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

[appellant's name]
Health Technician
[service] Service
Veterans Affairs Medical Center
U.S. Department of Veterans Affairs
[city, state]
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 (CFR), this decision constitutes a certificate which is mandatory and binding on all administrative, certifying, payroll, disbursing, and accounting officials of the Government.  The agency is responsible for reviewing its classification decisions for identical, similar, or related positions to ensure consistency with this decision.  There is no right of further appeal.  This decision is subject to discretionary review only under conditions and time limits specified in the Introduction to the Position Classification Standards (Introduction), appendix 4, Section G (address provided in appendix 4, section H).

Decision sent to:

[appellant’s name and HR office addresses]


On December 23, 2013, OPM’s Atlanta Agency Compliance and Evaluation accepted a classification appeal from [appellant’s name].  The appellant’s position is currently classified as Health Technician, GS-640-8, but he believes it should be classified to a higher grade level in the GS-601 General Health Science Series.  The position is assigned to the [service] (Service), Veterans Affairs Medical Center, U.S. Department of Veterans Affairs (VA), in [city, state].  We received the complete agency’s administrative report on January 17, 2014.  Due to program workload considerations, the appeal was transferred to Dallas Agency Compliance and Evaluation for adjudication.  We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

Background and general issues

The appellant’s position was previously classified as Health Technician, GS-640-7.  He filed a classification appeal with VA’s Office of Human Resources Management.  Their January 21, 2013, decision determined the position was appropriately classified at the GS-8 grade level.  The appellant subsequently filed a classification appeal with OPM.

The appellant asserts his duties are similar to those performed by higher-graded GS-601 positions assigned to other hospitals within VA and the U.S. Department of the Army (DA).  He forwarded vacancy announcements for a GS-601-9 position with VA and a GS-601-12 position with DA.  In reviewing the documents, we noted the vacancy announcements appear to describe positions with duties similar to the appellant’s position with no discernible differences in the major duties described.  Since vacancy announcements are not official classification documents, we lack sufficient information to warrant our tasking a classification consistency report on the positions cited by the appellant.  By law, we must classify positions solely by comparing their duties and responsibilities to OPM position classification standards (PCS) and guidelines (5 U.S.C. 5106, 5107, and 5112).  Since comparison to the PCSs and guidelines is the exclusive method for classifying positions, we cannot compare the appellant’s current duties to other positions, which may or may not be classified properly, as the basis for deciding his appeal.

By law, the VA and DA must classify positions consistently with published classification standards and in accordance with the principle of equal pay for substantially equal work.  Under 5 CFR 511.612, agencies must review their own classification decisions for identical, similar, or related positions to ensure consistency with OPM certificates.  The VA has primary responsibility for ensuring classification consistency at its medical centers, while the Defense Civilian Personnel Advisory Service (CPAS) has responsibility for classification consistency within DA and other Department of Defense components.  By separate letter, we are apprising VA, DA, and CPAS of our classification concerns regarding inconsistencies in the evaluation of the similarly described duties and responsibilities.

Position information

The Medical Center provides services to the estimated 175,000 veterans in the [state] counties of [name], [name], and [name].  The facility operates 432 hospital beds, an attached four-story community living center, two major satellite outpatient clinics, and five community based outpatient clinics.

The Service provides treatment to both inpatients and outpatients with disabilities resulting from musculoskeletal, neurological, orthopedic, general medicine, mental health, and surgical origins.  As the acupuncturist, the appellant is responsible for performing diagnostic and therapeutic techniques grounded in traditional and modern Chinese medical concepts and methods, with the goal being to promote health and treat neurological, organic, or functional disorders by the stimulation of various points on the surface of the body.  He integrates different modalities including, but not limited to, acupuncture, electro-acupuncture, massage, moxibustion, cupping, magnet therapy, and breathing exercises.  His immediate supervisor is the Staff Chiropractor, a VP-604-14 position.  We describe the appellant’s work in greater detail later in the decision.

The appellant and second-level supervisor certified to the accuracy of the duties described in the position description (PD) of record, number [number].  This PD and other material of record furnish much more information about the appellant’s duties and responsibilities and how they are performed and we incorporate it by reference into this decision.  To help decide this appeal, we conducted a telephone audit and follow-up interviews with the appellant on March 26, April 14, and May 6, 2014, and a telephone interview with the immediate supervisor on May 19, 2014.  In deciding this appeal, we carefully considered all of the information gained from these interviews, as well as written information furnished by the appellant and his agency, including the PD of record.

Series, title, and standard determination

The appellant disagrees with his agency’s assignment of his position to the GS-640 Health Aid and Technician Series, which is designated as a catchall for nonprofessional positions in health and medical work for which no other adequate series coverage exists.  This series includes positions involving nonprofessional work of a technical, specialized, or support nature in the field of health or medicine when the work is of such generalized, specialized, or miscellaneous nature that there is no other more appropriate series.  Such work is either (1) characteristic of two or more specialized nonprofessional series in the Medical, Hospital, Dental, and Public Health Group, GS-600, where no one type of work controls the qualification requirements; or (2) sufficiently new, unique, or miscellaneous that it is not specifically included in a specialized nonprofessional series in the Group.

The appellant believes his work warrants classification to the GS-601 General Health Science Series, which covers positions involving research or other professional and scientific work specifically health-oriented in character where the work is of such generalized or miscellaneous specialized nature that the positions are not more appropriately classifiable in any of the existing series in this or any other Group.  GS-601 work requires a background of knowledge, skills, and techniques gained from professional training in a health science or allied scientific field but has no paramount, rigid, or continuing requirement for the knowledge, skills, and techniques characterizing any of the established series that reflect one or more academic disciplines or recognized professions.

Because the appellant asserts his position is classifiable to the GS-601 two-grade interval professional series rather than the GS-640 one-grade interval technical series, we considered whether his position requires professional knowledge such as that of a physician, nurse, engineer, or biologist.  The Introduction contains guidance to distinguish between professional and technical work, describing professional work as italicized below:

Professional work requires knowledge in a field of science or learning characteristically acquired through education or training equivalent to a bachelor’s or higher degree with major study in or pertinent to the specialized field, as distinguished from general education.  This “positive education requirement” is common to nearly all professional occupational series.  In its appeal decision, the agency states:

For context, state requirements to perform such duties were explored.  Most states require a license to practice acupuncture; however, education and training standards and requirements for obtaining a license to practice vary from state to state although specific licensure, certification, and/or minimal training requirements for performing acupuncture-in-total have not been internally established and required by agency specific policy.

The bachelor’s degree is often the first degree received on the traditional academic career path, as a prerequisite for a one- or two- year master's degree program.  In contrast, what is called the Master of Science in Acupuncture (MSA) is the entry-level or first degree awarded within the acupuncture field.  The Accreditation Commission of Acupuncture and Oriental Medicine (ACAOM), the national accrediting agency recognized by the U.S. Department of Education, accredits and establishes standards for master’s level programs in acupuncture, requiring such programs to be at least three academic years in length and follow at least two years of accredited postsecondary education.  The appellant states he has an MSA degree from the Acupressure-Acupuncture Institute (now the Acupuncture and Massage College (AMC)) and is certified to perform acupoint injection therapy.  Published OPM guidance maintains that the experience and training requirements of a position, rather than the incumbent’s personal qualifications, govern its classification.  Thus, the level of knowledge reflected by the appellant’s degree and certification is creditable only to the extent that the position demands them.

In evaluating the education and training requirements of the appellant’s position, we considered the prerequisites for licensure as an acupuncturist.  He must be licensed to practice acupuncture in his State.  The general licensure requirements include meeting age, application, and fee requirements; providing proof of English proficiency and liability insurance coverage; successfully passing an approved examination; and completing a training program.  For individuals like the appellant, having applied for licensure on or after August 1, 2001, the training program criteria require completing an ACAOM candidate or accredited “four-year master’s level program” as defined previously or foreign equivalent in oriental medicine.  In addition, the State’s Board of Acupuncture requires licensed acupuncturists complete 30 continuing education credit hours every two years.

Each State has its own rules regarding the licensing of alternative medicine practitioners.  To illustrate the range of requirements for the licensing of acupuncturists:  formal schooling requirements in Texas include 1,800 didactic hours (450 hours must be in herbal training) and 60 semester hours including basic science courses; in Wisconsin to include two years of formal schooling requirements; in Ohio to include graduation from an ACAOM accredited school with a minimum of 1,725 hours; and in California to include 3,000 hours of study in curriculum pertaining to the practice of acupuncture from an accredited school.  Similar to the varying licensure requirements of each State, admission requirements also fluctuate depending on the acupuncture training program.  An ACAOM accredited program may apply stringent admission conditions; for example, requiring applicants to have attained a bachelor’s degree prior to enrollment in the program.  Other programs, like the appellant’s (now the AMC), require applicants to have completed 60 semester credits at the baccalaureate level from an accredited institution.  In general, acupuncturists in the United States are required to complete a three- or four-year training program when the State requires licensure.  The licensure requirements, admission requirements for enrollment in a training program, and length of program curriculum fluctuate significantly by State and school.  We conclude the lack of standardization shows the acupuncture field is currently not considered a broadly recognized profession in the United States for purposes of classification; the recognition of acupuncture as a profession would be marked by the standardization of essential requirements governing the profession such as licensure and admission requirements and length of program curriculum.

We recognize the appellant’s position requires acupuncture-specific training or education to understand the theory and philosophy of the field, traditional diagnostic methods, meridian pathways, and points and pulses; how to apply this knowledge to patients by recognizing symptoms through touch, hearing, smell, and sight; and how to plan treatment based on traditional diagnosis.  In reviewing AMC and other training programs, we noted the specificity of the established objectives and course descriptions.  The training programs, geared to provide practical, extensive training on the application of acupuncture treatments in a controlled environment, are characteristic of technical schools providing employment-preparation skills to train a workforce like licensed practical nurses and radiology technicians.  Sixty semester credits of college course work typically satisfy the associate degree requirements of junior and community colleges.  Such training is typical of the occupational theory requirements for technical rather than baccalaureate programs and trades and crafts apprenticeship programs.

In addition, the Introduction provides the following guidance, italicized, to distinguish between professional and technical work:  Work is professional when it requires the exercise of discretion, judgment, and personal responsibility for the application of an organized body of knowledge that is constantly studied to make new discoveries and interpretations, and to improve data, materials, and methods.  The Classifier’s Handbook further explains this particular point:

Professional work involves creativity, analysis, evaluation, and interpretation.  It involves applying basic or natural law, principles, or theory; evaluating the research of others; and assessing the need for and validity of proposed changes and improvements in procedures and methods.  Professional responsibility involves the ability to reason from existing knowledge to unexplored areas; to adapt methods to circumstances that deviate from the standards; and to stay abreast of and evaluate technical subjects, analyses, and proposals in professional literature.

We examined the appellant’s assignments along those dimensions most closely aligning to those of a professional.  Though some of his diagnostic work bears similarities to that of a professional, this and other work do not demand professional insight.  As the Medical Center’s only licensed non-physician acupuncturist, the appellant works with a high degree of freedom when making technical decisions such as the selection of acupuncture points for treatment based on his tongue, pulse, and other diagnostic examination.  Acupuncture describes a family of procedures aiming to correct imbalances in the flow of “qi” by stimulation of anatomical locations (acupuncture points) on or under the skin by a variety of techniques.  The appellant is knowledgeable of and skilled at a variety of acupuncture modalities such as oriental massage, magnet therapy, cupping, and breathing techniques.  However, he estimates that 99 percent of all acupuncture procedures involve the traditional insertion of thin metal needles into acupuncture points.  If time permits, he may introduce shiatsu and other massage, breathing exercises, and other modalities into the patient’s treatment.  His treatment room accommodates two beds where he treats an average of 12 patients daily.  As described by the appellant, it typically takes him a couple of minutes for each patient to insert the 20 to 30 disposable needles that remain inserted for 15 to 30 minutes.  To accommodate the volume of daily patients, treatment sessions often overlap where he will insert the needles for a second patient while the first waits for the removal of the needles.  The objective of the appellant’s acupuncturist position is the treatment and management of pain.  Acupuncture is commonly used for the treatment of pain but may also help manage and prevent numerous conditions related but not limited to anxiety, premenstrual syndrome, infertility, chronic fatigue syndrome, and weight management.  The Medical Center, however, controls the conditions for which a patient may seek acupuncture treatment, and the appellant’s Service weeds out referrals of patients seeking treatment for any condition other than pain management.

We noted the restrictions placed on the appellant’s position preclude him from making the wide-ranging judgment calls required when various modalities are regularly incorporated and multiple conditions must be considered in the development of the treatment plan.  For these and other reasons, we conclude his position does not apply the discretion, judgment, and personal responsibility in the broad application of acupuncture knowledge as expected of professional work.  The appellant makes various decisions such as identifying the acupuncture points corresponding to the patient’s source of pain, but this and other work do not require applying originality and imagination, evaluating the research of others, or having to reason from existing knowledge to unexplored areas as described of professional work.  Also unlike professional work, his position as the only non-physician acupuncturist at the Medical Center does not entail performing duties such as improving data, materials, and methods, or assessing the need for validity of proposed changes and improvements in procedures and methods.

The appellant’s work compares favorably to the following italicized guidance in the Introduction relating to technical work:  Technical employees carry out tasks, methods, procedures, and/or computations that are laid out either in published or oral instructions and covered by established precedents or guidelines.  Depending upon the level of difficulty of the work, these procedures often require a high degree of technical skill, care, and precision.  Experienced technicians often work with considerable independence for significant periods of time.  Similarly, the appellant independently carries out tasks, methods, and procedures following the established guidance and precedents of his field.  He decides the points for treatment by observing and questioning the patient in order to make a diagnosis.  Like technical work, he develops highly individualized treatment plans based on the philosophy of oriental medicine and his experience rather than on scientific research.

Since the appellant performs nonprofessional technical work, we determined his position is properly classified to the GS-640 series.  Titles are not prescribed but Health Technician is the suggested title for positions at grades GS-4 and above.  The GS-640 series does not contain grade-level criteria.  The Introduction directs if there are no specific grade-level criteria for the work, an appropriate general classification guide or criteria in a standard or standards for related kinds of work should be applied.  The standard selected for cross-series comparison should cover work as similar as possible to the work being evaluated with respect to the following:  the kind of work processes, functions, or subject matter of work performed; the qualifications required to do the work; the level of difficulty and responsibility; and the combination of classification factors with the greatest influence on the grade level.  The agency explains in its appeal decision the grade-level criteria they used for cross-series comparison:

There are two standards that meet these criteria:  GS-620, Practical (Vocational) Nurse Series and GS-186, Social Services Aid and Assistant Series.  The GS-620 standard is used to evaluate the technical acupuncture duties.  The appellant’s counseling and training activities are comparable to those described in the Social Services Aid and Assistant Series, GS-186, which covers nonprofessional positions that provide counseling and guidance to individuals and their families in an assistance program.  Work in this series requires effective communication skills in dealing with the individuals serviced.  Such skills are similar to the requirements for the appellant’s position.  Because the GS-186 standard does not contain grading criteria, the user is directed to the GS-187 standard as a source for evaluating duties and responsibilities.  Therefore, we use the GS-187 and GS-620 standards for grading purposes.

The agency evaluated the appellant’s work against the GS-620 standard at the GS-7 grade level.  Our application of the GS-620 standard graded his applicable work lower than that produced by comparison with other appropriate grade-level criteria; thus, we will not discuss application of the GS-620 standard further.

We disagree with the agency’s reliance on the GS-187 Social Services Series standard, which describes positions requiring application of specialized program knowledge and service skills to provide assistance on social welfare programs, to evaluate the appellant’s work.  GS-187 positions perform duties such as establishing eligibility for financial assistance and identifying related needs and providing auxiliary services.  We conclude the GS-187 standard does not properly consider the appellant’s work processes, functions, or subject matter of work performed (classifiable to the GS-600 Group) or the qualifications required to do the work.

In considering the grading criteria in the GS-600 Group, we conclude the PCS for the GS-649 Medical Instrument Technician Series is adequate for extrapolating to and evaluating the appellant’s acupuncture work.  Positions in the GS-649 series perform, like the appellant, diagnostic examinations or medical treatment procedures as part of the diagnostic or treatment plan for patients.  The work involves operating or monitoring diagnostic and therapeutic medical instruments and equipment associated with cardiac catheterization, pulmonary examinations and evaluations, heart bypass surgery, etc.  Similar to the appellant’s position, GS-649 positions require knowledge of the capabilities and operating characteristics of one or more kinds of instruments and a practical knowledge of human anatomy and physiology.  Work in the GS-649 series also requires a practical understanding of medical data generated by patient/equipment connections.  So although instruments used by GS-649 positions are different from the appellant’s own work tools and equipment (e.g., acupuncture needles, therapeutic balls and accessories, and cupping sets), the GS-649 PCS as a whole gives full weight and consideration to the purpose of his work (to perform diagnostic examinations and medical treatment procedures) and the nature of his work (e.g., when providing acupuncture treatment, he must recognize a patient’s unanticipated reactions and deviations from the norm to make necessary adjustments).

Grade determination

The GS-649 PCS 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 PCS.  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.  Conversely, if a position factor is evaluated at above the highest factor level published in the classification standard, the factor is evaluated by reference to the Primary Standard, the FES’s “standard-for-standards” in Appendix 3 of the Introduction.

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 1-5, the highest level described in the PCS, work requires knowledge and skill as described at Level 1-4 (e.g., practical knowledge of instruments used in the specialization to make adaptations and adjustments and interpret test results based on previous experience and observation) in addition to 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.  At this level, work requires knowledge of anatomy and physiology including an indepth understanding of the major systems and internal organs to interpret requests and to recognize the need for additional tests or a different position; and of a variety of related acute disorders and diseases, their effects on the organs, and methods of treatment.  Work at Level 1-5 requires skill to apply such knowledge to perform relatively new diagnostic procedures involving very fine distinctions or many delicate and exacting steps, the instruments are complex, and the setting and measurements are fine.  The work also requires skill to change and adapt parts of the instrument to meet especially difficult situations.

The knowledge required by the appellant’s position meets Level 1-5.  He provides acupuncture as treatment for outpatients at the Medical Center’s pain clinic.  When a patient is referred for treatment, the appellant reviews the notes from the treating physician and X-ray, magnetic resonance imaging, and other medical information to isolate the pain source (for example, the patient’s low back pain relates to a bulging disk).  In addition to requiring the knowledge and skill described at Level 1-4, his position requires knowledge consistent with Level 1-5 of acupuncture equipment, devices, and procedures including specialized complicated examinations or treatments for which there are no established instructions and procedures.  As part of his assessment, the appellant views the tongue and feels the pulse of the patient.  He develops a treatment plan, which requires knowing which and how many acupuncture points to employ to treat areas triggering the pain.  Consistent with Level 1-5, the appellant’s position requires knowledge of a variety of related acute disorders and diseases, their effects on the organs, and methods of treatment.  Also at this level, his acupuncture work requires knowledge of anatomy, biology, the pathology of diseases, and common medical terminology to assess data and make a determination of the patient’s needs to develop treatment objectives and plans.

The PCS provides the following illustration at Level 1-5:

Performs diagnostic ultrasound examinations and echocardiographs.  Locates and records internal elements of the body (for example, organs, tissues, skeletal members), displays their position and function, and identifies any anomalies indicative of disease, injury, or other medically significant condition, from ultrasound imaging and simultaneous recordings of the Doppler.  Incorporates the causes and results of a variety of symptoms and conditions into a plan of ultrasonic diagnostic examination.  Changes and develops sounding techniques to accommodate such variables as limited patient mobility, variation in physical condition or dimension of patient, presence of prosthesis or foreign objects and ultrasonic response of different body parts…

Though not identical to the appellant’s position, the level of skill and exacting adjustments described by the Level 1-5 illustration parallels acupuncture work.  His work requires skill to perform diagnostic or treatment procedures involving very fine distinctions or many delicate and exacting steps when, for example, inserting thin metal needles at precise depths into specific acupuncture points on a patient’s body.  The appellant’s position fully meets but does not exceed Level 1-5.

Level 1-5 is credited for 750 points.

Factor 2, Supervisory Controls

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

At Level 2-3, the highest level described in the PCS, the supervisor defines goals, priorities, and deadlines of the work.  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 supervisor helps the employee with unusual situations which have no clear precedents.  The technician plans and carries out procedures and handles problems and deviations in the work assignment in line with previous training and accepted practices.  The technician uses judgment and initiative that includes selecting appropriate instruments and methods, recognizing conditions that cause erroneous results, and troubleshooting complex instruments.  At this level, the technician rarely consults the supervisor for technical advice and independently makes recommendations about procedures or changes to procedures in some situations.  The supervisor checks completed work for results achieved and for conformance to hospital policy and overall adequacy of results produced.

At Level 2-4 in the Primary Standard, the supervisor sets the overall objectives and resources available.  The employee and supervisor, in consultation, develop deadlines, projects, and work to be done.  The employee, having developed expertise in the line of work, is responsible for planning and carrying out the assignment, resolving most of the conflicts that arise, coordinating the work with others as necessary, and interpreting policy on own initiative in terms of established objectives.  In some assignments, the employee also determines the approach to be taken and the methodology to be used.  The employee keeps the supervisor informed of progress and potentially controversial matters.  Completed work is reviewed only from an overall standpoint in terms of feasibility, compatibility with other work, or effectiveness in meeting requirements or expected results.

The supervisory controls of the appellant’s position meet and somewhat exceed Level 2-3.  As at this level, he works with substantial independence to plan, lay out, and perform his day-to-day work.  He carries out acupuncture procedures, handling problems and deviations in the work assignment in accordance with his training and accepted practices.  The appellant’s position exceeds Level 2-3 to some extent since his supervisor does not provide advice to the appellant on unusual situations having no clear precedents as described at this level.  The supervisor evaluates his work on the basis of his successfully accomplishing work schedules, completing monthly reports to ensure results achieved, and through occasional direct observation.  However, the appellant’s acupuncture methods are normally presumed to be correct.

There is some similarity between the supervisory controls of the appellant’s position and those described at Level 2-4 in the Primary Standard.  He follows established protocols of practice to independently schedule, plan, and carry out treatment activities including selecting specific therapeutic techniques as expected at this level.  He assesses and records normal and abnormal findings, pain location, pain score, and other information affecting the treatment of a patient.  Regardless, other Level 2-4 elements are not met.  The appellant’s assignments and deadlines are well established and clear cut; for example, the treating physician determines whether acupuncture is a viable alternative for a patient’s pain management regimen.  If so, the patient is sent for consultation to the appellant, who schedules the individual for consultation and treatment prior to follow-up with the physician.  His position does not receive work assignments and deadlines as a result of the collaborative, back and forth negotiation expected at Level 2-4.  The supervisor does not review the technical methods employed by the appellant.  However, his work is reviewed for accomplishment of objectives (whether the treatment met the stated purpose) and adherence to parameters (was the treatment scheduled timely).  This type of review is characteristic of Level 2-3, where completed work is reviewed for accomplishment of work objectives and conformity with policy.

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.

At Level 3-3, the highest level described in the PCS, guidelines are available but not completely applicable to the work.  The technician must frequently make searches in textbooks, journals, and technical manuals for application to individual cases.  Decision criteria do not cover every situation (for example, confirming unusual test results; using an altered technique; assessing and correcting unexpected reactions or errors; or the complexity of patients’ illness and physical condition).  Technicians at this level use judgment to adapt and change procedures, and adopt or develop new procedures or techniques for individual problems.  The technician uses initiative to learn new developments in the field and to recommend 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.

The appellant’s guidelines meet but do not exceed Level 3-3.  Guidelines are available including VA, Medical Center, and other agency-related memoranda, directives, and correspondence relating to patient care.  The appellant follows guidelines relating to infection control practices, in addition to the operation and maintenance of specialized equipment.  Standard references are available on matters such as anatomy, biology, and common medical terminology.  He exercises judgment in selecting appropriate manuals, policies, and references.  His available guidelines, however, lack specificity and are not readily applicable to his work.  Similar to Level 3-3, the appellant must search textbooks, trade publications, journals, and other technical manuals for guidance on established and developing techniques, processes, and equipment in the field of acupuncture.  He uses judgment to adapt and change treatment procedures and modalities to compensate for the patient’s illness, injuries, or physical disabilities, frequently assessing and modifying treatment based on unexpected reactions.  The appellant’s work requires using personal judgment, experience, and initiative to learn new developments in the field, recommend and implement changes to improve service, and improve the reliability of treatment results as described at Level 3-3.

Level 3-3 is credited for 275 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 4-3, the 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.  The 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; for example, when procedures do not give acceptable results the technician selects a different procedure.  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.

At Level 4-4, the work typically involves full responsibility for the technical aspects of the specialization and includes a wide variety of duties involving diverse and complex technical problems (for example, testing, refining, and implementing new procedures and developing procedural instructions to ensure proper performance of procedures).  Decisions involve complicating factors which hinder use of standard procedures and normal alternatives.  Such factors include changing technology, inadequate information about the use and capabilities of new instruments, seriousness of the illness and mental and physical capacity of the patient, requests for changed procedures, test alternatives, or special studies to meet specific clinical situations and research requirements.  The work performed by the technician requires variations of technical factors to accommodate the patient’s condition; extending standard test methods; changing conventional methods to produce acceptable results; developing new or revised procedures using standard techniques; or refining existing procedures.

The complexity of the appellant’s position meets Level 4-3 where work includes a variety of duties involving the performance of different specialized diagnostic and treatment procedures, methods, and techniques.  Like this level, his work involves performing the day-to-day technical and administrative operations of the acupuncture section of the pain clinic, and independently performing a wide number and variety of acupuncture consultations and examinations, treatment procedures, and other processes and methods (e.g., scheduling, ensuring supplies on a continuing basis, patient advising and preparation, and positioning of the patient and equipment).  He reviews referrals for his acupuncture services, choosing a course of action based on scheduling, priorities, current volume of patient load and demand, and other considerations.  The diagnostic skills required to conduct a complete acupuncture examination meets Level 4-3, requiring subtlety, sensitivity, and interpretation of a broad range of information and medical conditions.  The appellant develops a treatment plan for each patient, choosing the proper tools, materials, and acupuncture techniques to most effectively address individual concerns.  He implements the plan (identifying the size, placement, and depth of needles) through a series of twice a week visits, on average.  Similar to Level 4-3, his decisions on what needs to be done are affected by many variables including the condition of the patient, the desired results, and the variety of body systems examined.  The appellant’s work also requires precise timing and coordination, making quick and accurate adjustments to needles and other instruments in response to a patient’s condition and reactions, as expected at Level 4-3.

Although he has full responsibility for the technical operations of the acupuncture section as described at Level 4-4, the appellant’s position does not entail the diversity and complexity of technical problems equivalent to testing, refining, and implementing new procedures and developing procedural instructions to ensure the proper performance of procedures also described at this level.  Unlike Level 4-4, his decisions do not involve complicating factors that hinder use of standard procedures and normal alternatives, such as changing technology, inadequate information about the use and capabilities of new instruments, seriousness of the illness and mental and physical capacity of the patient, requests for changed procedures, test alternatives, or special studies to meet specific clinical situations and research requirements.  Upon careful assessment of the patient’s medical history and consultation, the appellant develops a treatment plan taking into account factors such as:  the specific complaint (pain in the back, neck, shoulder, or combination), mental health (dealing with posttraumatic stress disorder or other psychological issues), background (was sexually assaulted or other such event), and mobility (confined to a wheelchair or other disability).  Characteristic of Level 4-3 where decisions are dependent on patient condition, medication, or instrument performance, he makes necessary adjustments based on the patient’s mental health, mobility, and other factors; for example, he will prop, instead of lay, a wheelchair-bound patient on the table.

Level 4-3 is credited for 150 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.

At Level 5-3, the highest level described in the PCS, 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.  The work has a significant impact on the well being of the patient.

The appellant’s position meets Level 5-3.  Similar to this level, he has primary responsibility for planning and performing the full range of conventional acupuncture treatment to patients experiencing a wide variety of disabilities, illnesses, and conditions.  The appellant provides therapeutic and diagnostic procedures grounded in traditional and modern Chinese medical concepts and techniques.  He operates, monitors, and administers procedures, instruments, or equipment associated with the specific acupuncture procedure.  The acupuncture procedures he administers constitute a significant part of a patient’s pain management regimen, especially for those individuals unable to tolerate medication or the other customary pain management options.  By ensuring the quality and timely care of patients, the appellant’s work directly affects the physical, emotional, and psycho-social well being of the patients under his care as expected at Level 5-3.

The appellant administers acupuncture treatment to patients with multiple or severe conditions, but his work does not involve providing diagnostic and treatment services in critical care situations as described at Level 5-3.  His treatments, regarded as an alternative method for pain management, would be precluded in the critical care setting described at this level.  To provide a more reliable and fair means of evaluation, we compared the scope and effect of his position with Level 5-3 of the Primary Standard to ensure the overall intent of the factor level is met.  Level 5-3 in the Primary Standard describes work, comparable to the appellant’s position, involving treating a variety of conventional problems, questions, or situations in conformance with established criteria.  His work also compares favorably to the Level 5-3 description in the Primary Standard of work products or services affecting the social, physical, and economic well being of people.  By coordinated application of the PCS and Primary Standard, we conclude the scope and effect of the appellant’s position meet but do not exceed the intent of Level 5-3.

Level 5-3 is credited for 150 points.

Factors 6 and 7, Personal Contacts and Purpose of Contacts

Personal contacts include face-to-face and telephone contacts with people not in the supervisory chain.  Levels are based on what is required to make the initial contact, the difficulty in communicating with those contacted, and the setting in which the contact takes place.  The factors are interdependent, so the same contacts selected for crediting Factor 6 must be used to evaluate Factor 7.

Personal Contacts

At Level 2, the highest level identified in the PCS, contacts are with employees within the hospital, but outside the immediate work unit, patients, their families, physicians, nurses, or other professional and technical personnel.

The personal contacts of the appellant’s position are an exact match for, meeting but not exceeding, Level 2.  His contacts are primarily with the veteran patients and their families as well as with physicians, nurses, and other professional and technical staff assigned to his Service and Medical Center.

Purpose of Contacts

At Level b, the highest level identified in the PCS, the purpose of contacts is to coordinate work efforts and resolve technical problems.

The purpose of the appellant’s contacts meets but does not exceed Level b.  Like this level, his patient contacts are for the purpose of scheduling a series of coordinated treatments, obtaining information about and from them regarding their concerns, motivating them to engage in and continue practices he suggests for their care, and explaining information concerning acupuncture equipment and procedures to be performed.  The appellant frequently coordinates with healthcare providers and other Medical Center staff to clarify the treatments to be provided to patients.

Level 2b is credited for 75 points.

Factor 8, Physical Demands

This factor covers the requirements and physical demands placed on the employee by the work assigned.  This includes physical characteristics and abilities, as well as the extent of physical exertion involved in the work.

The physical demands of the appellant’s position meet but do not exceed Level 8-2, the highest level described by the PCS.  Similar to this level, his work requires regular and recurring physical exertion involving walking; standing; frequent bending; lifting and positioning patients; and carrying, pushing, or pulling heat lamps and other moderately heavy objects.  His acupuncture duties also require above average dexterity and precision.

Level 8-2 is credited for 20 points.

Factor 9, Work Environment

This factor considers the risks and discomforts in the employee’s physical surroundings.  Any safety regulations related to the work assigned are also considered.

The appellant’s work environment meets but does not exceed Level 9-2, the highest level described by the PCS.  As at this level, he performs work in a hospital setting involving regular and recurring exposure to infectious and contagious diseases, sharp needles, body fluids and other biohazard materials, odors, and other risks which require special health and safety precautions such as using protective techniques, clothing, or gear.

Level 9-2 is credited for 20 points.

Factor Level Points
1.  Knowledge Required by the Position 1-5 750
2.  Supervisory Controls 2-3 275
3.  Guidelines 3-3 275
4.  Complexity 4-3 150
5.  Scope and Effect 5-3 150
6. & 7.  Personal Contacts and Purpose of Contacts 2-b 75
8.  Physical Demands 8-2 20
9.  Work Environment 9-2 20
Total 1,715


A total of 1,715 points falls within the GS-8 range (1,605 to 1,850) on the grade conversion table provided in the PCS.


The appellant’s position is properly classified as GS-640-8.  Position title is at the agency’s discretion.


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