Washington, DC
U.S. Office of Personnel Management
Classification Appeal Decision
Under section 5112 of title 5, United States Code
Patient Administration Department
Director for Administration
Naval Medical Center – Portsmouth
Defense Health Agency
U.S. Department of the Navy
Portsmouth, Virginia
Damon B. Ford
Classification Appeals and FLSA Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance
09/27/2023
Date
As provided in section 511.612 of title 5, Code of Federal Regulations (CFR), this decision constitutes a certificate that is mandatory and binding on all administrative, certifying, payroll, disbursing, and accounting officials of the Government. The agency is responsible for reviewing its classification decisions for identical, similar, or related positions to ensure consistency with this decision. There is no right of further appeal. This decision is subject to discretionary review only under conditions and time limits specified in the Introduction to the Position Classification Standards (Introduction), appendix 4, section G (address provided in appendix 4, section H).
This is a group classification appeal. The appeal was originally filed by ten appellants and later one was added totaling eleven. However, during our adjudication process seven left the position. The appellants’ position is currently classified as Medical Records Technician (Medical Coder), GS-0675-06, but they believe the position should be classified at the GS-08 level. All are assigned to Outpatient Coding (OC), Patient Administration Department (PAD), Director for Administration (DAF), Naval Medical Center (NMC), Portsmouth, Defense Health Agency (DHA), U.S. Department of the Navy, in Portsmouth, Virginia. We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).
Prior to appealing to the Office of Personnel Management (OPM) the appellants filed an appeal with the Defense Civilian Personnel Advisory Service (DCPAS), U.S. Department of Defense. At the time their position was classified as Medical Records Technician (Medical Coder), GS-0675-07, but they believed it should be upgraded to the GS-08 level. However, in an appeal decision dated March 24, 2022, DCPAS downgraded the position classifying it as Medical Records Technician, GS-0675-06, with parenthetical title at agency discretion. Subsequently, the appellants filed their classification appeal to OPM seeking an upgrade to the GS-08 level.
The appellants make various statements concerning the agency’s evaluation of their position. In adjudicating this appeal, our responsibility is to make an independent decision on the proper classification of the appellants’ position. By law, we must classify positions solely by comparing the current duties and responsibilities to OPM standards and guidelines (5 U.S.C. 5106, 5107, and 5112). Because our decision sets aside any previous agency decisions, the appellants’ statements regarding the classification practices used by the agency to classify their position are not germane to the classification appeal process.
During our interview the appellants compared their current position description (PD) to the duties performed in their previously higher graded PD, and to similar but higher graded positions at other agencies. However, the classification of an employee’s position based on position-to-position comparisons is neither appealable nor reviewable under OPM’s classification appeal process. In addition, when interviewed the appellants cited a high volume of work as partial support for the requested grade increase. However, volume of work cannot be considered when determining the grade level of a position (The Classifier’s Handbook, Chapter 5).
Both the appellants and their first-level supervisor certify to the accuracy of their official PD (# 4657A) and after careful review we concur.
The appellants serve as Medical Records Technicians (Medical Coders) within NMC Portsmouth’s OC. They use practical knowledge of medical records procedures and references to identify, verify, and translate into coded form specific patient care processes (e.g., primary and secondary condition diagnosis and treatment plans) and a variety of patient care-related services (e.g., medical and behavioral healthcare services, pharmacy, physical rehabilitation, transportation, and use of long-term care facilities) and patient care-related consumables (e.g., equipment use, prosthetic devices, and medical supplies) provided to the patient by various NMC healthcare disciplines in a variety of settings.
They review and compare patient medical records prior to coding to ensure accuracy and completeness of entries into patient medical records (e.g., medical history; results of physical examination; x-ray and laboratory reports; diagnosis and treatment plans; and treatment orders and notes from doctors, nurses, and other health care professionals); the accurate use of approved standard diagnostic and medical terminology; and continuity between language describing patient diagnosis and treatment. For example, if the patient record indicates treatment for cancer, but no diagnosis of cancer is found, the appellants would inform the appropriate NMC health care professional (e.g., Doctors, Nurses, Social Workers, and Counselors) and non-professional administrative personnel (e.g., Secretaries, Administrative assistants, and Ward Clerks) of a possible inconsistency in the medical record and await corrective action to the medical record prior to identifying and assigning diagnostic and/or treatment codes.
They review third party collection records for coding inaccuracies and notify the appropriate staff of any inconsistencies. They also develop and maintain various coding and billing databases (e.g., Correct Coding Edits (CCE), Armed Forces Health Longitudinal Technology Application (AHLTA), Composite Health Care System (CHCS), T-System, Essentris, and Healthcare Artifacts and Image Management Solution (HAIMS)); and update databases when appropriate. They also submit a variety of cyclical and non-cyclical reports and documents to their supervisor and other appropriate offices and individuals both inside and outside NMC., NMC billing and Medical Records Department, patients and authorized caregivers, and authorized private insurance company representatives.
They strictly adhere to all current agency and Federal coding guidelines, regulations, and coding practices from a variety of established guidelines, such as the International Classification of Diseases Clinical Modifications (ICD-CM); Current Procedural Terminology (CPT); Healthcare Common Procedure Coding System (HCPCS) requirements; Military Health System Specific Coding Guidelines (MHSSCG); current DoD and Defense Health Agency (DHA) coding practices; and Joint Commission on Accreditation of Healthcare Organizations (JCAHO), American Hospital Association (AHA) Coding Clinic, and Center for Medical and Medicaid Services (CMMS) coding guidelines.
In reaching our classification decision, we have carefully reviewed all information provided by the appellants and the agency, including the official PD which we have incorporated by reference into this decision. In addition, to help decide the appeal, we conducted separate telephone interviews with the appellants and their immediate supervisor, as well as subsequent telephone and e-mail communications.
Series, title, and standard determination
The agency classified the appellants’ position in the Medical Records Technician Series, GS-0675, titling it Medical Records Technician (Medical Coder), and grading the position by application of the Job Family Position Classification Standard (JFS) for Assistance and Technical Work in the Medical, Hospital, Dental, and Public Health Group, GS-0600 (GS-0600 JFS). The appellants do not disagree with the agency’s assignment of series and basic title, and we concur. Selection of an appropriate parenthetical title is at the agency’s discretion. The GS-0675 series covers one-grade interval technical support positions that supervise, lead, or perform support work in connection with processing and maintaining medical records for compliance with regulatory requirements. This series also covers positions that review, analyze, code, abstract, and compile or extract medical records data and requires employees to possess a practical knowledge of medical record procedures and references and the organization, consistency and basic knowledge of human anatomy, physiology; and medical terminology.
The GS-0600 JFS is written in the Factor Evaluation System (FES) format, under which factor levels and accompanying point values are assigned for each of the nine factors. The total is converted to a grade level by use of the grade conversion table provided in the JFS. Under the FES, each factor-level description provides the minimum criteria needed to receive credit for the described level. If a position fails to meet the minimum criteria in a factor-level description in any significant aspect, it must be credited at a lower level unless an equally important aspect that meets a higher level balances the deficiency. Conversely, the position may exceed those criteria in some aspects and still not be credited at a higher level.
The DCPAS evaluated Factor 1, Knowledge Required by the Position, at Level 1-4; Factor 2, Supervisory Controls, at Level 2-3; Factor 3, Guidelines, at Level 3-2; Factor 4, Complexity, at Level 4-2; Factor 5, Scope and Effect, at Level 5-2; Factor 6, Personal Contacts, at Level 6-2; Factor 7, Purpose of Contacts at Level 7-b; Factor 8, Physical Demands at Level 8-1; and Factor 9, Work Environment, at Level 9-1. In their OPM appeal, the appellants originally disagreed with the DCPAS evaluation of Factors 1, 2, 3, 4, and 5. However, since both DCPAS and the appellants credited Factor 2 at Level 2-3, the appellants subsequently decided to remove Factor 2 from their appeal and disagree only with the DCPAS evaluation of Factors 1, 3, 4, and 5, contending they should be credited at Levels 1-5, 3-3, 4-3, and 5-3. After careful review, we concur with the DCPAS factor level assignments for Factors 2, 6, 7, and 8. Therefore, by application of the grading criteria in the GS-0600 JFS our evaluation below focuses solely on Factors 1, 3, 4, and 5.
Factor 1, Knowledge required by the position
This factor measures the nature and extent of information or facts that an employee must understand to do acceptable work and the nature and extent of the skills necessary to apply that knowledge.
At Level 1-4, employees possess knowledge of, and skill in applying, an extensive body of rules, procedures, and operations, such as well-established medical records procedures, regulations, and principles; Joint Commission on Accreditation of Healthcare Organizations (JCAHO) standards and medical records classification systems and references; elementary practical anatomy and physiology, medical techniques, and major disease processes, diagnoses, procedures, tests, pharmaceuticals operations, psychological, and other specialized terms; and computerized data entry and retrieval systems. Medical Records Technicians at Level 1-4 apply this knowledge and skill to sufficiently analyze medical records, maintain special registries, perform quality assurance, compile statistical data, and release medical information; code diagnostic and operative/procedural information; collect and organize data for statistical reports, audits, and/or research projects; and extract data for statistical and other reports.
At Level 1-5, employees possess a thorough and detailed knowledge of, and skill in applying, a comprehensive body of rules, procedures, and operations, such as medical records activities, operations, and regulations; medical terminology, procedures, anatomy, physiology, and disease processes; medical record classification systems coding techniques; and computerized data entry and retrieval systems. They apply this knowledge and skill to sufficiently assist in a wide range of quality assurance studies; make recommendations to improve procedures for compiling and retrieving medical records information; identify specific clinical findings, support existing diagnoses, or substantiate listing additional diagnoses in the medical record; code complicated medical records that are difficult to classify; plan, organize, and maintain special registries; gather and represent data graphically; make a variety of basic statistical computations; identify possible trends and patterns for preparing reports; and manage medical records.
Level 1-4 is met. Like this level, the appellants apply an extensive body of well-established healthcare coding principles, regulations, and procedural guidelines, such as various HCPCS requirements, Military Health System-Specific Coding Guidelines, International Classification of Diseases guidelines; and ICD-CM, CPT, CMMS, AHA, DoD, DHA, and JCAHO healthcare coding and records management guidelines. Similar to this level, the appellants use elementary practical knowledge of anatomy, physiology, medical techniques, and major disease processes techniques. They apply basic knoweldge of diagnoses, procedures, and tests and apply knowledge of computerized data entry and retrieval systems. They do so to identify and code a variety of patient-related diagnostic, treatment, and procedural information, and to perform basic medical record-related quality assurance reviews; extract and provide information in response to scheduled and unscheduled audits; develop reports; and occasionally, when requested, extract, compile, and submit patient care-related data and information used by analysts and agency management for various studies. Comparable to this level, the appellants analyze medical records to identify standard and nonstandard medical records procedural problems, such as obtaining and/or confirming additional or missing information from health care providers and forward this information to the appropriate professional and/or non-professional NMC personnel for resolution.
The appellant’s work does not meet Level 1-5. Unlike this level, their work does not typically require them to possess the thorough and detailed knowledge of medical records activities, operations, and regulations associated with specialized assignments that are characteristic of this level. Unlike this level, the appellants are not typically required to assist in a wide range of research and quality assurance studies; establish and/or maintain special registries of select disease types (e.g., cancerous tumors); or make recommendations to improve procedures for compiling and retrieving medical record information. Contrary to this level, their quality assurance work is limited to reviewing individual medical records compared against a standard and does not involve studies to assess the adequacy of or recommended improvements to medical records processes.
Factor 1 is evaluated at Level 1-4 and 550 points are assigned.
This factor covers the nature of guidelines and the judgment employees need to apply them.
At Level 3-2, employees use a number of procedural and regulatory guidelines that specifically cover the assigned work. The employee uses judgment to identify and select, from a number of similar guidelines and work situations, the most appropriate guidelines, references, and procedures to apply when making minor deviations or adapting guidelines to specific cases; and refers situations that do not readily fit instructions or other applicable guidelines to the supervisor or a designated employee for resolution.
At Level 3-3, the employee uses guidelines that consist of a variety of technical instructions, technical manuals, medical facility regulations, regulatory requirements, and established procedures; and are not completely applicable to some of the work or have gaps in specificity. The employee uses judgment to adapt and interpret guidelines to apply to specific cases or problems; uses discretion and initiative to decide on the appropriate course of action to correct deficiencies and improve the reliability of the information; and may, within the framework established by higher authority, develop approaches to apply to new regulatory requirements, or to adapt to new technology.
Level 3-2 is met. Like this level, the appellants use judgement to select from numerous established procedural and regulatory guidelines. Comparable to this level, the appellants adapt guidelines as needed to specific cases. Similar to this level, most guidelines used by the appellants are specific with regard to procedures and methods for identifying, processing, coding, assembling, and reporting medical information and the appellants are typically restricted to current authorized codes. Like this level, the appellants are required to refer unusual and/or controversial code or medical records-related situations not clearly covered by existing guidelines to their supervisor for resolution.
Level 3-3 is not met. Unlike this level, current coding guidelines available to the appellants are specific, directly applicable, and strictly adhered to by them. Their position does not require them to devise new and/or revised methods for coding patient treatments, procedures, or consumables. Unlike this level, their position neither requires nor permits them to exercise the broad scope of judgment necessary to develop approaches to apply to new regularoty requirements, including coding guidelines, or to adapt to new technology. This authority and responsibility rests with higher-level management within the agency and/or the Federal government.
Factor 3 is evaluated at Level 3-2 and 125 points are assigned.
This factor covers the nature, number, variety, and intricacy of the 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 4-2, work consists of related steps, processes, or standard explanations of methods, such as compiling, recording, and reviewing medical records data. The employee decides what needs to be done by choosing from a few recognizable alternatives, such as determining the relevance of many facts and conditions of information within the medical record, legal and regulatory requirements, and other variables. The employee recognizes inconsistencies in the medical records; and applies prescribed medical records procedures and methods to validate that the record contains factual information.
At Level 4-3, work consists of different, varied, and unrelated medical record processes and methods, including reviewing the work of other employees to verify compliance with regulatory requirements. The employee determines the relevance of many facts and conditions, such as information contained in the record, legal and regulatory requirements, and other variables and determines the appropriate action from many alternatives. The employee identifies and analyzes medical records problems and issues and determines their interrelationships and the appropriate methods and techniques needed to resolve them.
Level 4-2 is met. Like this level, the appellants’ work consists of related steps, processes, and methods associated with reviewing, analyzing, coding, documenting, and reporting diagnostic, treatment, and billable consumables information and a variety of health care services provided to Portsmouth NMC patients. Similar to this level, the appellants decide what needs to be done by choosing the most relevant and appropriate code from a few recognizable alternatives. Comparable to this level, the appellant recognizes and reacts to code-related inconsistencies and issues within individual patient medical records and use prescribed procedures to validate that the record contains factual information.
Level 4-3 is not met. Unlike this level, the appellants’ position does not involve different, varied, and unrelated medical record processes and methods. They are not responsible for reviewing the work of other employees to verify compliance with regulatory requirements, nor are they required to determine the relevance of many facts and conditions, such as information contained in the record, legal and regulatory requirements, or other variables or to determine the appropriate action from many alternatives. Unlike this level, their position does not require them to identify and analyze systemic medical records or coding problems and issues; determine the interrelationships of these problems and/or issues; or to identify possible methods and techniques needed to resolve them. Responsibility for identifying, evaluating, and resolving systemic medical coding issues rests with higher-level managers within the agency.
Factor 4 is evaluated at Level 4-2 and 75 points are assigned.
This factor covers the relationship between the nature of the work and the effect of the work products or services both within and outside the organization.
At Level 5-2, the work involves performing assignments according to specific rules or procedures that represent a significant segment of the medical records function for the organization. The work affects the accuracy, timeliness, reliability, and acceptability of information in the medical record.
At Level 5-3, the work involves performing a variety of specialized medical records tasks, and resolving problems according to established criteria (e.g., processing medical records and data that involve inconsistencies, discrepancies, and other non-routine problems), and developing, maintaining, and monitoring special registries that assist physicians in the care and treatment of patients. At this level, work affects the accuracy and reliability of medical records, which in turn affect the outcome of research efforts; the outcome of internal and external audits; the quality of information physicians receive on such things as readmission and legal claims; and the quality of patient care rendered.
Level 5-2 is met. Like this level, the appellants’ work involves performing assignments according to specific directives, rules, procedures, and protocols representing the totality of Portsmouth NMC’s healthcare coding function. Similar to this level, their work affects the accuracy, timeliness, reliability, and acceptability of diagnostic, procedural, and patient-related information used by Portsmouth NMC to track patient care and to seek monetary compensation for various patient care-related services and consumables.
Level 5-3 is not met. Unlike this level, the appellant’s work involves medical coding performed according to specific rules and procedures. The appellants do not perform a variety of specialized medical records tasks including processing medical records involving inconsistencies, discrepancies, and other non-routine problems involving the delivery of coding, billing, and delivery services within Portsmouth NMC. In addition, they do not develop, maintain, and monitor special registries that assist physicians in the care and treatment of patients. Unlike Level 5-3, their work does not affect the outcome of research efforts; internal and external audits, the quality of information physicians receive on such things as readmission and legal claims, or the quality of patient care rendered. Instead, their work focuses on billable information within individual patient records and directly affects the accuracy and reliability of coded information used to seek compensation for care, services, and consumables associated with individual patients.
Factor 5 is evaluated at Level 5-2 and 75 points are assigned.
Table 1 Grade Determination
|
Factor |
Level |
Points |
|
Knowledge required by the position |
1-4 |
550 |
|
Supervisory controls |
2-3 |
275 |
|
Guidelines |
3-2 |
125 |
|
Complexity |
4-2 |
75 |
|
Scope and effect |
5-2 |
75 |
|
Personal contacts |
6-2 |
---- |
|
Purpose of contacts |
7-B |
75 |
|
Physical demands |
8-1 |
5 |
|
Work environment |
9-1 |
5 |
|
Total Points |
1185 |
|
A total of 1,185 points falls within the GS-06 grade level point range (1,105 to 1,350) on the Grade Conversion Table in the GS-0600 JFS.
The appellants’ position is properly classified as Medical Records Technician, GS-0675-06. Addition of a parenthetical title is at the agency’s discretion.