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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

David Leffert
Category Manager (Specialty Departments)
Category Management Division
Sales Directorate
Sales Marketing & Policy Group
Defense Commissary Agency
Fort Lee, Virginia
Commissary Management 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 certificate which is mandatory and binding on all administrative, certifying, payroll, disbursing, and accounting officials of the Government. The agency is responsible for reviewing its classification decisions for identical, similar, or related positions to ensure consistency with this decision. There is no right of further appeal. This decision is subject to discretionary review only under conditions and time limits specified in the Introduction to the Position Classification Standards (Introduction), appendix 4, Section G (address provided in appendix 4, section H).

Since this decision lowers the grade of the appealed 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 the 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 report containing the corrected position description 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 OPM Agency Compliance and Evaluation (ACE) Atlanta Office.


On January 27, 2015, the U.S. Office of Personnel Management’s (OPM) Agency Compliance and Evaluation (ACE) Atlanta office accepted a classification appeal from Mr. David Leffert.  On April 22, 2015, we received the complete agency administrative report (AAR).  The appellant’s position is currently classified as Category Manager (Specialty Departments), GS-1101-13, and is located in the Category Management Division, Sales Directorate, Sales Marketing and Policy Group, Headquarters, Defense Commissary Agency (DeCA), in Fort Lee, Virginia.  The appellant believes his position should be classified at the GS-14 grade level.  We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).


In 2013, DeCA realigned its Sales Directorate and, as a result, the Category Management Division was created and the appellant’s position was classified as a Supervisory Category Manager (Specialty Departments), GS-1101-13.  The appellant disagreed with the grade of his position and requested a position review.  In November 2014, the DeCA Headquarters Human Resources Directorate conducted a position review which resulted in a change in title (i.e., removing the “supervisory” title) and classification of his position as Category Manager (Specialty Departments), GS-1101-13.  Disagreeing with the results, the appellant subsequently filed this appeal with OPM. 

General Issues

The appellant makes various statements about his working conditions, his agency’s evaluation of his position, and compares his duties to higher graded category manager positions in his organization.  In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of his position.  By law, we must make that decision solely by comparing his current duties and responsibilities to OPM standards and guidelines (5 U.S.C. 5106, 5107, and 5112).  Since comparison to standards is the exclusive method for classifying positions, we cannot compare the appellant’s position to others that may or may not be properly classified as a basis for deciding his appeal.  Because our decision sets aside all previous agency decisions, the appellant’s concerns regarding his agency’s classification review process are not germane to this decision. 

Like OPM, the appellant’s agency must classify positions based on comparison to OPM standards and guidelines.  However, the agency also has primary responsibility for ensuring that its positions are classified consistently with OPM appeal decisions.  If the appellant considers his position so similar to others that they all warrant the same classification, he may pursue the matter by writing to his agency’s human resources headquarters.  In doing so, he should specify the precise organizational location, classification, duties, and responsibilities of the positions in question.  If the positions are found to be basically the same as his, the agency must correct their classification to be consistent with this appeal decision.  Otherwise, the agency should explain to him the differences between his position and the others.  

The appellant also indicates that following the realignment of his organization, he was given additional responsibilities for operating the fresh food department along with the deli and bakery.  This increased his workload which now involves overseeing and managing a number of fresh food items (e.g., sushi trays) and packaged goods (e.g., seafood tray packs) to complement the stock assortment of products already merchandised in the specialty departments.  However, volume of work cannot be considered in determining the grade of a position (The Classifier’s Handbook, chapter 5).

Position information 

DeCA operates a worldwide chain of commissaries providing groceries to military personnel, retirees, and their families in a safe and secure shopping environment.  By shopping regularly in the commissary, patrons save an average of 30 percent or more on their purchases compared to commercial prices, amounting to thousands of dollars in savings annually.  

The Category Management Division comprises 13 separate category groupings for food, beverages, bread and snacks, specialty foods, frozen food, dairy, produce, meat, deli/bakery/fresh seafood, paper and laundry, pet food and household, beauty care, and baby and healthcare.  Teams for these groups work closely with all levels of DeCA management on matters relevant to category management, buying and selling of goods.  The appellant serves as a Category Manager over the specialty departments of deli, bakery, and seafood.  As such, he is the recognized expert in the field for his assigned commodities and supervises a Merchandising Specialist, GS-1101-12, and a File Maintenance Assistant, GS-303-7 (who he began supervising in September 2014).   

The appellant works with store operations and contracting personnel at headquarters and with commissary personnel in the field to resolve pricing and stock assortment issues that may arise with deli and bakery contractors.  He is the point-of-contact for contractor operations compliance issues and assists in resolving problems by providing guidance, or if the issues continue, informing contracting personnel of contractor non-compliance.  He serves as the subject-matter expert for determining contract deficiencies or by participating in contract award advisory panels to review contract proposals. 

The appellant performs competitive analysis by category, brand, and package to identify trends and opportunities and develops category management plans and implementation strategies to enhance customer sales and savings.  He provides input to the headquarters policy group regarding specialty department policies and procedures and to the field stores on sales and merchandising related policies and procedures.  He is involved in identifying and making recommendations to resolve problems at the store level involving policy, procedures, personnel resources, equipment needs, and funding issues.  

Both the appellant and his immediate supervisor (Deputy Director of Sales, GS-1101-15) certify to the accuracy of the appellant’s official position description (PD) (PD number HQ15008).  In reaching our classification decision, we have carefully reviewed all information provided by the appellant and his agency including his official PD, which we find sufficient for purposes of classification and incorporate by reference into this decision.  In addition, to help decide the appeal we conducted separate telephone interviews with the appellant and his supervisor, including a follow-up interview with his supervisor and requests for additional information from both the appellant and supervisor.

Series, title, and standard determination

The agency has placed the appellant’s position in the General Business and Industry Series, GS-1101, which is the general occupational series for positions properly assigned to the Business and Industry Group, GS-1100.  Because there are no titles specified for positions in the GS-1101 series, the agency assigned the title of Category Manager (Specialty Departments) and evaluated it by application of the Administrative Analysis Grade Evaluation Guide (AAGEG).   The appellant does not dispute the series or the use of the AAGEG to evaluate his position.  The General Business and Industry Series, GS-1101, covers all classes of positions the duties of which are to administer, supervise, or perform:  (1) any combination of work characteristic of two or more series in the group, where no one type of work is series controlling and where the combination is not specifically included in another series; or (2) other work properly classified in this group for which no other series has been provided. 

Our fact-finding does not support placement of the appellant’s position in the GS-1101 series.  The record shows the reason for the position’s existence is to improve the effectiveness of DeCA store operations by providing the right stock assortment to enhance customer sales and savings and to  increase customer transactions and patron awareness of the commissary benefit.  The paramount knowledge required by the position is knowledge of category management principles, techniques, and methods to plan, manage, or make decisions on product assortment, pricing, and promotions in order meet DeCA’s mission to “deliver a vital benefit of the military pay system that sells grocery items at cost while enhancing quality of life and readiness.”  Further, this determination is supported by his supervisor who indicated that the paramount knowledge needed for the incumbent's position is a sound understanding of deli, bakery, and seafood operations, including knowledge of product assortment, pricing, merchandising practices and equipment used.

The record shows the appellant’s work is appropriately assigned to the Commissary Management Series, GS-1144, which includes positions that manage, supervise the management of, or advise on the operation of commissaries or commissary departments.  Positions in this series, like that of the appellant’s, require knowledge of commercial food merchandising as well as knowledge of Department of Defense (DoD) commissary policy, equipment and facilities maintenance, security, contracting, pricing, and ordering.  These functions represent the primary work performed by the appellant, the purpose of the position, and reflect the paramount knowledge required to perform the work.  Thus, the appellant’s position is properly placed in the GS-1144 series and titled Commissary Management Specialist, which is the title authorized for positions like the appellant’s that are responsible for developing, analyzing, evaluating, advising on, or improving the effectiveness of administrative, accounting, budgetary, purchasing, and operational procedures in commissary stores and departments typical of this series.  These positions may be located at the agency headquarters, regional, or local level.   

The agency evaluated the grade of the appellant’s positon by application of the AAGEG.  We disagree with their determination.  The AAGEG provides grade level criteria for non-supervisory staff administrative analytical, planning, and evaluative work, at grade GS-9 and above.  However, this guide is used to evaluate work that is administrative in nature and does not require specialized subject-matter knowledge and skills.  However, the appellant’s work requires category management subject-matter knowledge, as well as knowledge and skills in merchandising and marketing practices.  The Position Classification Standard (PCS) for the Commissary Management Series, GS-1144, does not provide grade-level criteria for Commissary Management Specialist positions and instructs that these positions be graded on the basis of their nonsupervisory responsibilities in accordance with the appropriate subject-matter standards or guides.  Based on the functions and the nature of the work performed, the appellant’s position is appropriately graded using the criteria in the Grade Evaluation Guide for Supply Positions.  This guide provides grade level criteria for nonsupervisory operating and staff work in the administrative (two-grade interval) supply occupations at grades GS-9 and above.  Worked covered by the guide requires specialized knowledge and skills in one or more areas of Federal supply operations or Federal supply program management.

The appellant claims his supervisory responsibilities over the Merchandising Specialist, GS-1101-12, and the File Maintenance Assistant, GS-303-7, consume at least 25 percent (i.e., 10-15 percent for each employee) of his time and, thus, his position should be classified  as supervisory.  His rationale for this amount of involvement with his subordinate positions is described as follows:

Specialty Departments are complex because we deal so extensively with PLUs [Product Lookup Codes] and the need to manufacture our own PLUs for unique items is an endless task.  In addition, with 6 contractors, we have 6 different product mix selections to manage which creates a lot of intervention on my part.  In addition, due to the extensive interaction with other divisions, oversight is required in most matters because there is little routine and experience is required to guide decision making.  Between the merchandising and file maintenance questions, I spend more time (well over 10 hours a week) supervising than the typical Category Manager. 

In order for a position to be titled “supervisory” and graded by using the General Schedule Supervisory Guide (GSSG), the position is required to accomplish work through the technical and administrative direction of others and meet at least the lowest level of Factor 3, Supervisory and Managerial Authority Exercised, in the GSSG based on supervising Federal civilian employees, Federal military or uniformed service employees, volunteers or other non-contractor personnel.  Such work must occupy at least 25 percent of the position’s time. 

While the appellant exercises both technical and particularly administrative control required under Factor 3 of the GSSG (e.g., interviewing candidates for positions and recommending personnel actions; developing performance standards and evaluating work performance; effecting minor disciplinary measures; arranging for training and development; and formally hearing and resolving complaints), a review of the duties and grade levels of the subordinate positions, and their working and reporting relationship within the organization, do not support the demands the appellant describes are placed on him.  An analysis of the GS-12 PD, certified as current and accurate by competent management authority, credits the position’s supervisory controls at Level 2-4, for working independently within a framework of established guidelines and procedures with the supervisor setting overall objectives and resources available.

During our interview with the appellant he indicated that when working on a renovation, he could spend all day with the Merchandising Specialist.  He also stated that because his File Maintenance Assistant is new and perishable categories require the use of PLU codes as opposed to DeCA’s Universal Product Codes (UPC), he has to provide her with guidance on PLUs, as well as ensure she enters the right line items into the correct categories in the system.  However, during our interview with the appellant’s supervisor, he stated that although he did not know exactly how much time the appellant was spending performing supervisory duties, but indicated it should be less than 20 percent.  Moreover, he indicated that he did not believe the appellant was spending 10-15 percent of his time supervising the File Maintenance Assistant as they had senior file maintenance specialists who provided instruction on the technical aspects of their core business system and that in general, none of the category managers had detailed knowledge of file maintenance activities in their system. Thus, we find both these situations are transitory and cannot be used as the baseline percentage of supervisory work performed on a regular and recurring basis for a staff consisting of only two full performance level employees.  Therefore, given the limited technical supervision demands of the appellant’s position, as well the degree of independence certified to in the subordinates’ positions, we conclude that the appellant does not meet the minimum 25 percent threshold for supervision of the two positions.  Thus, his position cannot be evaluated by using the GSSG or be titled “supervisory.” 

Grade determination

Positions evaluated by the Grade Evaluation Guide for Supply Positions are evaluated on a factor-by-factor basis using the Factor Evaluation System (FES) factor level descriptions contained in the guide.  Total points for all factors are converted to grade levels using the table provided in the guide.  Under the FES, each factor-level description demonstrates the minimum characteristics needed to receive credit for the described level.  If a position fails to meet the criteria in a factor-level description in any significant aspect, it must be credited at a lower level 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.  Our application to the nine FES factor level descriptions to the appellant’s position follows.

Factor 1, Knowledge Required by the Position

This factor measures the nature and extent of information an employee must understand in order to do the work, and the skills needed to apply that knowledge.

At Level 1-7, work requires knowledge of a broad range of supply program relationships or significant expertise and depth in one of the specialized fields of supply operations.  Assignments require knowledge of specialized methods and techniques to analyze and evaluate the effectiveness and efficiency of supply programs and/or operations.  The employee at this level applies a depth of knowledge developed from extensive experience in one or more areas of supply operations or management programs.  The work requires the employee to analyze independently and resolve difficult issues and problems in the assigned area of responsibility involving, for example, supply processes, work methods, supply data management, or day- to- day operational procedures.  At this level, employees often use knowledge of interrelated supply processes to coordinate the objectives and plans of two or more specialized supply programs and/or two or more independent organizations receiving local supply support, or to develop and/or implement procedures and practices to cover multiple supply objectives including inventory management of the supply stock fund for expendable and nonexpendable items.  They must evaluate variables such as availability of materials, status of funds for purchases, time required for assembly and delivery, and similar considerations where the employee must make decisions about priorities and allocation of resources. 

Level 1-7 knowledge is also used in supply program planning at a major organizational level.  Employees interpret policy direction for specific operating requirements.  They develop guidance for applying supply policy, procedures, techniques, equipment, and methods to a variety of work situations involving various degrees or levels of supply controls.  This level is used further in responding to problems or questions involving implementation of supply guidelines at lower levels.  Employees at this level are commonly considered the major authoritative source of knowledge for organizations supported by the local supply office, about the overall supply program or one of the technical supply specializations, and for interpreting policy originating from higher organizational levels. 

At Level 1-8, employees use comprehensive knowledge of supply policy requirements to function as technical authorities in applying new theories, concepts, and developments to problems not susceptible to treatment by accepted methods.  In addition to mastery of a specialty area, employees at this level use knowledge of other supply specialties in resolving major conflicts in policy and program objectives.  Employees use this level and kind of knowledge to serve at a variety of operating and staff level positions requiring expertise in a specialty area of supply or as a generalist concerned with supply policy or program responsibilities.  The work is characterized by the depth of analysis involved in resolving problems or issues, and/or the impact on supply support programs that extend beyond local operations.  It is typically found at a major level of the organization, such as a major military command, a major depot with national and/or worldwide support requirements, a regional headquarters with delegated supply support responsibilities, or at a national headquarters level, depending on the level of authority and program responsibility delegated to each.  Examples provided in the standard of assignments that embody these characteristics include the following: 

  • planning for significantly new or far-reaching supply program requirements; or leading or participating as a technical expert in interagency study groups to resolve problems in existing supply systems and programs that require innovative solutions;
  • planning, organizing, and directing studies to develop long-range (i.e., 5-10 years) studies and forecasts;
  • recommending methods for enhancing efficiency of supply systems by adapting existing and/or applying evolving technology;
  • evaluating and making recommendations concerning overall plans and proposals for major agency and interagency supply projects; and
  • developing and implementing national level guidance in agency standards, guidelines, or policies for major supply programs.

The appellant’s position meets Level 1-7.  His work requires significant expertise and specialized knowledge of category management methods and techniques to analyze the effectiveness and efficiency in the specialty department operations of DeCA commissaries.  For instance, he applies depth of knowledge in merchandising and marketing methods and practices developed from extensive experience to make decisions about product assortment, prices, promotions, layout of store merchandise, and product inventory levels to meet customer and sales demands.  Like this level, his work requires analyzing and resolving difficult issues and problems in the assigned area of responsibility involving day-to-day operational procedures.  For instance, when he received information from suppliers that a contractor who serviced 44 stores was not making payments, he analyzed trends (i.e., amount of empty supply cases, loss of sales, customer complaints) to assess contractor performance and informed contracting personnel of contractor non-compliance.  Similar to Level 1-7, when developing category management plans for his assigned commodities, the appellant evaluates variables such as sales data, market share, demographic data, and consumer purchasing behavior in his group of categories to make decisions about priorities and allocation of resources. 

Comparable to Level 1-7, the appellant interprets DoD policy direction for specific operating requirements of DeCA specialty departments and develops guidance for applying merchandising policy, procedures, techniques, and equipment in the areas of ordering, receiving, storing, processing, pricing, and rotating and displaying various products purchased for resale.  In doing so, he responds to problems or questions involving implementation of commissary guidelines at store levels.  Specifically, he has written operating procedures involving activities such as cutting tests to determine shrinkage and waste, and shelf-life and storage guidelines which he provided to zone managers and other store personnel.  Furthermore, like at this level, he often uses knowledge of interrelated merchandising processes (i.e., planning and implementation) to coordinate the objectives and plans of DeCA’s merchandising and marketing programs.  He does this when creating annual merchandising and promotion plans that include specialty department specials and savings offerings which complement overall commissary merchandising plans. 

The appellant’s position does not meet Level 1-8.  The nature of the appellant’s work is not such that it requires him to serve as a technical authority in applying new merchandising or marketing concepts or developments or to resolve major policy or program conflicts.  The appellant does not occupy a staff level position responsible for developing commissary program policies, standards, or guidelines.  Rather, as stated in his PD, "as a subject matter expert, the incumbent assists in providing input to the writing of policy and procedures for proper operations of specialty departments.”  Policy development is the responsibility of the Operations and Policy Directorate.  Instead, the appellant occupies a staff level position overseeing the activities of the specialty departments, which primarily involve contracted deli and bakery operations.  Furthermore, as the category manager for specialty departments, he manages a subset of items by adding and deleting items and making pricing decisions.  He analyzes trends and data to support his decisions, and documents his recommendations in the form of a business needs statement.  Although he is a recognized subject-matter expert within the specialty departments located at the headquarters level, and is delegated authority for category management for specialty departments in commissaries worldwide, in contrast to Level 1-8, we do not find he plans for significantly new or far-reaching commissary management  program requirements.  Rather, his focus is on managing  his category to meet the goals of DeCA’s merchandising and marketing programs.  The appellant’s work is limited to conducting fact-based analyses of market trends by using available automated marketing and demographic data obtained from external data sources (e.g., Nielsen), which do not require either the adaptation of existing or the application of evolving technology to make recommendations on methods for enhancing efficiency.  Instead, he gathers existing industry data to use as benchmarks for measuring savings and to help identify opportunities for future product offerings.

This factor is evaluated at Level 1-7 and 1250 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 2-4, the supervisor sets the overall objectives and decides on the resources available.  The employee consults with the supervisor in determining which projects to initiate, develops deadlines, and identifies staff and other resources required to carry out the assignments.  The employee, having developed expertise in the work, is responsible for planning and carrying out the work, resolving most of the conflicts that arise, integrating and coordinating the work of others as necessary and interpreting policy in terms of established objectives.  The employee keeps the supervisor informed of progress, potential controversies, issues with far-reaching implications, and intractable problems.  Work is reviewed from an overall standpoint in terms of feasibility, compatibility with other supply program requirements, or effectiveness in meeting objectives and achieving expected results.

At Level 2-5, the supervisor provides broad administrative and policy direction through discussion of financial and program goals, and national, agency, and local supply policies affecting the direction of the supply program.  The employee works under broad delegated authority for independently planning, scheduling, coordinating, carrying out, and monitoring the effectiveness of supply operations.  The employee makes extensive unreviewed technical judgments concerning the interpretation and implementation of existing supply policy and is regarded as a leading technical authority in a supply specialization or supply program management.  The supervisor usually accepts the employee’s recommendations without change.  The employee’s actions and recommendations are reviewed primarily for results obtained in achieving supply program goals and in providing to the organization’s mission.  The supervisor evaluates the employee’s recommendations for new or revised supply policies, procedures, and controls in terms of impact on end user programs, broad supply program goals, and/or national supply program priorities.

The appellant’s position meets Level 2-4.  Like this level, the appellant is responsible for planning and carrying out category management plans including resolving most problems, coordinating the work with others, interpreting policy in terms of established objectives, and determining the approach to be taken and the methods and techniques to be employed.  Although the appellant's supervisor does not provide technical guidance to the appellant, he is responsible for determining whether his performance meets defined goals and for accepting or rejecting his work.  This includes determining how well his category plans are supported to meet defined management needs.  Comparable to Level 2-4, the appellant’s completed work is reviewed in terms of effectiveness in meeting objectives and achieving expected results for his assigned categories.  Also, like this level, the appellant keeps the supervisor informed of progress, potential controversies, issues with far-reaching implications, and intractable problems.  For example, the supervisor discussed the implications of a contractor that serviced 44 commissaries defaulting and the deli/bakery departments needing to be operated by DeCA until a new contractor was found.

The appellant does not meet Level 2-5.  This level does not represent merely a greater degree of independence than Level 2-4 but also a greater degree of responsibility and authority exercised, which in turn are directly related to the nature of the work performed.  Level 2-5 is predicated on the exercise of some degree of program management or policy development responsibility, where the employee works under “broad delegated authority” in directing the supply program and revising supply policies.  Unlike Level 2-5, the appellant is not delegated responsibility for major programs; e.g., developing new or substantially revising marketing and merchandising programs, including the allocation of staff and monetary resources.  The appellant does not direct or control a staff or other resources integral to the broad program managed as depicted at Level 2-5.  Instead, within the parameters of the established mission and functions of the Category Management Division and the resources allocated, the appellant has broad latitude for making operational decisions to achieve the expected results within a specialized area, i.e., deli/bakery/seafood departments.  The record indicates the Operations and Policy Directorate is responsible for the development of policy.  Furthermore, officials in higher echelons of the Sales Directorate retain program management authority to manage the sales and merchandising activities associated with the DeCA mission.  Thus, the appellant’s work does not permit exercise of the degree or type of authority depicted at Level 2-5.  

This factor is evaluated at Level 2-4 and 450 points are assigned.

Factor 3, Guidelines

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

At Level 3-4, guidelines consist of broad supply guidance such as directives issued by a national headquarters, general agency policy statements and objectives, or other departmental guides that are open to local interpretation.  The employee exercises a great deal of personal judgment and discretion with broad latitude for interpreting and applying guidelines across the organization, researching and implementing new and improved supply methods and procedures within the organization, and establishing criteria to identify and analyze trends in supply programs. 

At Level 3-5, the employee is a recognized technical authority on the development and interpretation of supply guidelines, policies, legislation, and regulations.  The results of the work cover supply operations in one or more substantive national supply programs.  Guidelines are nonspecific and stated in terms of broad national or departmental policies and goals, often in obscure legal and technical terminology which necessitates extensive interpretation to define the extent and intent of coverage.  For example, at this level employees perform such work as reviewing and commenting on pending legislation; recommending new or revised legislation; and developing supply regulations and policies.

The appellant’s position meets Level 3-4.  Like this level, he works within the parameters of broad commissary management guidance issued by the DeCA headquarters, such as DeCA directives relating to areas of operations, engineering, acquisition, and budget.  The appellant also uses DoD regulations and instructions regarding the DoD Commissary Program and other Federal regulations applicable to commissary operations (e.g., USDA Food Code).  Comparable to Level 3-4, as subject matter expert for specialty departments, most of which are contracted out, he uses experienced judgment and initiative in applying the principles underlying various contracting and procurement guidelines  to evaluate contracting activities regarding contractor compliance and performance assessment.

The appellant’s position does not meet Level 3-5.  The organizational location of the appellant’s position does not allow for the performance of such work as reviewing and recommending new legislation affecting the conduct of DeCA commissary programs. Thus, unlike this level, the appellant is not the authority on the development and interpretation of commissary guidelines, policies, legislation, and regulations.  Such responsibilities rest with the Operations and Policy Group at headquarters. .  Furthermore, although the appellant evaluates the effectiveness and efficiency of contracted services and works closely with contracting staff to ensure contract services are provided, in contrast to Level 3-5, contractual precedents exist to guide the appellant in developing procurement strategies and in assessing the provisions of contracted services.

This factor is evaluated at Level 3-4 and 450 points are assigned.

Factor 4, Complexity                                            

This factor covers the nature, number, variety, and intricacy of the tasks or processes 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 4-5, employees perform assignments involving various projects or evaluations requiring the application of many and different processes, differing regulatory criteria and procedures, and significant departures from established practices.  They make decisions, or develop and implement new methods and techniques that satisfy broad policy and technical requirements.  For example, employees at this level may recommend changes in implementing instructions covering established supply practices and methods. 

At Level 4-6, employees perform work that defines the course of supply programs across organizational lines in Federal agencies and/or industrial organizations involved in supporting supply systems.  They conduct research and develop new approaches and applications in supply theory, technological developments, or controls over Federal supply work.  They analyze, plan, schedule, and coordinate the development of legislative and supply policy issuances.  Assignments typically involve participation, as an expert authority, in group efforts to resolve problems in supply policy development and implementation, such as interagency committees to review, analyze, develop, and issue national policy directives and draft legislation affecting supply policies and programs throughout the Government.

The appellant’s position meets Level 4-5.  Like this level, the appellant’s work involves making decisions that satisfy broad policy and technical requirements when developing strategies and plans to drive category growth to meet program goals.  For example, he makes decisions as to which stores have potential for an increase in product sales after considering the geographic, demographic, and socio-economic variables.  Also, like this level, the appellant makes recommendations for implementing instructions covering established merchandising techniques, practices, and methods.  For example, he was responsible for reviewing the DeCA Directive (DeCAD) 40-28, “Specialty Department Operations,” which implements policies as defined in the Defense Commissary Manual (DeCAM), and provided subject-matter input to officials at the headquarters policy directorate.  Further, as the subject-matter expert for the specialty departments, the appellant uses personal analysis to evaluate current methods and processes, identifies areas that can be improved, and recommends changes in methods and techniques for use in commissary operations for his assigned categories.  For instance, he develops innovative planogram approaches to test new merchandising concepts and develops seasonal programs to match consumer buying patterns and preferences.  

The appellant’s position does not meet Level 4-6.  Although he is the subject-matter expert for specialty departments, the appellant’s involvement is limited to overseeing operating-level activities which does not allow for the performance of the type of policy development work depicted at this level.  Although the appellant participates in discussions relating to making policy updates, the responsibility to analyze, plan, schedule, and coordinate the development of commissary-related legislative and policy issuances is vested in the Operations and Policy Directorate.  

This factor is evaluated at Level 4-5 and 325 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 5-4, work involves investigating and analyzing a variety of unusual supply problems or conditions associated with supply programs or operations, formulating projects or studies to substantially alter existing supply systems, or establishing criteria in an area of specialization.  Employees at this level develop alternatives and options designed to meet requirements in a variety of physical and environmental circumstances.  The work affects supply system design, installation, and maintenance in a wide range of activities.

At Level 5-5, the work involves planning, developing, and carrying out vital supply projects and programs which are central to the mission of the agency, typically having national or international impact.  Work on policy matters often involves establishing the agency’s position on broad issues or working on national level committees to develop supply programs of importance to national programs.  The employee’s work affects the development of major aspects of supply program definition and administration throughout the agency and sometimes in other agencies.  Program and project proposals frequently cut across component or geographic lines within the agency and may also affect the budgets, programs, and interests of other Federal agencies.

The appellant’s position meets Level 5-4.  Like this level, the purpose of the appellant's work often involves dealing with commissary problems or conditions equivalent to supply problems expected to occur in a major receipt and distribution center.  The effect of the work (i.e., the impact of the work product or service) meets the general intent of Level 5-4 to the extent that the Sales Directorate provides specialized supply services affecting all commissary operations worldwide comparable to a “wide range of activities.”  For instance, the appellant recommends approaches to procurement problems or issues that may require analysis due to unusual conditions; e.g., how to recruit and train personnel if a contractor does not fulfill its obligations and the contract is terminated or changing shipping methods (by ship versus plane) when shipping luncheon meats to Europe to lower costs.

The appellant’s position does not meet Level 5-5.  Although the appellant’s proposals and work concerning his categories receive serious consideration and contribute to meeting DeCA’s mission and support to its patrons worldwide, unlike Level 5-5 they do not affect the development of major aspects of commodity  program definition and administration throughout the agency and sometimes in other agencies.  The appellant’s category (specialty food items) is limited in size and scope, and the results of his work (i.e., sales of $215 million) do not significantly affect major aspects of his agency’s commodity program or the methods to be applied by other category mangers in their programs.  For example, even though he is involved in identifying service needs, assessing future requirements within budget constraints, and working with contracting/acquisition staff in planning and coordinating procurement services in commissaries worldwide, this work only affects the specialty departments, but not the agency’s major commodity programs or services. 

This factor is evaluated at Level 5-4 and 225 points are credited.

Factor 6 and 7, Personal Contacts and Purpose of Contacts

These factors relate to the recurring face-to-face and telephone contacts with persons not in the supervisory chain and the purposes of those contacts.  The relationship between Factors 6 and 7 presumes that the same contacts will be evaluated under both factors.

      Persons Contacted

At Level 2, contacts are with other agency employees engaged in different functions or missions and at various organizational levels, and/or with the general public in moderately structured settings; i.e., the exact purpose of the contact or the role and authority of the parties involved may be unclear. 

At Level 3, contacts are with individuals or groups from outside the agency in moderately unstructured settings; i.e., the contacts are not established on a routine basis, the purpose and extent of each contact is different, and the role of each party is identified during the contact.  Typical contacts at this level are with supply managers from other agencies, vendors, or technical level representatives from foreign governments; members of professional organizations, the news media, or public action groups; or the head of the agency or program officials several managerial levels above the employee when such contacts occur on an ad hoc basis.  

The appellant's position meets Level 2.  Like this level, his regular and recurring contacts are with DeCA employees in different program offices (e.g., headquarters contracting and engineering) and at various levels of the organization.  Although the appellant has contact with brokers, manufacturers, and business suppliers, unlike Level 3 these contacts are structured in that they are for predetermined purposes and the role and authority of the parties involved are clear.  Moreover, the record does not indicate that he has frequent contact with industry organizations such as the Coalition of Military Distributors and the Armed Forces Marketing Council whose representatives include industry executives.  Therefore, we may not consider this group as being part of his regular and recurring contacts.

      Purpose of Contacts

At Level b, contacts are for the purpose of planning, coordinating work, and resolving operating problems by influencing or motivating individuals or groups who are working toward mutual goals and have basically cooperative attitudes.

At Level c, contacts are for the purpose of influencing or motivating persons or groups where the persons contacted may be uncooperative; e.g., such as when attempting to gain compliance with established policies and regulations by persuasion or negotiation. 

The purpose of the appellant's contacts are consistent with Level b; i.e., planning, coordinating, and resolving problems equivalent to those encountered in operating-level supply activities where the parties involved are working toward the same objectives.  Further, he is not in a compliance or regulatory function that would require the types of persuasion or negotiation depicted at Level c.   

Level 2b is assigned and 75 points are credited.

Factor 8, Physical Demands

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

At Level 8-1, work is sedentary and is usually accomplished while the employee is comfortably seated at a desk or table.  Some walking and standing may occur in the course of a normal workday in connection with attendance at meetings and conferences, or while researching files.  Items carried typically are light objects such as briefcases, notebooks, and data processing reports.  Lifting of moderately heavy objects is not normally required.  No special physical effort is required to perform the work. 

At Level 8-2, work requires regular and recurring physical exertion, such as long periods of standing, walking, bending, stopping, reaching, and similar activities in and around storage areas.

The appellant’s position meets Level 8-1.  Like this level, his work is sedentary.  No special physical demands are necessary to perform his duties.

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

Factor 9, Work Environment

This factor considers the risks and discomforts in the employee's physical surroundings or the nature of the work assigned and the safety regulations required

At Level 9-1, the work is primarily performed in an office-like setting involving everyday risks or discomforts which require normal safety precautions typical of such places as offices, meeting and training rooms, libraries, residences, and private and commercial vehicles. The work is adequately lighted, heated and ventilated.

At Level 9-2, the work is performed in a setting which there is regular and recurring exposure to moderate discomforts and unpleasantness such as high levels of noise in vendor plants, high temperatures in warehouses, or adverse weather conditions at open storage sites.  The employee may be required to use protective clothing or gear such as protective helmets, masks, gowns, coats, boots, goggles, gloves, or shields.  Similarly, employees may be required to follow special precautions when working around storage area containing explosives, corrosives, or highly combustible materials.

The appellant’s position meets Level 9-1.  Like this level, he works in an office environment involving every day risks or discomforts requiring normal safety precautions such as safely using office equipment, avoiding trips or falls, and observing fire regulations.  

This factor is evaluated at Level 9-1 and 5 points are credited.


Factor Level Points
1.  Knowledge Required by the Position 1-7 1250
2.  Supervisory Controls 2-4   450
3.  Guidelines 3-4   450
4.  Complextiy 4-5   325
5.  Scope and Effect 5-4   225
6. & 7. Personal Contacts and Purpose of Contacts 2b     75
8.  Physical Demands 8-1       5
9.  Work Environment 9-1       5
     Total 2785

The total of 2785 points falls within the GS-12 point range (2755-3150) on the grade conversion table provided in the guide.  Therefore, the appellant’s position is properly graded at the GS-12 level.


The position is properly classified as Commissary Management Specialist, GS-1144-12.

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