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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

Myrna Marsch-Fuller
Supervisory Health System Specialist
GS-671-12
Reserve and Service Member
Support Office
Defense Health Agency
U.S. Department of Defense
Great Lakes, Illinois
Supervisory Health System Specialist
GS-671-12
C-0671-12-03

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

08/14/2014


Date

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

Introduction

On August 29, 2012, OPM’s Agency Compliance and Evaluation (ACE)-Chicago office accepted a classification appeal from Ms. Myrna Marsh-Fuller.  The appeal was transferred to ACE-Atlanta on December 11, 2013.  The appellant’s position is currently classified as a Supervisory Health System Specialist, GS-671-12. The appellant believes it should be classified at the GS-13 grade level.  The position is assigned to the Reserve and Service Member Support Office (R&SMSO), Defense Health Agency, U.S. Department of Defense, in Great Lakes, Illinois.  We received the agency’s administrative report on February 15, 2013, the appellant’s comments on the report on March 19, 2013, and additional clarifying information provided by the agency at our request. We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

To help decide this appeal, we conducted a telephone audit with the appellant on January 22, 2014, and a follow-up discussion on February 21, 2014.  We also conducted a telephone interview with the appellant’s supervisor on January 28, 2014.  In reaching our decision, we carefully considered all of the information gained from these interviews, as well as the written information furnished by the appellant and her agency.

General Issues

The appellant stated her previous position description (PD), #40139-909504, did not accurately reflect higher level duties and responsibilities acquired through “accretion” since April 2010.  The appellant was subsequently reassigned on November 4, 2012, to PD#0861 with no change in the title, series or grade from the previous position.  The appellant maintains this PD also does not accurately reflect her duties and responsibilities. Specifically, she disagrees that she spends 75 percent of her time performing supervisory duties given that her direct reporting subordinates perform their work independently, and each of her subordinate supervisors  manage their team’s work.  The appellant states that she spends 50 percent of her time “as a section chief” and as part of the R&SMSO “leadership team” which focuses on “management and control.”

However, as discussed later in this decision, supervision in the GS system extends beyond day-to-day “people management.” Under “Statement of Coverage” in the General Schedule Supervisory Guide (GSSG), which is used to grade supervisory positions, such work includes “supervisory and related managerial responsibilities.”  Duties that the appellant describes as being administrative in nature are duties directly covered by the GSSG and are an integral part of supervisory work; e.g., developing and reviewing performance objectives and appraisals prepared by first line supervisors, writing position descriptions, and collaborating with staffing personnel on recruiting actions.

We accepted the appeal based on evidence of the appellant’s reasonable attempt to obtain an accurate PD.  However, in adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of the appellant’s position.  Because our decision sets aside all previous agency decisions, any concerns regarding the agency’s evaluation of her position are not germane to this decision.

A PD is the official record of the major duties and responsibilities assigned to a position or job by an official with the authority to assign work.  OPM considers a PD to be accurate for classification purposes when the major duties and responsibilities of the position are listed and proper classification can be made when the description is supplemented by otherwise accurate, available, and current information on the organization’s structure, mission, and procedures.  Classification appeal regulations permit OPM to investigate or audit a position and decide an appeal on the basis of the actual duties and responsibilities currently assigned by management and performed by the employee (5 CFR 511.607(a)(1) and 609).  An OPM appeal decision classifies a real operating position and not simply the PD.  This decision is based on the work currently assigned to and performed by the appellant.

By law, we must classify positions solely by comparing their current duties and responsibilities to OPM standards and guidelines (5 U.S.C. 5106, 5107, and 5112). In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of the appellant’s position. We cannot compare the appellant’s position to others, which may or may not be classified properly, as a basis for deciding her appeal. Since our decision sets aside any previously issued agency decision, any actions previously taken by the agency in their review of the appellant’s position are not germane to the classification appeal process.

Position information

The R&SMSO directly supports the provision of medical care to remotely located Active Duty and Reserve Component service members within the 50 United States and District of Columbia through TRICARE Prime Remote (TPR) and the Supplemental Health Care Program (SHCP). On October 1, 2013, the Department of Defense established the Defense Health Agency (DHA) to manage the activities of the Military Health System. These activities include those previously managed by the TRICARE Management Activity (TMA), which was disestablished on the same date.  In addition, the Military Member Support Office (MMSO) was reestablished as the Reserve and Service Member Support Office (R&SMSO).  We note the information provided by the agency in its administrative report as well as information provided by the appellant make reference to the TMA and MMSO.

The appellant supervises the Health Care Support Service Section (HCSSS) of the R&SMSO which is responsible for providing medical management support, technical research and analysis of medical issues, and debt collection assistance.  This work is accomplished utilizing three subordinate supervisors and support staff.  The appellant’s first-level supervisor’s position is classified as a Supervisory Health System Specialist, GS-671-13. This position manages the R&SMSO and reports to the Director of the Warrior Support Branch, whose position is classified as a Supervisory Program Analyst, GS-343-15.

The appellant describes her “management and control” work as serving as the subject matter expert as relates to legislation, laws and regulations; directing and managing her subordinate teams (Medical Customer Support, Line of Duty, Service Point of Contact, Transitional Care Support) and the Field Educator;  ensuring HCSSS provides guidance for the arrangement, provision and payment of medical care for active duty and reserve component service members under the Supplemental Health Care and Tricare Prime Remote programs; coordinating policy and procedural guidance to resolve problems; expediting administrative actions; implementing new initiatives; improving management processes; and facilitating accomplishment of program objectives. The appellant states this work includes coordinating with other R&SMSO and other staff for the purpose of monitoring, evaluating, and analyzing the impact of system changes and initiatives of new technologies and processes which include call center operations, database development and operations, and automated interfaces with managed care support contractors for review of claims.

Also included in this work is overseeing the performance of all functions associated with provision of mission related services; ensuring implementation of guidance provided on service members' eligibility, health benefits specifications, compensation, debt collection actions and sources of healthcare services within the Military Health Systems (MHS) for Army, Air Force, Navy and Marine Corps; ensuring staff properly implements policy and procedural guidelines through review and evaluation or feedback from clients (internal and external); and overseeing service members' medical readiness through application of procedures that interface with and coordinate civilian medical care. The appellant states the Section's responsibilities include, but are not limited to: identification of service members who potentially do not meet medical fitness or retention standards; coordination of the referral of remote service members' medical care to Military Treatment Facilities (MTFs) for medical evaluations; review for approval or denial of non-covered or unauthorized medical care; customer service support; and debt collection assistance support.

The appellant states she spends 25 percent of her time performing duties she describes as “administrative in nature” which consist of conducting research and responding to congressional inquiries; developing and reviewing performance objectives and appraisals prepared by first line supervisors; writing position descriptions and collaborating with staffing personnel on recruiting actions; developing internal procedures for subordinate supervisors to follow and ensuring effective control and direction of work activities; reviewing and authorizing requests for travel; and ensuring Health Insurance Portability and Accountability Act (HIPAA) requirements are met as well as compliance with safety practices and security regulations.

A summary of the appellant’s major duties and responsibilities, as described in her official PD, follows:

Under the section titled “Supervisory Duties” covering 75 percent of her time, the PD states the appellant performs the full range of personnel management duties for team supervisors and support staff.  These duties include determining staffing requirements, preparing requests for personnel actions, interviewing applicants, and recommending selections. She sets and establishes performance standards for subordinate supervisors, performs evaluations at appropriate periods, counsels employees on work-related matters, and takes appropriate disciplinary actions.  The appellant advises the Director of workload variances and impact, and anticipates personnel vacancies and circumstances requiring additional staffing.  She reviews performance for accuracy and quantity of work processed, as well as information provided to internal/external Tri–Service customers.  The appellant develops and establishes internal procedures for subordinate supervisors; reviews, analyzes and interprets information provided by team supervisors for thoroughness, completeness and approach; oversees the preparation of projects; and ensures cases are sound and based on logical recommendations.  She plans work schedules by establishing work priorities and deadlines, divides work into manageable components, establishes time frames to monitor the progress and completion of work, and ensures the Section's mission/goals are met.  The appellant ensures all employees adhere to safety practices and security regulations, instructs employees on safety issues, and reports all potential safety hazards to the designated safety officer.  The appellant ensures property is inventoried and accounted for.  She oversees and promotes employee compliance with privacy and security protections of HIPAA and the Privacy Act, and ensures employees protect the confidentiality of Personally Identifiable Information (PII) and Protected Health Information (PHI) as required by law and regulation.

Under the section titled “Technical Duties” occupying 25 percent of her time, the PD states the appellant directs and coordinates the planning, scheduling and conduct of reviews, projects, and analyses of health care under the Supplemental Health Care Program (SHCP) including situations involving TRICARE Prime Remote (TPR) and reserve line of duty (LOD) care; renders advice to management based on information obtained from TRICARE and health care benefit reports and written guidance; and develops general procedures for operations under SHCP and TPR.  The appellant reviews, maintains and updates pertinent Section standard operating procedures (SOPs) and policies.  She reviews collected data and summarizes facts to develop conclusions and to make fact-based recommendations, and prepares detailed data and analytical reports of historical patterns and trends regarding SHCP operations, health care workload, and Tri-Service population.  She ensures that services are rendered in a timely, cost-effective manner at the most appropriate level of care supporting medical readiness procedures and conducts research to determine requirements and standards.  The appellant assigns, directs and/or conducts detailed reviews of internal functions, workflow, systems and policies related to health care and SHCP.  She employs fact-finding analysis techniques and interpretation of higher authority guidance to identify trends, reach conclusions, and make appropriate recommendations.  She guides and advises Section personnel and other supervisory personnel in the organization on the completion of required projects, and reviews cases, reports and supporting documentation for accuracy, reliability and consistency. The appellant serves as a point of contact for Department of Defense (DoD) Tri-Service-related issues and concerns regarding SHCP.  She reviews complaints, appeals, and Congressional inquiries submitted to the Section.  She monitors situations or transactions that could indicate fraud, abuse, or improper claims payment, and prepares detailed documentation reports and justifications to support findings and recommendations.

Integral to supervisory work in the GS is planning and overseeing the work performed by subordinates, improving ways to perform the organization’s work, and rendering advice to higher level managers.  Thus, we find the appellant’s “technical duties” are part of her supervisory duties for purposes of classification analysis.  While the appellant’s description of her work expands upon what is described in her PD of record, we find the PD of record adequate for purposes of classification and we incorporate it by reference into this decision.

Series, title, and standard determination

The agency has placed the appellant’s position in the Health System Specialist Series, GS-671, titled the position Supervisory Health System Specialist, and evaluated it by application of the grading criteria in the GSSG.  The appellant does not disagree and, after careful review of the record, we concur.

Grade determination

Supervisory positions may be graded using the General Schedule Supervisory Guide (GSSG) or the appropriate standard for nonsupervisory duties when the position includes major nonsupervisory duties. To determine the grade level for this position, the agency used the GSSG. We concur that the GSSG is appropriate for grade level determination based on our finding of no major nonsupervisory duties associated with this position.

The GSSG uses a point-factor evaluation approach with six evaluation factors designed specifically for supervisory positions. Under each factor there are several factor level definitions which are assigned specific point values. The points for all levels are fixed and no interpolation or extrapolation of them is permitted. Supervisory duties are evaluated by comparing them with each factor. Points are credited for the highest factor level which is met according to the instructions specific to each factor and level. If two or more levels of a factor are met, points are credited for the highest level met.  However, if one level of a factor is exceeded, but the next higher level is not met, only the lower level will be credited.  The point total of the six evaluation factors are converted to a grade level by use of the grade conversion chart provided in the GSSG. 

The appellant only disagrees with the agency’s evaluation of Factors 4A and 4B, 5, and 6.  We reviewed the agency’s determination for Factors 1, 2, and 3.  Based on careful analysis of the entire record, we concur with the crediting of Levels 2-1 and 3-3.  Therefore, we will address the remaining Factors 1, 4, 5, and 6.

Factor 1, Program scope and effect

This factor assesses the general complexity, breadth, and impact of the program areas and work directed, including its organizational and geographic coverage.  It also assesses the impact of the work both within and outside the immediate organization.  To assign a factor level, the criteria dealing with both scope and effect, as defined below, must be met.

The levels of this factor describe two situations: agency line programs (e.g., providing services to the public); and support programs (e.g., providing administrative or other complex support services within an agency).  The appellant’s position falls under the first situation since her organization provides line TRICARE services to a defined segment of the TRICARE serviced population.

Scope

Scope addresses the general complexity and breadth of the program or work directed including the geographic and organizational coverage within the agency structure. The concept of Scope involves more than just geographic coverage. When one considers both the general factor-level criteria and the illustrations, a general pattern of analysis emerges. OPM guidance indicates there is a dynamic at work which deals with the interaction of four aspects implicit in the concept of Scope:

·           sweep: the geographic coverage of the program (for instance, city, region, or state);

·           magnitude: the total population serviced directly and significantly by the program (for instance,     

            small and confined to an installation, moderate, or large);

·           importance: the importance of the program to the agency and its mission (whether line or staff,   

            whether involving service to higher agency levels, other agencies, or the general public); and

·           complexity: the complexity of the products or services provided (for instance, routine or  complicated).

In deciding whether a position meets a factor level, one must consider each of these implicit aspects and how they interact.  No one aspect is necessarily predominant.  We consider these aspects for the appellant’s position below:

At Level 1-2, the program segment or work directed is administrative, technical, complex clerical, or comparable in nature.  The functions, activities, or services provided have limited geographic coverage and support most of the activities comprising a typical agency field office, an area office, a small to medium military installation, or comparable activities within program segments.

At Level 1-3, the work involves directing a program segment that performs technical, administrative, protective, investigative, or professional work.  The program segment and work directed typically have coverage which encompasses a major metropolitan area, a State, or a small region of several States; or, when most of an area's taxpayers or businesses are involved, coverage comparable to a small city.  Providing complex administrative, technical, or professional services directly affecting a large or complex multimission military installation also falls at this level.

The appellant agrees with her agency’s most recent evaluation which credits her position at Level 1-3.  When considering sweep, at Level 1-3 work directed typically has coverage which encompasses a major metropolitan area, a State, or a small region of several States.  The appellant’s Section services remotely located active duty military members throughout the United States.  Eligibility for service is defined as active duty and activated guard and reserve personnel under full-time orders with a permanent duty assignment who live and work more than 50 miles (or approximately a one-hour drive) from a military hospital or clinic in Tricare Prime Remote-designated ZIP codes. The appellant’s Section does not provide services to family members.  Based on the geographic coverage of the program, the position meets Level 1-3 in regard to sweep.

With respect to magnitude, the appellant’s position warrants Level 1-2.  The general factor-level criteria at Level 1-3 indicate that when most of an area’s taxpayers are covered, work directed typically has coverage comparable to a small city.  Illustrative of magnitude at Level 1-3 is a position providing services directly to a population equivalent to the number of citizens in a small city where the population may be concentrated in one place or located throughout a significant portion of a multistate area.  Because the population serviced by the appellant’s Section is dispersed throughout the 50 United States, the comparison to a “small city where the population may be concentrated in one place or located throughout a significant portion of a multistate area” must be made in the context of the geographic make-up of the United States military.  A report titled “Evaluation of the Tricare Program: Access, Cost and Quality Fiscal Year 2013 Report to Congress” reports the total end-year number of Active Duty, Guard and Reserve Tricare Prime Remote enrolled beneficiaries for FY12 was 100,000.  The report also states total number of beneficiaries eligible for Department of Defense (DoD) medical care was 9.66 million as of the end of FY12.  The discussions of Effect and the illustrations at different factor levels all indicate that in evaluating magnitude, one may consider only the total population serviced directly and significantly by a program.  The population serviced by the appellant’s Section makes up less than 1 percent of the total population serviced under DOD medical care (9.66 million).  While a population of 100,000 beneficiaries is comparable to the population of a small city, only those beneficiaries who are directly and substantially impacted by the services provided by the Section may be considered under this element.  The number of unique beneficiaries provided service is not tracked by the R&SMSO, therefore, although the potential population of 100,000 could be considered equivalent to a small city, this number does not represent the total population directly and substantially impacted on an ongoing basis because it only indicates the total number of enrolled beneficiaries, not the total number of beneficiaries serviced significantly and directly.

With respect to importance, the appellant’s position warrants Level 1-2. The closest example from the GSSG illustrations at Level 1-3 would be to “furnish a significant portion of an agency’s line program to the general public.”  In comparing this illustration to the appellant’s Section, providing specialized services (i.e., a portion of the program assigned to the Warrior Support Branch and to its parent organization, the R&SMSO) to a limited portion of the total population serviced by her entire agency does not equate to a significant portion of the agency’s line program. 

With respect to complexity, the appellant’s position warrants Level 1-3. As described below under Factor 5, the appellant’s base level of work is GS-9.  OPM interpretive guidance on applying the GSSG is that the GS-9 grade level is considered the first full performance level for administrative and professional work.  As envisioned in the first sentence under Scope at Level 1-3, the appellant’s subordinates perform moderately complex technical and administrative work.

In sum, the appellant’s position meets Level 1-3 with respect to sweep and complexity. With respect to magnitude and importance, the position falls short of Level 1-3 but meets Level 1-2. As noted earlier, none of these four aspects is necessarily predominant. However, considering all four aspects, how they interact, and the extent to which the appellant’s position falls short of Level 1-3 for magnitude and importance, the appellant’s position must be evaluated at Level 1-2 for Scope.

Effect

At Level 1-2, the services or products support and significantly affect installation level, area office level, or field office operations and objectives, or comparable program segments; or provide services to a moderate, local, or limited population of clients or users comparable to a major portion of a small city or rural county.

At Level 1-3, the activities, functions, or services accomplished directly and significantly impact a wide range of agency activities, the work of other agencies, or the operations of outside interests (e.g., a segment of a regulated industry), or the general public.  At the field activity level (involving large, complex, multimission organizations and/or very large serviced populations), the work directly involves or substantially impacts the provision of essential support operations to numerous, varied, and complex technical, professional, and administrative functions.  As discussed previously, illustrative of externally oriented line work is furnishing a significant portion of the agency's line program to a moderate-sized population of clients, a small city or a portion of a larger metropolitan area.

The appellant’s position meets Level 1-2 for Effect.  The appellant’s services do not fully meet Level 1-3 because, as discussed previously, the appellant’s Section provides services that directly and substantially impact a population substantially less than found at Level 1-3.  Because Level 1-3 is not fully met, Level 1-2 must be credited.

Since the appellant’s position warrants Level 1-2 for both Scope and Effect, Level 1-2 is credited for 350 points.

Factor 4, Personal Contacts

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

Subfactor  4A, Nature of Contacts

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

The appellant asserts in her appeal that she should be rated at Level 4A-4 based on her contacts with a wide variety of DoD, VA, high ranking military and civilian managers, and Federal Government officials tasked to support diverse elements of the MMSO's mission, as well as daily contacts with service members located nationwide and at times overseas.

At Level 4A-2, frequent contacts are with:  (1) members of the business community or the general public; (2) higher ranking managers, supervisors, and staff of program, administrative, and other work units and activities throughout the field activity, installation, command (below major command level) or major organization level of the agency; (3) representatives of local public interest groups; (4) case workers in congressional district offices; (5) technical or operating level employees of State and local governments; and/or (6) reporters for local and other limited media outlets reaching a small, general population, or comparable contacts. Contacts may be informal, occur in conferences and meetings, or take place through telephone, televised, radio, or similar contact, and sometimes require nonroutine or special preparation.

At Level 4A-3, frequent contacts are with (1) high ranking military or civilian managers, supervisors, and technical staff at bureau and major organization levels of the agency; (2) agency headquarters administrative support staff or comparable personnel in other Federal agencies; (3) key staff of public interest groups (usually in formal briefings) with significant political influence or media coverage;  (4) journalists representing influential city or county newspapers or comparable radio or television coverage;  (5) congressional committee and subcommittee staff assistants below staff director or chief counsel levels; (6) contracting officials and high level technical staff of large industrial firms; (7) local officers of regional or national trade associations, public action groups, or professional organizations, and/or State and local government managers doing business with the agency, or comparable contacts.  Contacts include those which take place in meetings and conferences and unplanned contacts for which the employee is designated as a contact point by higher management. They often require extensive preparation of briefing materials or up-to-date familiarity with complex subject matter.

The appellant’s position requires her to have extensive knowledge of medical management procedures in order to explain and interpret to military service members, contractors and responsible personnel located within civilian and Federal health care facilities.  Also, the appellant serves as the point of contact for Department of Defense Tri-Service related issues and concerns regarding the SHCP.  This responsibility requires contact with higher ranking managers, supervisors, and staff of program, administrative, and other work units and activities throughout the field activity, installation, command (below major command level) or major organization level of the agency as described under Level 4A-2.  The record shows the appellant does not have the types of contacts under the conditions required to support the crediting of Level 4-A3.

Level 4A-2 is credited for 50 points.

Subfactor 4B, Purpose of Contacts

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

At Level 4B-2, the purpose of contacts is to ensure that information provided to outside parties is accurate and consistent; to plan and coordinate the work directed with that of others outside the subordinate organization; and/or to resolve differences of opinion among managers, supervisors, employees, contractors or others.  This is descriptive of the purpose of the appellant’s regular and recurring contacts, including dealing with beneficiaries on claims matters.

At Level 4B-3, the purpose of contacts is to justify, defend, or negotiate in representing the project, program segment(s), or organizational unit(s) directed, in obtaining or committing resources, and in gaining compliance with established policies, regulations, or contracts. Contacts at this level usually involve active participation in conferences, meetings, hearings, or presentations involving problems or issues of considerable consequence or importance to the program or program segment(s) managed.

The appellant describes the purpose of her contacts as to influence/persuade customers to accept the results of claims and benefits determinations.  This does not meet Level 4B-3 which involves justifying, defending, or negotiating in representing the project, program segment(s), or organizational unit(s) directed, in obtaining or committing resources.  The appellant also states in her appeal: “We often encounter resistance as a result of denial of claims requests and must gain compliance with established policies and regulations.” Explaining claims and benefits determinations to serviced customers does not amount to gaining compliance with established policies, regulations, or contracts within the program context of Level 4B-3.  

Level 4B-2 is credited for 75 points.

Factor 5, Difficulty of Typical Work Directed

This factor measures the difficulty and complexity of the basic work most typical of the organization directed, as well as other line, staff, or contracted work for which the supervisor has technical or oversight responsibility, directly or through subordinate supervisors, team leaders, or others.  The level is determined by identifying the highest grade which best characterizes the nature of the basic (mission oriented) nonsupervisory/nonleader work performed or overseen by the organization directed, and which constitutes 25 percent or more of the workload of the organization.  It does not cover or consider the analytical work personally performed by the employee which the appellant discusses in her comments on the AAR.

The GSSG excludes from consideration the work of lower level positions that primarily support or facilitate the basic work of the unit; any subordinate work that is graded based on criteria in this guide (i.e., supervisory duties) or the General Schedule Leader Grade Evaluation Guide (GSLGEG); work that is graded on an extraordinary degree of independence from supervision, or personal research accomplishments; and work for which the supervisor or a subordinate does not exercise the level of supervisory responsibility needed to meet the threshold for credit under Factor 3.

The HCSSS is staffed with 24 permanent full-time civilian positions as shown below by both their official and organizational titles.  For purposes of this appeal decision we assume these positions are correctly classified.

1 - GS-0671-12, Supervisory Health System Specialist/Service Point of Contact Supervisor (SPCS)

1 - GS-0671-11, Supervisory Health System Specialist/Line of Duty/Office Automation Supervisor (LOD/OAS)

1 - GS-0671-11, Supervisory Health System Specialist/Medical Contact Support Supervisor (MCSS)

1 - GS-0671-11, Health System Specialist/Service Point of Contact Educator (SPCE)

1 - GS-0671-9, Health System Specialist/Debt Collection Officer (DCO)

1 - GS-0301-9, Claims Entitlement Specialist/Transitional Care Support Specialist (TCS)

3 - GS-0671-9, Health System Specialist/Service Point of Contact Specialist (SPOCS)

1 - GS-0671-9, Health System Specialist/Line of Duty Specialist (LODS)

1 - GS-0671-9, Health System Specialist/Medical Contact Support Specialist (MCSS)

1 - GS-0962-8, Contact Representative/ Transitional Care Support Representative (TCSR)

2 - GS-0962-8, Contact Representative/Line of Duty Representative (LODR)

7 - GS-0962-8, Contact Representative/Medical Contact Support Representative (MCSR)

1 – GS-0962-7, Contact Representative/Line of Duty Representative (LODR)

2 – GS-0326-5, Office Automation Assistant (OAS)

The PD for the SPCS, GS-0671-12, Supervisory Health System Specialist, does not indicate the amount of time spent on nonsupervisory versus supervisory duties.  However, the nonsupervisory work is grade controlling for the position.  To warrant classification as supervisory, a position must devote 25 percent or more of the work time to supervisory duties.  Therefore, we have included .75 work years in the base level determination.

The LOD/OAS and MCSS, GS-0671-11, Supervisory Health System Specialist work is graded based on the GSSG and although there is no percentage of time spent performing supervisory versus nonsupervisory work identified, the PD indicates all of the time for these positions is spent performing supervisory work and they are, therefore, excluded from the base level determination. 

The OAS position is excluded from the base level determination as a lower graded position that primarily supports or facilitates the basic work of the Section. 

The following listing shows positions performing the nonsupervisory/nonleader workload; i.e., the basic work of the Section.  Amounts shown are stated in work years.

            GS-12

                 .75              GS-0671-12, Supervisory Health System Specialist/(SPCS)

            GS-11

               1.0                GS-0671-11, Health System Specialist/(SPCE)

            GS-9

               1.0                GS-0671-9, Health System Specialist/(DCO)

               1.0                GS-0301-9, Claims Entitlement Specialist/(TCSS)

               3.0                GS-0671-9, Health System Specialist/(SPOCS)

               1.0                GS-0671-9, Health System Specialist/(LODS)

               1.0                GS-0671-9, Health System Specialist/(MCSS)

            GS-8

               1.0                GS-0962-8, Contact Representative/(TCSR)

               2.0                GS-0962-8, Contact Representative/(LODR)

               7.0                GS-0962-8, Contact Representative/(MCSR)

            GS-7

               1.0                GS-0962-7, Contact Representative/(LODR)

Total staff years (work years) are 21.

GS-12:               4.5%

GS-11:               4.5 %

GS-9:               31.8%

GS-8:               45.5%

GS-7:                 4.5%

GS-5:                 9.0%

Based on the foregoing, GS-9 is the highest grade level of work supervised which meets or exceeds 25 percent of the workload.

The GSSG recognizes that second (and higher) level supervisory positions sometimes include heavy supervisory or managerial workload related to work above the base level. In such situations, the GSSG permits using the “highest level of nonsupervisory work directed, requiring at least 50 percent of the duty time of the supervisory position under evaluation,” for this factor. The appellant is a second-level supervisor.  However, the record shows only 1.75 work years of nonsupervisory grade level work performed above the base level.  This does not represent a heavy supervisory workload requiring 50 percent or more of her time to supervise.

Level 5-5 is credited for 650 points.

Factor 6, Other Conditions

This factor measures the extent to which various conditions contribute to the difficulty and complexity of carrying out supervisory duties, authorities, and responsibilities. To evaluate Factor 6, two steps are used. First, the highest level that a position substantially meets is initially credited.  Then, if the level selected is 6-1, 6-2, or 6-3, the Special Situations listed after the factor level definitions are considered.  If a position meets three or more of the situations, then a single level is added to the level selected in Step 1.  If the level selected under Step 1 is 6-4, 6-5, or 6-6, the Special Situations may not be considered in determining whether a higher factor level is creditable.

The appellant believes her position functions at Level 6-4.  In her appeal, she contends her duties consist of a wide variety of projects and studies associated with the delivery of health care requiring analysis of interrelated issues of effectiveness, efficiency, and productivity of substantive mission-oriented programs and other activities.  She states her primary responsibility is directing, planning, scheduling, conducting and/or coordinating the management and TRICARE procedure assignments to solve or contribute to the solution of TRICARE Prime Remote programs, processing of health care benefits, and direct supervision of three supervisors (GS-12 and GS-11), a field educator (GS-11), and a claims entitlement specialist (GS-9). The team supervisors, in turn, supervise GS-9 and below employees. The agency credited the position with Level 6-3.

Factor 6 is linked directly to the previous factors in the GSSG.  The difficulty of work is measured primarily by the base level determined in Factor 5.  Complexity is measured by the degree of coordination required, and increases with the base level.  In this regard, the appellant’s position has been credited under Factors 3 and 5 as a second-level supervisor over a base level of GS-9 work.  At Level 6-4, at least one of the two following conditions must be met:

a. Supervision requires substantial coordination and integration of a number of major work assignments, projects, or program segments of professional, scientific, technical, or administrative work comparable in difficulty to the GS-11 level.

The appellant exercises full technical and administrative supervision over the work of .75 work years of nonsupervisory GS-12 work and one work year of GS-11 Health System Specialist work.  This equals 1.75 work years at the GS-11 and 12 grade levels out of the 21 work years of work in the section, or 8 percent of the nonsupervisory work, which may not be construed as being a sizeable GS-11 workload.  Therefore, Level 6-4a may not be credited to the position.

b. The position directs subordinate supervisors and/or contractors who each direct substantial workloads comparable to the GS-9 or 10 levels.

OPM guidance has made clear that use of the term “each” is deliberate and requires that multiple subordinate supervisors must individually direct a substantial GS-9 or GS-10 workload before Level 6-4b may be credited.  The appellant directs subordinate supervisors who supervise work which is predominately at the GS-8 level, with only one supervisor directing a substantial workload at the GS-9 grade level.  This does not meet the conditions of Level 6-4b.

At Level 6-3a, the supervisor coordinates, integrates, or consolidates administrative, technical, or complex technician or other support work comparable to GS-9 or 10, or work at the GS-7 or 8 levels where the supervisor has full and final technical authority.  The second situation (6-3b) covers positions which direct subordinate supervisors over positions in grades GS-7 or 8, requiring consolidation or coordination to ensure consistency of product, service, interpretation, or advice; or conformance with the output of other units, with formal standards, or agency policy.

Level 6-3a is met.  As documented in the workload analysis, the appellant directs a substantial workload comparable to GS-9.  She also directs the work of the organization through multiple subordinate supervisors meeting the conditions of 6-3b.

Special Situations:

Supervisory and oversight work may be complicated by special situations and/or conditions. For credit, the condition must be present and dealt with on a regular basis. The conditions described are: (1) Variety of Work, (2) Shift Operations, (3) Fluctuating Work Force or Constantly Changing Deadlines, (4) Physical Dispersion, (5) Special Staffing Situations, (6) Impact of Specialized Programs, (7) Changing Technology, and (8) Special Hazard and Safety Conditions. If the position meets three or more of the eight special situations, it is credited one level above that which would otherwise be assigned (e.g., at Level 6-4 in this case).

Variety of Work

Credit is given for this situation when more than one kind of work is present in the unit and the kinds of work require the supervisor to be substantially fully qualified in distinctly separate areas or have full knowledge and understanding of the rules, regulations, procedures and subject matter of distinctly different areas of work to properly carry out his/her supervisory duties and responsibilities.  To be considered, the supervisor must exercise both technical and administrative supervision over the work, and the supervision cannot be performed at more than one grade level below that used as the base level for Factor 5.  A “kind of work” is usually the equivalent of a classification standard.  The Section includes positions classified to two separate classification series (GS-671 and 962) at grade levels meeting the criteria for credit under this situation.  However, the work of these positions represents different aspects and/or phases of the same overall process requiring varying degrees of knowledge and ability to apply the same basic body of technical information.  Therefore, this situation is not met.

Shift Operations

Credit is given for this situation when the position supervises an operation carried out on at least two fully staffed shifts.  The appellant’s staff all work typical business hours.  This situation is not met.

Fluctuating Work Force or Constantly Changing Deadlines

This situation is credited when the work force has large fluctuations in size which impose a substantially greater responsibility on the supervisor to adjust assignments, train employees, and maintain a smooth flow of work while adjusting to staff changes.  It is also credited when a supervisor must frequently adjust work operations to accommodate abrupt and unexpected changes to work assignments, goals, and deadlines.  The appellant’s workforce is constant except for occasional vacancies, and major shifts in work operations are predictable.  This situation is not met.

Physical Dispersion

This situation is credited when a substantial amount of the workload for which the supervisor is responsible is carried out in more than one location and under conditions which make the day to day direction and administration of the work more difficult.  All of the employees supervised by the appellant are located in the same office building.  This situation is not met.

Special Staffing Situations

Credit is given when a substantial portion of the workforce is regularly involved in special employment programs; supervision requires unique counseling and/or motivational efforts; and job assignments and/or training must be tailored to meet special employee circumstances.  The record does not indicate the appellant deals with any of these conditions on a regular basis.  This situation is not met.

Impact of Specialized Programs

Credit is given for this situation when a supervisor is responsible for a significant technical or administrative workload, in grades above that credited for Factor 5, provided the supervisor exercises full technical and administrative supervision over the work.  As discussed previously, the appellant supervises 1.75 work years of work at the GS-11 and 12 grade levels, grades above the base level of work credited in Factor 5.  However, as discussed previously, this limited amount of higher graded work cannot be considered a significant workload.  This situation is not met.

Changing Technology

This situation is credited when the supervisor’s work is regularly made more difficult because of the need to train and provide guidance to employees regarding constantly varying processes and procedures caused by changing technology.  While such shifts occasionally occur, the record does not show the appellant’s supervisory burden is regularly impacted by modified procedures and processes resulting from frequent technological upgrades/changes. This situation is not met.

Special Hazard and Safety Conditions

Credit is given for this situation when the supervisor’s work is regularly made more difficult by the need to make provisions for unsafe and/or hazardous working conditions affecting the work of subordinates.  The appellant’s work does not meet the criteria for crediting this situation.

The position meets none of the eight special conditions.  Therefore, an additional level is not warranted, and Level 6-3 is credited for 975 points.

Summary

Factors Level Points
1. Program Scope and Effect 1-2    350
2. Organiational Setting 2-1    100
3. Supervisory and Managerial Authority 3-3    775
4. Personal Contacts 4A-2     50
4B-2     75
5. Difficulty of Typical Work Directed 5-5    690
6. Other Conditions 6-3    975
Total 2,975

 

A total of 2,975 points falls within the GS-12 range (2,755-3,150) on the grade conversion table in the GSSG. 

Decision

The position is properly classified as Supervisory Health System Specialist, GS-671-12.

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