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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

Patricia A. Wilde
Assistant Commissary Officer
Office of Store Director
Air Force Base Commissary
Central Area/Zone 1
Store Operations Group
Defense Commissary Agency
Barksdale Air Force Base, Louisiana
Assistant Commissary Officer

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



As provided in section 511.612 of title 5, Code of Federal Regulations (CFR), this decision constitutes a certificate 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).


On July 16, 2014, OPM’s Dallas Agency Compliance and Evaluation accepted a classification appeal from Ms. Patricia A. Wilde.  The appellant’s position is currently classified as Assistant Commissary Officer, GS-1144-11, but she believes it should be classified at the GS-12 grade level.  The position is assigned to the Office of Store Director, Air Force Base Commissary, Central Area/Zone 1, Store Operations Group, Defense Commissary Agency (DeCA), at Barksdale Air Force Base (AFB), Louisiana.  We received the complete agency’s administrative report (AAR) on September 8, 2014.  We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

Background and general issues

The appellant’s position was previously classified as Assistant Commissary Officer, GS-1144-12.  The human resources office of DeCA headquarters notified her that the agency had reviewed the classification of the position and determined it was appropriately classified at the GS-11 grade level.  Effective June 15, 2014, the appellant’s position was downgraded and assigned to official position description (PD), number DS11033.  In the appeal request to OPM, the appellant states there “has been no justification given as to why this action was taken,” and moreover that the “responsibilities listed on the [PD] for GS 11 (downgraded position) are the same as the responsibilities for the GS 12 position.”

By law, OPM must classify positions solely by comparing their current duties and responsibilities to the criteria specified in the appropriate OPM position classification standard (PCS) or guide (5 U.S.C. 5106, 5107, and 5112).  The law does not authorize use of other methods, such as comparison to other positions that may or may not have been classified correctly.  Consequently, we cannot compare the appellant’s position to her former position as a basis for deciding her appeal.  In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of her position.  Because our decision sets aside all previous agency decisions, any concerns regarding the agency’s evaluation of the classification of her position are not germane to this decision.

The appellant certified to the accuracy of her official GS-11 PD.  However, she states the PD does not describe the security coordination duties she performs as her Commissary’s Force Protection Monitor.  Only duties that occupy at least 25 percent of an employee’s time can affect the grade of a position (Introduction, section III.J).  Therefore, we will not evaluate the appellant’s ancillary security coordination work in this decision.  She also states her security coordination work requires a Level 2 security clearance.  The security clearance associated with a position is a condition of employment and does not have a direct bearing on the position’s grade.  Since the level of clearance required is independent of a position’s grade, the appellant’s security clearance also cannot be considered in determining the grade of her position.

The agency created April 2013 supplemental guidance to the PCS for the GS-1144 Commissary Management Series, which was applied by DeCA to evaluate the classification of the appealed position.  All positions subject to the Classification Law contained in title 5, U.S.C., must be classified in conformance with OPM’s published PCSs.  Hence, other methods or factors of evaluation, such as position-to-position comparison as discussed previously or the application of agency-developed supplemental classification guidance, which has neither been reviewed or approved by OPM for use, may elucidate the meaning of OPM standards, but may not be used as a substitute for OPM classification standards for classifying positions in the classification appeals process.

Position information

As Assistant Commissary Officer for the Barksdale AFB store, the appellant fully participates with the Commissary Officer in the management of all store activities.  The appellant, along with the Commissary Officer, manages the activities and functions of the Commissary which has the full range of departments (e.g., grocery, meat, produce, and management support).  Her work entails participating with the Commissary Officer in managing store resources, ensuring adequate services are provided to patrons, ensuring performance of quality assurance work, monitoring suggestions for improvement from customers and others and ensuring implementation of adopted ideas, and scheduling and attending community, staff, patron, and other organizational meetings.  In addition, the appellant provides advice and guidance to store division managers as necessary, assists managers in the development of major programs and departmental goals and objectives, and sets specific priorities and schedules to complete work.  Her position is supervised by the GS-1144-12 Commissary Officer, who is fully responsible for managing all activities and functions of the Commissary.

The appellant is responsible for activities of the front end, customer service, and store operations departments.  She spends a minimum of 25 percent of her time supervising the approximately 65 employees assigned to the Commissary.  Through subordinate supervisors and work leaders, she directs and controls phases of commissary operations to include receiving, inspecting, and storing stock; processing packaging, pricing, displaying, and replenishing of supplies; performing inventories; selling subsistence; receiving money for purchases; using electronic cash registers; verifying registers and making deposits; and other related functions.  The appellant carries out a full range of supervisory human resources duties such as planning and assigning work, evaluating performance, hearing and resolving complaints, taking disciplinary actions, approving leave, and awarding, developing, and training employees.

The appellant and the Executive Director of the Store Operations Group (her fourth-level supervisor) certified to the accuracy of the duties described in the PD of record.  This PD and other material of record furnish much more information about the appellant’s duties and responsibilities and how they are performed and we incorporate it by reference into this decision.  To help decide this appeal, we conducted telephone interviews with the immediate supervisor on January 14, 2015, and the Zone Manager (her second-level supervisor) on February 10, 2015.  In deciding this appeal, we carefully considered all of the information gained from these interviews, as well as the written information furnished by the appellant and her agency, including the PD of record.

Series, title, and standard determination

The agency assigned the appellant’s position to the GS-1144 Commissary Management Series, titled it Assistant Commissary Officer (i.e., the title used for full assistants to commissary officers sharing fully in the duties, responsibilities, and authorities of the commissary officer), and applied the grading criteria in the GS-1144 PCS.  The appellant does not disagree and, after careful review of the record, we concur.

The appellant’s position meets the requirements for coverage and evaluation by the General Schedule Supervisory Guide (GSSG).  The agency did not evaluate her supervisory work by application of the GSSG.  We applied the GSSG to the appellant’s supervisory work and determined that those duties and responsibilities are graded lower than her GS-1144 covered work.  Since her GSSG covered duties are not grade controlling, we will not discuss them further.

Grade determination

As stated on page 5 of the GS-1144 PCS, Assistant Commissary Officer positions are normally graded one grade below the Commissary Officer position.

The OPM accepted and processed separate classification appeals from incumbents of the Commissary Officer (the appellant’s supervisor) and Assistant Commissary Officer (the appellant) positions at the Barksdale AFB.  As the grade of the appellant’s position is aligned with the Commissary Officer position, we initially evaluated the classification of the Commissary Officer position.  In doing so, we applied Part I of the PCS which contains criteria covering commissary officer positions at grades GS-9 through GS-13.  Positions are graded on the basis of their duties and responsibilities, as evaluated in terms of three factors which combine to include the relative complexity and difficulty of the work:  Scope of Operations, Complexity of Operations, and Level of Managerial Responsibility.

In our evaluation of the Commissary Officer’s position, we found the position properly classified at the GS-12 grade level (OPM decision number C-1144-12-01).  By application of instructions in the PCS to grade Assistant Commissary Officer positions one grade below the Commissary Officer’s, the appellant’s position is properly classified at the GS-11 grade level.


The position is properly classified as Assistant Commissary Officer, GS-1144-11.

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