The appellants' position was classified as GS-647-5. The PD of record stated that the appellants performed both routine and complex radiographic procedures under general supervision. As part of their appeal rationale, the appellants submitted a proposed PD generated by an automated position classification system. Both the PD of record and the automated system PD credited Level 1-4. However, for Factor 2, the automated system PD credited Level 2-3, one level higher than credited in the PD of record. This resulted in the automated system PD classifying the position one grade higher than the PD of record. The automated system PD stated that the appellants worked with greater independence on the complex procedures than described in the PD of record but did not identify the amount of work time spent on complex procedures.

The GS-647 standard requires evaluating positions, to the extent possible, by using the benchmarks in the standard. The benchmarks link Level 2-3 to work situations where technical guidance and oversight is limited, e.g., functioning as the technologist in charge of an outpatient section, or where the employee performs more complex procedures independently. This requires considering the degree of supervision within the context of the complexity, difficulty, and knowledge required to perform medical procedures. Conducting simpler procedures does not provide the opportunity to exercise the same degree of technical judgment as more complex procedures under equivalent independence.

OPM found that the appellants performed the complex procedures substantially less than 25 percent of their work time. When they did perform the complex procedures, their work was closely monitored and higher-graded employees did the most invasive aspects. Thus, OPM found that Level 2-3 was not consistent with the nature of the appellants' work. In addition, Factor 4 in the automated system PD was inconsistent with Factors 1 and 2 since it described performing a variety of examinations of limited difficulty. Therefore, OPM concluded that the automated system PD could not be considered in evaluating the appealed position. Level 2-2 was credited.

An OPM appeal decision classifies a real operating position, and not simply a position description. When PD accuracy issues are unresolved, OPM decides classification appeals on the basis of the actual duties and responsibilities assigned by management and performed by the employee. Information in a proposed PD is considered only to the extent that it is relevant in comparing the appellant's work with OPM standards.

Automated system PD's are not equivalent to benchmark PD's, which are found in some Factor Evaluation System (FES) standards. They are similar in that they can be used to classify a position if the position is a direct match to the PD. The difference is that benchmark PD's, in contrast to automated system PD's, are validated when the classification standard is developed. Therefore, automated system PD's may require further evaluation before use. Even though, in this case example, the PD of record contained the same wording as Level 2-3 in the standard, that wording was used out of context and conflicted with other factors. The erroneous information in the automated system PD could not be used to classify the appealed position since the automated system PD described duties and responsibilities not actually performed by the appellants.