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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

Melanie A. Moyer
Visual Information Specialist
Medical Media
Public Affairs Office
Office of the Medical Center Director
Veterans Affairs Medical Center
Veterans Health Administration
U.S. Department of Veterans Affairs
Wilmington, Delaware
Visual Information Specialist

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 classification 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 5 CFR 511.605, 511.613, and 511.614, as cited in the Introduction to the Position Classification Standards (Introduction), appendix 4, section G (address provided in appendix 4, section H).

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


On August 3, 2015, OPM’s Agency Compliance and Evaluation (ACE)-Philadelphia accepted a position classification appeal from Ms. Melanie A. Moyer.  The appellant’s position is currently classified as Visual Information Specialist, GS-1084-10, and is located in Medical Media, Public Affairs Office, Office of the Medical Center Director, Veterans Affairs Medical Center (VAMC), Veterans Health Administration (VHA), U.S. Department of Veterans Affairs (VA), in Wilmington, Delaware.  The appellant believes her position should be classified as Visual Information Specialist/Webmaster, GS-1084-11.  We received the complete agency administrative report on October 1, 2015, and have accepted and decided this appeal under section 5112(b) of title 5, United States Code (U.S.C.).

Background and general issues

The record shows that beginning in May 2011, the appellant sought reclassification of her Visual Information Specialist, GS-1084-10, position to the GS-11 grade level.  On March 15, 2012, as the result of a grievance, a desk audit was performed by VAMC Human Resources (HR) staff, which sustained the current classification on March 29, 2012.  On February 1, 2013, the appellant submitted a revised PD to HR, which again sustained the GS-10 grade level on April 2, 2013.  In May 2014, she submitted an updated PD to HR for a classification review.  Because of this review, HR determined the appellant’s position was appropriately classified as Visual Information Specialist, GS-1084-9.  On March 11, 2015, she filed a classification appeal with VA Headquarters Compensation and Classification Service which notified her in a letter dated May 7, 2015, that the agency sustained the GS-9 grade level.  The record shows the agency did not take final action to implement this decision.

The appellant raises concerns about the agency’s classification review process.  She alludes to classification inconsistency as the appellant’s rationale is based on the description of work in a former employee’s higher graded PD; she believes she has taken over those duties.  A PD is the official record of the major duties and responsibilities assigned to a position by an official with the authority to assign work.  A position consists of the duties and responsibilities that make up the work performed by the employee.  Position classification appeal regulations permit OPM to investigate or audit a position and decide an appeal on the basis of the actual duties and responsibilities assigned by management and performed by the employee.  An OPM appeal decision classifies a real operating position, and not simply the PD.  Therefore, this decision is based on the actual work assigned to and performed 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 duties to those of other positions, which may or may not be classified properly, as the basis for deciding this appeal.  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, the agency’s classification review process is not germane to this decision.

Position information

The record shows the appellant’s duties include developing a variety of visual arts materials from the initial planning stage through final production, including reproduction; updating and maintaining the facility internet, intranet, and SharePoint sites; and serving as back-up for updating and maintaining social media sites for internal and external stakeholders, e.g., VAMC employees, Community Based Outpatient Clinic (CBOC) employees, and patients and their families. 

The appellant develops original and creative concepts for intranet webpages based on customer requirements.  For example, the appellant created an original design for a conference room scheduling system on the intranet site with a table outlining the rooms and technology available, the size of each room, and contact information for reservations.  She assisted the Emergency Department’s service chief with creating a webpage for his department that included links to directives, memoranda, and policies related to the Emergency Department for ease of access by his staff.  The design and layout of each webpage is left up to the appellant to create fusing source code, i.e., Hyper Text Markup Language (HTML), and is reviewed and approved by the customer. 

She updates the Employee Bulletin Board on the facility’s intranet site, which contains information such as VAMC news updates, current job openings, employee recognition, employee retirements, etc.  The appellant uses HTML code to display the information and adds visual concepts using Adobe Photoshop or clipart depending on the need, space, and layout.  In addition, the site contains libraries of facility memoranda, standard operating policy documents, forms and publications, and employee resources, e.g., employee directory, employee bulletin board, job openings, etc., which the appellant continually maintains and occasionally improves upon for ease of use, navigation, and Section 508 compliance. 

The appellant maintains and, as needed, modifies the VAMC’s SharePoint site following the requirements of VA Directive 6515, Use of Web-Based Collaboration Technologies.  The appellant adds or removes pages, workspaces, lists, and libraries as requested by the service chiefs.  She reviews and maintains permissions for each site, library, folder, list, etc., by ensuring only those approved to “contribute” or “edit” the information may do so while keeping the information accessible to all staff.  She assists users in uploading documents, troubleshoots user access issues, runs scheduled backups, and empties the recycle bin weekly.

She monitors, performs data comparisons, and reports on website statistics.  She experiments with new efforts to increase ease of navigation for the user, maximizes the information presented in relation to search engines, and revises sites based on external and internal feedback.  For example, through Google Analytics, the appellant receives reports on the internet and intranet website traffic.  By creating a better traffic flow toward more relevant information, she was able to optimize the site for search engines to find the information.  She graphed the intranet statistics to show VAMC supervisors the importance of their intranet site information and used the graphs to demonstrate the Education and Human Resources (especially job opportunities) service areas were the highest in site traffic.

She drafts the electronic Wilmington Weekly newsletter by gathering information from multiple services and mediums (including the Employee Bulletin Board, national newsletters, job listings, facility events calendar, etc.).  It is created in HTML and, a result, it appears as a webpage with links to the intranet for the reader to access for the information.  The newsletter’s primary purpose is to promote specific events to create staff awareness, as well as increase employee usage of the intranet site for finding pertinent information.  Her supervisor is responsible for approving and distributing it via email.  Some supervisors use this weekly newsletter to share important information during staff meetings with employees who do not readily have access to email.

The appellant ensures the internet and intranet sites remain functional.  She modifies source code or takes other actions to locate and fix broken links.  Erroneous code causes pages to load slower and makes it harder for the search feature to accurately identify information.  She checks the problematic page using a link checker, e.g., Broken Link Checker, to identify the broken links and then edits the HTML code to fix the link.  She uses proper syntax or set of rules to troubleshoot and prevent future occurrences.

Customers meet with her to discuss the information objectives of the project and the points to be emphasized in presentations, brochures, posters, banners, etc., for use both electronically and in print form.  She selects appropriate visual materials such as graphics and illustrations; determines the placement of text in relation to visual concepts such as a logo, design, or photograph; decides on the type of style and typographical effects to use and plans the effective use of color schemes and textures, considering the technical constraints of a particular method of communication, e.g., 508 compliance, and user-friendly navigation techniques for webpages.  The appellant uses commercial off-the-shelf computer graphics systems and programs, e.g., an Enterprise Content Management System, Adobe Creative Suite software, and Microsoft Office Products to include Word, Excel, Outlook, PowerPoint, Publisher, Visio, and InfoPath.  She utilizes a wide variety of arts and graphic arts multimedia and materials and the correct techniques associated with the mechanics of cropping and scaling photographs and illustrations.  She also judges the reproduction quality of illustrations and graphics, and coordinates with the staff photographer for pictures needed to display a certain idea while giving the staff photographer cues as to the lighting and the speed to use as needed.  The appellant refers to VA and VHA Section 508 manuals to maintain 508 compliance for all print and web-based material, and VA Handbook 8500, Public Affairs Handbook, to ensure all privacy issues with regard to photography and visual imagery are addressed.

For projects in electronic form, the appellant receives requests in person, by telephone, or email from her customers to create or update webpages or SharePoint sites to convey information to clinicians and administrative staff so these employees can readily access needed information.  If the project requires more than a simple email to explain, she will meet with the customer(s) to gain a clearer picture of the objectives and to suggest alternatives and avenues for the most effective way to present the project.  The appellant develops the design and layout and presents a draft or mock up to the customer prior to publishing for the customer to provide comments and approval.  For example, she designed a SharePoint site for storing VAMC memoranda that affects all employees and individual departments in collaboration with the VAMC Director’s Office Quality Management Team.  This resulted in a document library that enables users to find a policy quickly and efficiently.  She maintains the site and occasionally makes improvements by adding new documents and/or guidance.  In another project with the Quality Management Department, the appellant created a SharePoint site to store the minutes, agendas, scorecards and other documents for the VAMC’s boards, councils, and committees.  She then created separate document libraries for each board and committee to store various documents required by the Joint Commission.  Although she creates and maintains the document libraries, the chair of each is responsible for uploading any document to their respective SharePoint site.

For projects in print form, she reviews the specifications of the project to determine the setup, materials needed, number of copies, type, and size of paper stock.  She develops proofs to inspect for color, balance and other quality imperfections and makes the necessary adjustments.  Depending on the final product, she may need to use several types of equipment to produce it, e.g., a copier, printer, plotter, laminator, and/or binder, and may use cutters for projects which do not use a full sheet of paper, e.g., appointment cards.  The appellant performs all the minor troubleshooting and maintenance for the printer, plotter, laminator, and binder, e.g., replacing toner, drums, waste containers, and changing paper rolls/laminate rolls when they run out.  For products requiring outside printing, e.g., the VAMC annual report, she coordinates with a vendor to ensure the product will appear as originally designed.  For example, she electronically sends the product file to be reproduced to the vendor; the vendor sends a proof to the appellant to review and she provides feedback prior to publication.  Once the appellant approves the proof, the vendor re-produces the product. 

The appellant maintains a listing of the VAMC’s visual equipment, televisions, cameras, DVD players, projectors, laminators, printers, binders, etc.  On a yearly basis, she conducts an annual equipment inventory and forwards the listing to her supervisor to sign as accurate and complete.

The appellant is an active voting member in the Health Promotion & Disease Prevention (HPDP) Committee and the Veterans’ Health Education Advisory Committee (VHEAC).  Each of these committees meets monthly.  She provides advice to the HPDP Committee members concerning advertising their events and activities such as deciding who the audience will be (e.g., staff, veterans, and veterans families/caregivers) and promoting the event through various forms of media (i.e. electronic bulletin boards, direct email campaign, Facebook, internet).  She may also design promotional material and ensure that it is disseminated to the target audience.  VHEAC is tasked with reviewing educational material for patients including brochures and flyers that are specific to program or disease information.  The appellant works closely with subject-matter experts to ensure the educational material meets the VA/VHA style guidelines as well as reviews the content for grammar, spelling, and audience-level comprehension.  After receiving approval from the respective committee, she decides how to disseminate the information (web-based or print material), designs the product, and produces or promotes the product.

To help us decide the appeal, we conducted telephone interviews with the appellant on February 4 and 10, 2016, and her immediate supervisor on February 24, 2016.  In reaching our decision, we have carefully considered all information obtained from the interviews, as well as all other information of record provided by the appellant and her agency.  The appellant and her immediate supervisor certified to the accuracy of the duties described in the appellant’s PD.  However, it is not clear the version of the appellant’s  PD, number 05189-0 to which they were referring as all used the same PD number.  We reviewed her official PD and found it meets the standards of PD adequacy for classification purposes as discussed in section III.E of the Introduction and we incorporate it by reference into our decision, as it contains the major duties and responsibilities assigned to and performed by the appellant.

Series, title, and standard determination

The agency has classified the appellant’s position in the GS-1084 Visual Information Specialist Series and applied the grading criteria in the Grade Evaluation Guide for Visual Arts Work (Guide).  Although the appellant agrees with the series, she requests her position be titled Visual Information Specialist/Webmaster because she states her position contains “mixed series” duties in the Visual Arts and GS-2200 Information Technology (IT) fields.  In her appeal rationale, the appellant states that 55 percent of her duties are clearly defined as web design, publishing, and content management and she believes these are duties related to the GS-2210 IT series. 

The Job Family Standard (JFS) for Administrative Work in the Information Technology Group, 2200, covers two-grade interval administrative positions which manage, supervise, lead, administer, develop, deliver, and support information technology systems and services.  This series covers only those positions for which the paramount requirement is knowledge of IT principles, concepts, and methods, e.g., data storage, software applications, networking.  This knowledge is used to perform such functions as planning, designing, analyzing, developing, and implementing systems for the organization.  Information technology refers to systems and services used in the automated acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, assurance, or reception of information.  Information technology includes computers, network components, peripheral equipment, software, firmware, services, and related resources. 

The 2200 JFS excludes work that involves preparing and updating subject-matter information on an organization’s website that requires knowledge of subject-matter programs and processes and knowledge of basic website development techniques rather than knowledge of IT principles, concepts, and methods as the paramount requirement.  The 2200 JFS includes prescribed specialty or parenthetical titles to further identify the duties and responsibilities performed and the special skills needed.  The appellant states that her duties are reflective of the Internet specialty, which is work that involves the technical planning, design, development, testing, implementation, and management of internet, intranet, and extranet activities, including systems/applications development and technical management of websites.  This specialty only includes positions that require the application of technical knowledge of internet systems, services, and technologies.  However, as the 2200 JFS describes, this specialty excludes positions referred to as Webmaster, Web Manager, and Web Page Manager that do not require a paramount knowledge of IT principles, concepts, and methods.  The appellant’s work is covered by this exclusion.  The appellant works within the parameters of the IT operating environment managed and controlled by IT organizations at higher echelons within VA and VHA which have responsibility for establishing service-wide systems and hardware and software requirements, and making decisions on the need for system upgrades and/or software migrations.

The 1084 series includes positions involved in communicating information through visual means, including the design and display of such visual materials as photographs, illustrations, diagrams, graphs, objects, models, slides, and charts used in books, magazines, pamphlets, exhibits, live or video recorded speeches or lectures, and other means of communicating.  This description represents the primary purpose and knowledge requirements of the appellant’s position and the highest grade level of work performed by the appellant. 

Computer technology is one of the many kinds of visual media that may be selected by the appellant to communicate a particular message and is to be treated as equivalent to traditional visual products used to communicate a particular message.  While there can be considerable difficulty in learning to work with electronic mediums, the degree of sophistication of the equipment or software programs used does not in itself make the work intrinsically more difficult.  Rather, the essential difficulties in visual arts work lie in applying the principles of visual design and exercising the skill to portray what is seen or imagined through an art medium.

Therefore, the appellant’s position is properly assigned to the Visual Information Series, GS-1084, titled Visual Information Specialist, and properly graded using the Guide.  Because the appellant’s work is specifically excluded from coverage by the 2200 JFS, it is not a mixed series position as she asserts, and there is no basis for assigning her position to the GS-2210 series or evaluating the position using the 2200 JFS.

Grade determination

The Guide uses the Factor Evaluation System (FES) and employs nine factors.  Under the FES, each factor-level description describes the minimum characteristics needed to receive credit for the described level.  Therefore, if a position fails to meet the criteria in a factor-level description in any significant aspect, it must be credited at a lower level, 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.  Each factor level has a corresponding point value.  The total points assigned are converted to a grade by use of the grade conversion table in the Guide.

The appellant disagrees with the agency's evaluation of Factors 1, 2, 3, 4, 5, and 8.  After careful review, we concur with the agency's evaluation of Factors 6, 7, and 9.  Therefore, we have confined our analysis to Factors 1, 2, 3, 4, 5, and 8.

Factor 1, Knowledge required by the position

This factor measures the nature and extent of information or facts that a worker must understand in order to do acceptable work and the nature and extent of the skills needed to apply that knowledge.  To be used as a basis for selecting a level under this factor, knowledge must be required and applied.

At Level 1-6, work requires knowledge of a variety of methods, techniques, and materials used in the design, production, and reproduction of visual products to plan the technical details of, or produce, aesthetically composed visual products in a timely manner.  This work requires a basic knowledge of specialized subject matter such as medicine, science, or technical equipment; a field peculiar to the employing organization; or a range of general subjects relating to the work of the organization.  This knowledge is needed to understand the specifications and generally usable, observable, and recognizable visual materials provided with the assignment with little explanation or research.  Visual materials are items to be incorporated into a visual product, such as photographs or charts to be reproduced as part of a publication, items to be illustrated, or artifacts to be exhibited.

The record shows the appellant’s work meets Level 1-6.  Like Level 1-6, the appellant’s work requires a working knowledge of graphic design, illustrative techniques, printing procedures, reproduction methods, photographic copying techniques, electronic publishing, and supporting automation equipment, i.e., printers, scanners, etc.  Her work also requires a proficiency in various graphics software packages including an Enterprise Content Management System, Adobe Creative Suite software, and Microsoft Office Products to include Word, Excel, Outlook, PowerPoint, Publisher, Visio, and InfoPath.  The appellant applies this knowledge by creating new web design features for the VAMC’s internet and intranet sites; updating information on the intranet’s employee bulletin board and libraries; improving upon the internet and intranet sites ease of use and navigation; locating and fixing broken web site links; working with customers to produce visual arts products in accordance with the desired outcome, etc.

At Level 1-7, work requires knowledge of visual arts methods and techniques required at Level 1-6, in addition to knowledge of the subject matter area supported or depicted that is thorough enough to plan visual products that interpret subject matter content information provided with the assignment.  Employees typically are required to apply knowledge of a subject matter or program area in order to develop original designs, concepts, or visual styles for publications, exhibits, or presentation materials that present to the public the ideas or image desired by the organization, that evoke certain responses from viewers, or that reduce the cost of production, installation, or maintenance of the visual product.  The work requires employees to transform spoken or written descriptions of items, processes, issues, or events into visual representations without benefit of existing pictures, models, or diagrams.  At this level, the work may require employees to graphically or physically reconstruct biological, medical, geological, architectural, archeological, technological, or other kinds of artifacts, specimens, or materials that have been significantly damaged, distorted, or altered. 

In support of crediting Level 1-7, the appellant stated a typical visual information project consists of her discussing with the customer the objectives of the project, the intended audience, and what information to emphasize.  She also stated the customer relies on her to develop a product to meet the intended goal.  However, this example is a direct match to Level 1-6 in that the work requires the ability to present subject matter information in a visual form that will convey the intended message to, or have the desired effect on, the intended audience. Like Level 1-6, the appellant may advise, consult, and coordinate with the subject matter experts, i.e., the customer, on various formats, styles, options, and methods to meet the information objectives of the project.  The work does not require the appellant to apply the breadth and depth of subject knowledge required at Level 1-7 because her projects are primarily limited to making already existing information, such as administrative policies and procedures, electronically or otherwise readily available to potential users.  Most of her work involves communicating information within the parameters of the internet and intranet sites and continuously updating the information.  Most of this work is recurring in nature and does not lead to development of new methods, approaches, or procedures.  Therefore, Level 1-7 is not met and Level 1-6 is assigned.

This factor is evaluated at Level 1-6 and 950 points are assigned.

Factor 2, Supervisory controls

This factor covers the nature and extent of direct or indirect controls exercised by the supervisor, the employee’s responsibility, and the review of completed work. 

At Level 2-3, the supervisor makes assignments by defining objectives (e.g., specifying what subject matter is to be depicted and for what purpose), priorities (e.g., specifying what degree of emphasis each aspect of the subject matter is to receive), and deadlines, and assists the employee where projects call for substantial departures from established styles or formats, or from customary methods or materials.  The employee plans and carries out the successive steps of producing the visual product, and independently solves technical problems that arise in the course of using common materials, methods, or techniques.  The employee is personally responsible for the aesthetic quality of the visual product. Completed work is evaluated for compliance with established practice and policy and for meeting the objectives of the assignment. Only methods that represent substantial departures from customary practice are reviewed in detail. 

Level 2-3 is met.  As at this level, the appellant’s supervisor provides directions on work objectives and priorities, resource limitations, deadlines, and deadline changes.  The supervisor or another higher-graded employee provides detailed instructions for new, difficult, or unusual assignments.  He meets daily with his subordinates and discusses any priorities from the VAMC Director.  The appellant identifies the work to be done, plans and carries out the steps required, and submits completed work to the customer for review.  Completed work is reviewed by the supervisor for conformity to deadlines, customer satisfaction, and accepted practices.  Work methods are not normally reviewed.

At Level 2-4, the employee is given only the broad objectives and resource limitations of the project.  The employee consults with the supervisor or client to develop specific ideas on the appearance and contents of the product (e.g., specific photos, illustrations, or artifacts; typography; color scheme; lighting effects; size and placement of artifacts; or number of views to be illustrated).  The employee independently plans and carries out visual arts projects; resolves most differences of opinion or interpretation with clients or contractors; and coordinates the work with clients, contractors, and others such as project team members or structural and fire safety experts.  Completed work is reviewed only in terms of its effectiveness in meeting the overall objectives of the project.  This is generally based on the degree of client satisfaction.

In support of crediting Level 2-4, the appellant stated she plans and creates visual arts projects independently, resolves any differences of opinion with the customer, and completed work products are only reviewed by the customer in terms of the project’s objectives being met.  The record shows the appellant functions independently in planning and carrying out her assignments.  However, similar to Level 2-3, her supervisor ensures the finished work product and methods used are technically accurate and of an acceptable level of aesthetic quality.  While the appellant may not submit her work products to her supervisor for review, he reviews her work in his walks through the VAMC or when he accesses the intranet for the purposes defined at Level 2-3.  Her supervisor is held responsible for the visual arts projects displayed and the content on the VAMC’s internet and intranet sites.  Therefore, Level 2-4 is not met and Level 2-3 is assigned.

This factor is evaluated at Level 2-3 and 275 points are credited.

Factor 3, Guidelines

This factor covers the nature of guidelines and the judgment needed to apply them. 

At Level 3-3, the subject matter is well defined and the aspects to be depicted are already decided.  Unlike the next lower level, formats or methods have not been specified in detail with total accuracy.  Guidelines consist primarily of examples of previous similar, but not identical projects done for the organization; examples of similar, but not identical visual products found in books or magazines; or sketches, construction drawings, photographs, virtually intact specimens, or other materials provided by clients.  The employee uses judgment in transforming these ideas and visual materials into finished visual products that achieve the desired purpose and effect.  The employee is expected to recognize where precedent projects, design specifications, or materials offered by clients must be adapted, decide how they should be adapted, and recommend these changes.

Level 3-3 is met.  Similar to this level, the appellant transforms ideas and visual materials into finished products to achieve the desired purpose and effect, and her customers have a general idea as to the subject matter they would like depicted.  The record shows most of the appellant’s work is recurring in nature because she has produced similar products in the past, i.e. brochures, annual reports, SharePoint directories, and intranet sites.  She uses VA and VHA manuals to maintain 508 compliance for print and web based materials; VA directives to establish, manage, maintain, and present information on the VAMC’s internet and intranet web sites; VA Directive 6515 to modify the VAMC’s SharePoint site, etc., and they require similar interpretative demands.

At Level 3-4, the subject matter to be depicted is either novel or vague, and the form and content of the visual product are left to the discretion of the employee.  Because of the unique nature of projects, guidelines are scarce or of limited use.  Guides that do exist typically consist of rough sketches, simplistic diagrams, or damaged specimens provided by clients.  The employee uses initiative and resourcefulness in researching the subject matter to be depicted (e.g., specimens, historic structures, or aircraft), searching for appropriate visual elements, or testing new materials and methods to use in creating a visual product.

The appellant stated Level 3-4 should be assigned to her position because it includes visual arts projects for novel or vague subject matter, where the form and content are left to the employee’s discretion, which are duties the appellant states she performs.  She also stated clear cut guidelines are rare or consist of rough ideas, sketches or renderings, etc.  The appellant further stated she uses resourcefulness and initiative when researching subject materials, searching for and identifying visual and textual elements, and using new and innovative materials and methods to create a product with the impact requested by the customer.  The record does not support the appellant’s assertions. Unlike this level and as previously discussed, the appellant’s work assignments are of a more recurring nature and are covered by procedures and guidelines which are developed and controlled at the VA and VHA levels.  These guidelines include standard reference materials and operating manuals typical of Level 3-3 that go into detail as to the methods and procedures to be used to accomplish the work.  Therefore, Level 3-4 is not met.  

This factor is evaluated at Level 3-3 and 275 points are assigned.

Factor 4, Complexity

This factor covers the nature, number, variety, and intricacy of tasks, steps, processes, or methods in the work performed; the difficulty in identifying what needs to be done; and the difficulty and originality involved in performing the work.

The appellant asserts her work meets Level 4-5.  In support of Level 4-5, the appellant stated most projects require her to present subject matter information geared toward the intended audience and that she determines which images to use and visually emphasize.  She also stated there is usually no “previous visual guideline” so she develops unique visual products from customer ideas, concepts, and information.

At Level 4-3, the work involves a variety of visual arts projects, each with its own sequence of different technical processes.  Themes or subjects, as well as the general format (medium, color scheme, overall dimension, etc.) to be used, are already established or specified by others.  The emphasis is on technical proficiency in the development of visual products.  At this level, the employee makes decisions necessary to work out details of the final visual product (illustration, publication, or two-dimensional exhibit layout, free-standing three-dimensional exhibit case, sequence of slides or transparencies) after the subject, theme, and general format have been determined and presented to the employee in the form of sketches, scale models, plans, or diagrams.  The employee applies knowledge of the characteristics of a variety of art media and visual materials and methods to produce finished visual products.  These products typically present factual information or depict specific operations or occurrences, and are based on design concepts and subject matter content provided by others.

We find Level 4-3 is met.  Similar to this level, the appellant creates a variety of visual arts projects each with its own processes, e.g., brochures, booklets, folders, posters, and displays using various materials and formats.  The subject matter is usually specified or is already established.  The appellant prepares rough drafts and works closely with requestors to select the most appropriate rendering, including choice of color(s) and emphasis items, and discusses substantial departures from established requirements.  She considers such factors as size, medium, purpose of illustration, intended audience, reproduction criteria, etc., and works from existing materials, sketches, photographs, requestors' ideas or suggestions.  The appellant uses a variety of methods, techniques, materials, or art media; however, the type of exhibit or presentation affects these.  The appellant’s work requires decisions on how best to present the specified subject matter, assess whether or not there is sufficient subject information and visual material available, and identify possible sources of additional information and material needed to develop the product.  These projects require a high degree of artistic skill in the use of various art techniques and media that will enhance the publication or presentation.  She selects the proper art media, format, and reproduction process to use, makes creative layouts and rough sketches for approval by the customer, and prepares illustrations that will communicate the theme of the publication or presentation.  For example, the appellant creates new web design features for the VAMC’s intranet sites, and determines the placement of text in relation to visual concepts such as a logo, design, or photograph.

At Level 4-4, the work involves varied projects requiring the application of a wide range of methods, techniques, materials, or art media.  The projects are conventional, but no format or visual style has been specified and the employee must visually interpret the subject matter to be depicted.  Visual products have been produced before on the same general subject matter and in the same general manner of presentation, i.e., illustration, publication, exhibit, sequence of visuals to accompany a speech, training class, or briefing.  The emphasis is on planning, research, and collaboration with persons knowledgeable in the subject matter to be depicted or presented.  At this level, the work requires decisions on how best to present specified subject-matter information.  These decisions include assessing whether there is sufficient subject matter information and visual material immediately available, and identifying possible sources of additional information and material needed to develop a visual product.  The employee also must decide which images, views, or artifacts to present and how to give particular visual emphasis to some of them through size, color, texture, variations in the degree of detail, typography, lighting, or location.  Projects typically require departing from past approaches used in the design or production of similar products in order to create a new visual effect, or to adjust to differences in time or money available, in location or space available, in certain details of the subject matter itself, or in aspects of the subject matter to be emphasized.

Level 4-4 is not fully met.  Like this level, the appellant’s work projects require the application of various methods, techniques, and materials.  The projects are conventional and the visual art work created describes the work being performed by a particular service or serves as basic technical references.  The format or visual style are generally not specified; she interprets the subject matter to be depicted, and suggests alternatives within cost and time constraints.  However, her projects do not involve particularly technical or complex material but rather consist more of organizational and general information of limited technical complexity, e.g., the weekly bulletin and patient educational handouts and brochures.  

As discussed above, the appellant’s position fails to fully meet Level 4-4.  Thus, since the threshold for Level 4-4 is not met, consideration of the next higher level would normally not be necessary or appropriate.  However, for purposes of this review we are also responding to the appellant’s rationale for assignment of Level 4-5.

At Level 4-5, the work involves projects characterized by the need for extensive research into, and decision making on, the subject matter to be depicted due to conditions such as novelty of the subject matter to be depicted or presented (e.g., newly found zoological species, newly conceived technology, newly observed natural phenomenon, unique historic structures); the abstract nature of the subject matter to be depicted or presented (e.g., broad concepts or ideas as opposed to specific events or processes); or the multiplicity of themes in the subject matter to be depicted and diversity in the levels of knowledge and interest among members of the audience.  At this level, the work requires decisions on design and technique similar to those required at Level 4-4, and in addition, decisions on the precise subject-matter content and the aspects of the subject matter to be emphasized.  Because there is no previous visual treatment of the subject matter due to its novelty or unique nature, the employee plays the major role in transforming ideas and information into a visual product.  The work requires translating subject-matter ideas and information into unprecedented visual products.  The employee typically decides what aspects of the subject matter will be depicted and emphasized as well as how each will be depicted.

The record shows the appellant’s work projects, unlike Level 4-5, do not involve depicting subject matter that is novel, abstract, or contains multiple themes and diversity in the knowledge levels and interest among the audience.  Similar to Level 4-3, the work involves a variety of different projects, each with its unique techniques and processes.  The subject matter depicted does not require extensive research in technical publications.  Rather, most of the information can be readily obtained from program files.  Therefore, Level 4-5 is not met.

This factor is evaluated at Level 4-3 and 150 points are assigned.

Factor 5, Scope and effect

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 5-3, the purpose of the work is to plan the details of developing a variety of conventional visual products that depict or present subject matter information or ideas.  These visual products are conventional in that similar products have been produced in the past covering the same general subject matter and using the same general manner of presentation.  Work products support and affect the adequacy of such activities as public information, training, developing technical publications, or conducting relations with professional communities associated with the work of the organization.

Level 5-3 is met.  The appellant’s projects are interpretive in nature and are designed to attract the audience’s attention and aid in communicating the desired message by reinforcing the ideas that are expressed verbally and/or in writing to the audience.  These work products include public information materials, and information for employees, etc.  For example, the appellant is the intranet site administrator and she ensures it remains fully functional and easy to navigate.  The appellant updates the ideas and messages that the service chiefs and other program officials want to provide to the employees as needed.  Another example is the appellant updating the information found on the information kiosks and electronic message boards located throughout the VAMC, e.g., upcoming events.  The appellant updates these to provide information not only to employees but to visitors of the VAMC.  Typical of Level 5-3, the purpose of the appellant’s assigned work is to provide visual graphics support for technical and non-technical publications for the serviced organization.  Assignments often involve design problems, defining requirements, composition, layout, and form of visual materials.  The work contributes to the effectiveness of the material being presented and impacts on the programs and activities of the organizations serviced.

At Level 5-4, the purpose of the work is to design visual products characterized by their novelty and unusual scale involving a multiplicity of media or individual visual components.  The products typically require specifying, accepting, and when necessary, rejecting custom-produced photographs, illustrations, murals, maps, video or animated sequences, models, sculpture, exhibit display cases, or unique support or suspension systems for artifacts of unusual size, weight, or fragility.  The designs affect a wide range of activities both within and outside the agency, such as in-house production operations, procurement actions, and finance office transactions; the activities of private sector visual arts production contractors (e.g., illustrators, photographers, printers, exhibit builders, muralists, cartographers, sculptors, and model makers); and the activities of other local, State, and Federal agencies involved in related work.

In support of crediting Level 5-4, the appellant stated she designs visual products which are novel or unusual, and creates banners reproduced by vendors.  She also stated she develops, tests, and implements new technologies for the VAMC Director’s blog, videos, and the SharePoint web site.  Unlike this level, the record does not show the appellant’s products are novel or unique.  Like Level 5-3, they are relatively simple, self-contained items, such as a weekly newsletter, technical bulletin, folder, electronic display, presentations, brochures, posters, and banners.  These products are not of the magnitude or complexity expected at this level, which might include, for example, designing a visual display for the visitor center of a park, historic site, or agency headquarters that involves such elements as maps, illustrations, display cases for historic artifacts or natural specimens, and video sequences.  Most of the appellant’s products are of a much smaller scale and she completes most of the printed visual products herself using reproduction equipment, e.g., printer/copier, and other equipment to assemble the product such as a binder and laminator.  Some documents, e.g., the annual report, are forwarded to the Government Publishing Office for reproduction due to the complexity of the document.  This rarely occurs and she may have to coordinate with the Government Printing Office’s contractors to ensure the material sent will be printed as originally designed.  Because the appellant creates small scale products, she completes them herself and does not have to coordinate and review the work of contractors or other in-house visual arts production personnel on a regular basis.  Therefore, Level 5-4 is not met.

This factor is evaluated at Level 5-3 and 150 points are assigned.

Factor 8, Physical demands

This factor covers the requirements and physical demands placed on the employee by the work assignment.

At Level 8-1, the work may require some walking, standing, bending, or driving an automobile.  The appellant’s position meets Level 8-1 as work is primarily performed while sitting, although there is some walking or standing required when performing duties. 

At Level 8-2, the work may require some physical exertion, such as long periods of standing or recurring lifting of moderately heavy items.  This is typical of work involving personal production or installation of exhibits, illustration work “on location,” or on-site inspection or supervision of one or more phases of the production of a visual product.

In support of crediting Level 8-2, the appellant stated she occasionally travels within the VAMC or to one of the CBOC’s to perform work “on location.”  She also stated the Guide includes the following in its description of Level 8-2 work:  “The work requires some physical exertion, such as long periods of standing or recurring lifting of moderately heavy items.”  Because most of the printed form visual products are reproduced in-house, the appellant is responsible for the upkeep and maintenance of the various machines used.  For example, the paper rolls for the plotter are 44” x 100" and weigh approximately 23 pounds and the Durafilm used for the laminator machine are 42” x 250" and weigh approximately 40 pounds.  She replaces these as needed by lifting them onto the machines.  The appellant is also responsible for placement of visual products throughout the VAMC and the CBOCs.  For example, she printed and laminated 100 National Patient Safety Goals posters sized 11” x 17” for placement in each clinic, and anything that is hung in a clinic must be laminated so that it can be wiped down for infectious control.  Each month, there is a different patient educational campaign and she is responsible for the production and hanging of the posters throughout the VAMC and the CBOCs.

Level 8-2 is not met.  The physical demands of hanging small posters falls short of those involved in long periods of standing.  As noted in the Primary Standard, Level 8-2 is defined as work requiring “some physical exertion, such as long periods of standing; walking over rough, uneven, or rocky surfaces; recurring bending, crouching, stooping, stretching, reaching, or similar activities; or recurring lifting of moderately heavy items, such as typewriters and record boxes.  The work may require specific, but common, physical characteristics and abilities, such as above average agility and dexterity.”  This level may only be credited when such demands are a regular and recurring aspect of the work performed.  The claimant’s occasional lifting of paper rolls fails to meet this requirement as it is done sporadically.  Therefore, because Level 8-2 is not met fully, Level 8-1 must be credited.

This factor is evaluated at Level 8-1 and 5 points are assigned.


Factor Level Points
1.  Knowledge required by the position 1-6 950
2.  Supervisory controls 2-3 275
3.  Guidelines 3-2 275
4.  Complexity 4-3 150
5.  Scope and effect 5-3 150
6&7.  Personal contacts & Purpose of contacts  3-b 110
8.  Physical demands 8-1    5
9.  Work envionment 9-1    5
Tpotal Points 1920


The total of 1920 points falls within the GS-9 point range (1855-2100) on the grade conversion table in the Guide.  Therefore, the appellant’s position is properly graded at the GS-9 level.


The appellant’s position is properly classified as Visual Information Specialist GS-1084-9.



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