U.S. Office of Personnel Management Office of Merit Systems Oversight and Effectiveness Classification Appeals and FLSA Programs Dallas Oversight Division 1100 Commerce Street, Room 4C22 Dallas, TX 75242-1027 Classification Appeal Decision Under section 5112 of title 5, United States Code Appellant: [appellant] Agency classification: Prosthetic Representative GS-672-12 Organization: [installation] Department of Veterans Affairs [city, state] OPM decision: GS-672-12 Title at agency discretion (title to denote supervisory responsibilities) OPM decision number: C-0672-12-01 /s/ _____________________________ Bonnie J. Brandon Classification Appeals Officer September 13, 2002 _____________________________ Date As provided in section 511.612 of title 5, Code of Federal Regulations, 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, appendix 4, section G (address provided in appendix 4, section H). Since this decision changes the classification (i.e., the title) of the appealed position, it is to be effective no later than the beginning of the fourth pay period after the date of this decision, as permitted by 5 CFR 511.702. The appellant’s 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. Decision sent to: [appellant’s name and address] Human Resources Manager [installation] Department of Veterans Affairs [installation’s address] Chief, Compensation and Classification Division (051) Human Resources Management Department of Veterans Affairs 810 Vermont Avenue, NW. Washington, DC 20420 Deputy Assistant Secretary for Human Resources Management (05) Department of Veterans Affairs 810 Vermont Avenue, NW., Room 206 Washington, DC 20420 Introduction On May 14, 2002, the Dallas Oversight Division of the U. S. Office of Personnel Management (OPM) accepted a classification appeal from [appellant]. We received his agency’s administrative report on July 18, 2002. The appellant’s position is currently classified as Prosthetic Representative, GS-672-12. The appellant requests that his position be classified as Prosthetic Representative, GS-672-13, or Program Analyst, GS-340-13. We have accepted and decided the appeal under section 5112 of title 5, United States Code (U.S.C.). Before appealing to OPM, the appellant appealed the classification of his position to the Department of Veterans Affairs (DVA). The DVA found the appellant’s position to be classified as Prosthetic Representative, GS-672-12. The appellant requested the DVA forward the appeal to OPM for further consideration. We conducted a telephone interview with the appellant on August 5, 2002. We also conducted a telephone interview with the appellant’s supervisor on August 7, 2002. In deciding this appeal, we fully considered the interview findings and all information provided by the appellant and his agency, including his current work assignments and position description of record. The appellant is assigned to position description number [number]. The appellant and his supervisor have certified the accuracy of the position description. We find the position description is accurate, with one exception. The position description does not address the appellant’s regular and recurring responsibilities for supervising three employees. These responsibilities require a substantial amount of the appellant’s time and impose knowledge requirements that should be addressed in his position description. Accordingly, the agency is to revise the appellant’s position description to reflect this information and provide this office with a copy along with its compliance report. General issues The DVA used a classification guide developed internally to classify the appellant’s position because there is no published OPM classification standard covering the GS-672 Prosthetic Representative Series. The appellant believes that DVA’s classification of his position is flawed in that it is based solely on the agency’s internal classification guide, which is outdated and does not take into consideration the administrative and other program responsibilities of his position. By law, we must make our classification decision solely by comparing the appellant’s current duties and responsibilities to OPM standards and guidelines (5 U.S.C. 5106, 5107, and 5112). Position information The appellant works in Patient Administration Services at the VA [organizational location]. The appellant is responsible for administering the prosthetics and sensory aid program, the home oxygen program, and the audiology program for the medical center, nine outpatient clinics, and a nursing home care unit within the State of [state]. The appellant’s program administration responsibilities also extend to include Veterans Integrated Service Network (VISN) [number] and, to lesser degrees, VISN’s [two numbers]. The appellant is responsible for planning and operating the prosthetics and sensory aids program. This includes developing and achieving program goals, managing an annual budget, interpreting policy and instructions and issuing local implementing guidance, and maintaining management systems to ensure timely delivery of services. The appellant makes all decisions regarding entitlement to and the method for furnishing prosthetics; advises veterans, their families, physicians, nurses, and therapists about prosthetic needs and issues; serves as the Contracting Officer’s Technical Representative (COTR) for prosthetic contracts; represents the medical center in contractual relationships and with committees involving the program; visits contractors to verify they meet Joint Commission on Accreditation of Healthcare Organizations (JCAHO) standards; administers the clothing allowance and auto adaptive equipment programs; inspects appliances to ensure specifications are met; and maintains inventory control of all equipment at the medical center and the out-based clinics. The appellant administers the VA [state] home oxygen program and serves as the COTR for the VISN [number] home oxygen program. The appellant advises and assists VISN’s [two numbers] in contractual arrangements for their oxygen programs. The appellant works with the VISN medical centers to develop procedures and resolve problems. The appellant visits patients’ homes within VISN [number] to ensure the equipment is being used correctly and safely and inspects contractor facilities to verify they meet JCAHO standards. The appellant states this program has grown substantially and now occupies about half of his time. The appellant administers the audiology program, which involves contracting with private audiologists throughout the state to provide services to veterans near their homes. The appellant serves as COTR for this program as well. The appellant supervises three purchasing agents who provide support to the appellant in receiving and analyzing prescriptions, ordering appliances and services, responding to questions, resolving problems, and monitoring the budget and expenditures. The appellant states he probably spends close to 25 percent of his time supervising the purchasing agents. Series and title determination The appellant’s position consists of a variety of work covered in the GS-600 Medical, Hospital, Dental, and Public Health Group. There are a number of factors to consider in determining the proper series for such a position. These include the paramount knowledge requirement, the reason for the position’s existence, the organizational function, line of promotion, and the recruitment source. Both the appellant and his supervisor agree that the primary purpose and the reason for the position’s existence are to administer the prosthetics and sensory aids program. The appellant’s supervisor stated that he would recruit for someone with knowledge in the prosthetics and sensory aid field if he had to fill the position again in the future. Since knowledge of regulations, procedures, and practices concerning a prosthetics program constitutes the primary knowledge requirement of the appealed position, we find that it is properly classified in the GS-672 Prosthetic Representative Series. There is no OPM published standard for the GS-672 series. Consequently, the title of the appealed position is at the agency’s discretion. However, the title constructed by the agency should denote the appellant’s supervisory responsibilities. Guide determination Because there are no directly applicable grade level criteria to use for positions in the GS-672 series, we examined other classification standards that could be used for comparison. In doing so, we considered the kind of work involved, the knowledge required to do the work, the level of difficulty and responsibility, and the classification factors that would have the greatest influence on the grade level. We examined a variety of classification standards in the GS-600 Medical, Hospital, Dental, and Public Health Group and found none that appropriately address the appellant’s responsibilities in terms of the above criteria. We have determined the most appropriate standard for assessing the appellant’s program administration responsibilities is the Administrative Analysis Grade Evaluation Guide (AAGEG). The appellant’s responsibilities are to a large extent administrative in nature, requiring knowledge of management principles to resolve procedural or factual problems. Although the AAGEG excludes positions performing line management or delivery of agency programs requiring specialized subject matter knowledge, it does provide guidance for positions that perform work in analyzing, planning, and evaluating work concerned with the administrative and operational aspects of agency programs. The General Schedule Supervisory Guide (GSSG) is used to evaluate the appellant’s supervisory responsibilities. Grade determination Evaluation using the AAGEG The AAGEG is written in the Factor Evaluation System (FES) format. Under the FES, positions are placed in grades on the basis of their duties, responsibilities, and the qualifications required as evaluated in terms of nine factors common to nonsupervisory General Schedule positions. A point value is assigned to each factor based on a comparison of the position’s duties with the factor-level descriptions in the AAGEG. The factor point values mark the lower end of the ranges for the factor levels. For a factor to warrant a given point value, it must be fully equivalent to the overall intent of the selected factor-level description. If the position fails in any significant aspect to meet a particular factor-level description, the point value for the next lower factor level must be assigned. The total points are converted to a grade by use of the grade conversion table in the AAGEG. Our evaluation with respect to the nine FES factors follows. Factor 1, Knowledge required by the position As described in the AAGEG, assignments at Level 1-7 require knowledge and skill in applying analytical and evaluative methods and techniques to issues or studies concerning the efficiency and effectiveness of program operations carried out by administrative or professional personnel. This level includes knowledge of pertinent laws, regulations, policies, and precedents which affect the program and related support resources, such as people, money, or equipment. The work at this level also requires knowledge of major issues, program goals and objectives, work processes, and administrative operations of the organization. The knowledge required at Level 1-7 is used to plan, schedule, and conduct studies to evaluate and recommend ways to improve the effectiveness and efficiency of work operations in a program or support setting. The assignments require knowledge and skill in adapting analytical techniques and evaluation criteria to the measurement and improvement of program effectiveness. Knowledge is applied in developing new or modified work methods, management processes, procedures for administering program services, guidelines and procedures, and automating work processes. An illustration of assignments at this level involves performing a wide variety of studies and projects related to management improvement, productivity improvement, and long-range planning requiring knowledge of service or bureau benefit programs, operations, objectives, and policies. Level 1-7 is met. The appellant’s program administration responsibilities require knowledge of DVA policies, regulations, and business procedures, as well as agency goals and objectives. The appellant develops long-range program goals, collects quantitative and qualitative data through a variety of methods, and monitors outcomes to identify problems and promote program improvements. The appellant makes all decisions regarding the programs in terms of patient entitlements, policy issues, and how resources are to be used in support of the programs. The appellant develops local implementing guidance based on applicable laws and regulations. The appellant serves as an advisor and point of contact for three VISN’s in developing procedures for administering the home oxygen program. The appellant develops and implements management systems to ensure timely delivery of services and compliance with regulations. The appellant represents the medical center in business relationships, resolves contract and procurement problems with a variety of vendors, and ensures the programs are administered in accordance with JCAHO standards and agency requirements. Level 1-8 is not met. The employee at this level operates as an expert analyst who has mastered the application of a wide range of methods used for the assessment and improvement of complex management processes and systems. This level requires comprehensive knowledge of the range of administrative laws, policies, regulations, and precedents that apply to one or more important public programs. This typically includes knowledge of agency program goals and objectives, the sequence and timing of key program events and milestones, and methods of evaluating the worth of program accomplishments. This knowledge is used to design and conduct comprehensive studies where the boundaries are extremely broad and difficult to determine in advance. Previous studies and established management techniques are frequently inadequate. An illustration of work at this level is developing standards covering complex program functions such as agency research operations. The appellant must be knowledgeable of his program goals and how they integrate with medical center goals, but his responsibilities are not so broad as to require knowledge of DVA goals and timing of key agency program events. In addition, his program administration responsibilities do not involve the vague parameters depicted at Level 1-8. Level 1-7 is credited for 1250 points. Factor 2, Supervisory controls The employee at Level 2-4 works within a framework of priorities, funding, and overall project objectives. The employee and supervisor mutually develop a project plan that includes identifying the work to be done, the scope of the project, and deadlines for completion. The employee at this level is responsible for planning and organizing the work and conducting all phases of the project, including the interpretation of regulations, procedures, and application of new methods. The employee informs the supervisor of potentially controversial findings, issues, or problems with widespread impact. Completed assignments are reviewed by the supervisor for compatibility within organizational goals, guidelines, and effectiveness in achieving intended objectives. Level 2-4 is met. The appellant reports to the Chief of Staff and independently administers his programs within assigned resources. The appellant has broad authority to interpret and apply policy and develop short- and long-range goals and objectives. The appellant keeps the supervisor informed of controversial issues as they arise. The appellant’s supervisor reviews his work in terms of overall effectiveness and for quality assurance. Level 2-5 is not met. This level reflects administrative supervision only, with full authority delegated to the employee to carry out major projects in terms of broadly defined missions or functions. This level of authority is typically accompanied by responsibility for a significant program or function. Management officials review recommendations developed by the employee only for potential influence on broad agency policy objectives and program goals. While the appellant operates with a high degree of independence, he is not operating under the broad policy direction depicted at Level 2-5. In addition, the appellant’s decisions directly influence program activities at the medical center and VISN’s in a multistate area. This level of responsibility is more limited than the agency program implications described at Level 2-5. Level 2-4 is credited for 450 points. Factor 3, Guidelines Guidelines at Level 3-4 consist of general administrative policies and management theories that require considerable adaptation or interpretation. At this level, administrative policies and precedents provide a basic outline of the results desired, but do not go into detail as to the methods used to accomplish assignments. Within the context of broad regulatory guidelines, the employee may refine or develop more specific guidelines, such as implementing regulations or methods for the measurement and improvement of effectiveness and productivity in the administration of operating programs. Level 3-4 is met. The appellant uses a variety of guidelines that provide a general outline of the concepts and methods to be used and the goals to be achieved. The guidelines are intentionally general in order to reach decisions on patients’ eligibility and specific medical needs. The appellant uses considerable judgment and initiative to interpret the guidelines and adapt them to achieve desired results. The appellant develops local policy and guidelines for the medical center and VISN’s related to the programs under his responsibility. Level 3-5 is not met. Guidelines at this level consist of basic administrative policy statements and may include reference to pertinent legislative history, related court decisions, state and local laws, or policy initiatives of agency management. The employee uses judgment and discretion in determining intent and in revising existing policy and regulatory guidance for use by others. The AAGEG provides an example of employees who review proposed legislation or regulations that would significantly change the basic character of agency programs or the way the agency conducts its business with the public, or would modify important inter-agency relationships. The appellant does not develop policy or propose legislation or regulations that would significantly change DVA programs. The appellant does not have to routinely interpret the intent of vague or broad policy statements as required for crediting Level 3-5. Level 3-4 is credited for 450 points. Factor 4, Complexity The work at Level 4-4 involves gathering information, identifying and analyzing issues, and developing recommendations to resolve problems of effectiveness and efficiency of work operations in a program or program support setting. Work at this level requires the application of qualitative and quantitative analytical techniques that frequently require modification to fit a wider range of variables. Projects at this level usually consist of issues that are not always susceptible to direct observation and analysis. Difficulty is encountered in measuring effectiveness and productivity due to variations in the nature of administrative processes studied. Information about the subject is often conflicting or incomplete. An example is given as analyzing and developing new methods to improve systems for disseminating information about programs to many organizational echelons or geographic locations. The employee at this level must consider the needs and interests of a wide variety of user requirements. Level 4-4 is met. The appellant has administrative responsibility for three program segments, each one consisting of distinct processes and requirements. The appellant evaluates alternatives to standard methods of operation to determine better and more economical processes. Assignments are complicated by the need to interpret guidelines that provide very general instructions, to use value judgments to determine eligibility and entitlements, to select the right equipment for patients with varying needs, and to reach common goals involving a variety of medical facilities in a large geographic area. The appellant’s work requires a high degree of coordination to administer the programs, to include developing and monitoring their budgets, enforcing vendor contracts, visiting vendor facilities and patients’ homes, advising patients and staff members on the various types of appliances, and serving on various committees. Level 4-5 is not met. At this level, the work involves projects that require analysis of interrelated issues of effectiveness, efficiency, and productivity of substantive mission-oriented programs. Assignments require developing detailed plans, goals, and objectives for the long-range implementation and administration of the program or developing criteria for evaluating the effectiveness of the program. Decisions are complicated by conflicting program goals and objectives resulting from variations in demand for program services. Assignments are further complicated by the need to use value judgments and the need to deal with subjective concepts. The employee at this level must consider uncertainties about the data and other variables which affect long-range program performance. The appellant’s assignments are not as broad as to encompass interrelated, substantive mission-oriented programs (e.g., a nationwide medical care program), but rather involve distinctive program segments (prosthetics, home oxygen, and audiology) at the operating level. Level 4-4 fully captures the complexities inherent in the appellant’s assignments in terms of geographic scope and the voluminous details for which he is responsible. Level 4-4 is assigned for 225 points. Factor 5, Scope and effect The purpose of work at Level 5-4 is to assess the effectiveness and efficiency of program operations or administrative support activities. The work involves establishing criteria to measure organizational goals and objectives. Work at this level may also include developing related guidance for application across organizational lines or in varied geographic locations. Work that involves the evaluation of program effectiveness usually focuses on the delivery of program benefits or services at the operating level. The work contributes to the improvement of program operations or administrative support activities at different echelons or geographical locations within the organization. Level 5-4 is met. The purpose of the appellant’s work is to administer the prosthetics and sensory aids, home oxygen, and audiology programs at the medical center and facilities within the VISN. The work involves establishing goals and developing procedures and guidance for the facilities covering a large geographic area. The appellant’s work affects the efficiency and effectiveness of the programs and the services provided to the veteran population. Level 5-5 is not met. The purpose of work at this level is to analyze major administrative aspects of substantive, mission-oriented programs. This involves the development of long-range program plans or evaluating the effectiveness of programs throughout a bureau or service of an independent agency, a regional structure of equivalent scope, or a large complex multimission field activity. At this level, study findings are typically of major significance to top agency management and often serve as the basis for new administrative systems, legislation, regulations, or programs. An illustration of work at this level is that of a project officer evaluating the effectiveness and efficiency of major program operations throughout an agency. The scope of the appellant’s work is not of the magnitude envisioned at Level 5-5 in that his work involves programs at the operating level of his agency. In addition, his work does not have the agency-level impact as intended to credit Level 5-5. Level 5-4 is credited for 225 points. Factors 6 and 7, Personal contacts and Purpose of contacts These two factors are evaluated separately but combined for the purpose of arriving at a total point value. Personal contacts Contacts at Level 3 typically occur in an unstructured setting and include consultants, contractors, or business executives. This level may also include ad hoc contacts with the head of the employing agency or program officials several managerial levels removed from the employee. Level 3 is met. The appellant’s personal contacts are with veterans, physicians, nurses, therapists, higher management officials, Congressional staffers, commercial companies, vendors, and contractors. Level 4 is not met. Contacts at this level are high-ranking officials such as other agency heads, top congressional staff officials, state executive or legislative leaders, mayors of major cities, or executives of comparable private sector organizations. Purpose of contacts The purpose of contacts at Level c is to influence officials to accept and implement findings and recommendations on program effectiveness. The employee at this level may encounter resistance due to competing objectives or resource problems. Level c is met. The purpose of the appellant’s contacts is to obtain and furnish information, provide recommendations on program effectiveness, provide services to patients, and coordinate program activities with other medical facilities. The appellant may encounter difficulty because of competing goals at the medical facilities and resistance by patients to accept the appellant’s recommendations regarding entitlements and equipment. Level d is not met. Contacts at this level are for the purpose of justifying or settling significant or controversial issues. Recommendations at this level affect major programs dealing with substantial expenditures. The appellant’s contacts do not impose this level of conflict or involve major programs of the scope intended to credit this level. Both factors are credited at Level 3c for a combined total of 180 points. Factor 8, Physical demands At Level 8-2, assignments regularly involve long periods of standing, bending, and stooping to observe and study work operations in an industrial, storage, or comparable work area. Level 8-2 is met. The appellant’s work imposes physical demands on a regular and recurring basis during home and office visits. This includes bending and lifting, packing/unpacking, assembling, and repairing medical equipment, such as prosthetics and oxygen tanks. The appellant also deals with patients who may have emotional problems and become threatening. The appellant has taken a self-defense training course to prepare for such situations. Level 8-2 is credited for 20 points. Factor 9, Work environment Assignments at Level 9-2 regularly require visits to manufacturing, storage, or other industrial areas, and involve moderate risks of discomforts. Protective clothing and gear and observance of safety precautions are required. Level 9-2 is met. The appellant routinely makes home visits to ensure that equipment is working properly and safety precautions are being followed. This requires use of gloves and gowns to prevent infection. The appellant also inspects vendor facilities during which he is exposed to mechanical equipment and chemicals. The appellant wears protective clothing in the medical center when working with the various types of equipment. Level 9-2 is credited for 20 points. Summary Factor Level Points 1. Knowledge required by the position 1-7 1250 2. Supervisory controls 2-4 450 3. Guidelines 3-4 450 4. Complexity 4-4 225 5. Scope and effect 5-4 225 6. Personal contacts and 7. Purpose of contacts 3c 180 8. Physical demands 8-2 20 9. Work environment 9-2 20 Total 2820 A total of 2820 points falls within the range for GS-12 (2755 to 3150 points), according to the grade conversion table in the AAGEG. The appellant’s program administration duties are properly graded at the GS-12 level. Evaluation using the GSSG The GSSG is intended to measure the difficulty, complexity, and responsibility of work involved in the administrative and technical direction of others. The GSSG uses a factor-point evaluation method that assesses six factors common to all supervisory positions. The appellant’s position is evaluated as follows. Factor 1, Program scope and effect To credit a particular level under this factor, the criteria for both scope and effect must be met. a. Scope At Level 1-3, the supervisor directs a program segment that performs technical, administrative, protective, investigative, or professional work. The program segment and work directed typically have coverage that encompasses a major metropolitan area, a state, or a small region of several states. An example is providing services to a moderate-sized population of clients in several rural counties, a small city, or a portion of a larger metropolitan area that could cover several states. At Level 1-4, the supervisor directs a segment of a professional, highly technical, or complex administrative program that involves the development of major aspects of key agency scientific, medical, legal, administrative, regulatory, policy development, or comparable highly-technical programs. Level 1-3 is met. The appellant and the three purchasing agents he supervises perform administrative and technical work. Workload data provided in the case file indicate that the appellant and his staff saw 27,864 patients and processed 21,336 orders during Fiscal Year 2001. They provide services to veterans in the State of [state] and to several other states in VISN [number]. Level 1-4 is not met in that the appellant does not direct work of a professional, highly technical, or complex administrative nature. b. Effect At Level 1-2, the services or products support and significantly affect installation level, area office level, or field office operations and objectives; or provide services to a moderate, local, or limited population of clients or users comparable to a major portion of a small city or rural county. At Level 1-3, the activities directly and significantly affect a wide range of agency activities, the work of other agencies, the operations of outside interests, or the general public. At the field activity level (i.e., large, complex, multimission organizations or very large serviced populations), the work directly involves or substantially affects the provision of essential support operations to numerous, varied, and complex technical, professional, and administrative functions. Level 1-2 is met. While the geographic area serviced by the appellant and his staff exceeds Level 1-2 to some extent, the services affect a moderate-sized population of veterans and do not involve numerous, varied, and complex technical, professional, and administrative functions as intended for field activities at Level 1-3. Because Level 1-3 is assigned to Scope and Level 1-2 to Effect, Level 1-2 must be credited for this factor for 350 points. Factor 2, Organizational setting This factor considers the organizational situation of the supervisory position in relation to higher levels of management. As at Level 2-2, the appellant reports to the Chief of Staff, who is one reporting level below the first Senior Executive Service level. Level 2-2 is credited for 250 points. Factor 3, Supervisory and managerial authority exercised Level 3-2 describes three situations, only one of which must be met for this level to be credited. Situation c lists 10 supervisory authorities and responsibilities. At least three of the first four and a total of six out of the ten responsibilities must be performed before crediting this level. The appellant meets all ten of the responsibilities as follows. * Plans work to be accomplished by subordinates, sets and adjusts short-term priorities, and prepares schedules for completion of work. * Assigns work to subordinates based on priorities, selective consideration of the difficulty and requirements of assignments, and the capabilities of employees. * Evaluates work performance of subordinates. * Gives advice, counsel, or instruction to employees on both work and administrative matters. * Interviews candidates for positions in the unit; recommends appointment, promotion, or reassignment to such positions. * Hears and resolves complaints from employees, referring group grievances and more serious unresolved complaints to a higher supervisor or manager. * Effects minor disciplinary measures, recommending other action in more serious cases; * Identifies, provides, and arranges for needed development and training. * Finds ways to improve production or increase the quality of the work directed. * Develops performance standards. Level 3-3 describes two situations, one of which must be met to be credited. In situation a, the position exercises delegated managerial authority to set a series of annual, multiyear, or similar long-range work plans and schedules for in-service or contracted work; assures implementation by subordinate organizational units of program goals and objectives; determines which goals and objectives need additional emphasis; determines the best solution to budget shortages; and plans for long-range staffing needs. Positions in this situation are closely involved with high-level program officials or comparable agency staff personnel in developing overall goals and objectives for assigned programs. For example, they direct development of data; provision of expertise and insights; securing of legal opinions; preparation of position papers or legislative proposals; and execution of comparable activities which support development of goals and objectives related to high levels of program management and development or formulation. The appellant does not meet situation 3-3a which requires participation in program management, development, and formulation with high-level program officials (e.g., at an agency headquarters level). In addition, the appellant does not have subordinate organizational units for which he is responsible. Situation b involves the exercise of a range of supervisory authorities and responsibilities that exceed those normally exercised by a first-line supervisor. The supervisor at this level must exercise all or nearly all of the supervisory responsibilities described at Level 3-2c, as well as at least 8 of the 15 responsibilities described in situation b. The appellant meets five of the responsibilities as follows. * Responsibility 1 is not met since the appellant does not use supervisors or leaders to direct, coordinate, or oversee the work. * Responsibility 2 is met. The appellant works with officials in other units and advises management officials of higher rank at the medical center about the programs under his responsibility. * Responsibility 3 is not met. The appellant does not assure reasonable equity among units, groups, or teams of performance standards and rating techniques developed by subordinates due to the small size of his subordinate staff. * Responsibility 4 is met. The appellant directs program segments with significant resources. The prosthetics and sensory aid program involves $4.5 million in resources, and, according to the appellant, the home oxygen program approximately $2.1 million. The appellant has authority to approve all expenditures for his programs within assigned budget allocations. * Responsibility 5 is not met since the appellant does not make decisions on work problems presented by subordinate supervisors or team leaders. * Responsibility 6 is not met since the appellant does not evaluate subordinate supervisors or leaders. * Responsibility 7 is met since the appellant has approval authority to select subordinate nonsupervisory positions. * Responsibility 8 is not met since the appellant does not recommend selections for subordinate supervisory positions. * Responsibility 9 is not met since the appellant does not hear and resolve group grievances of serious employee complaints. Complaints of this nature would be resolved at a higher level. * Responsibility 10 is not met since serious disciplinary actions are reviewed and approved by the appellant’s supervisor. * Responsibility 11 is not met since training requests are approved by either the appellant’s supervisor or a training committee. * Responsibility 12 is not met since the appellant does not determine whether contractor-performed work meets standards of adequacy necessary for authorization of payment. This responsibility is intended to credit a supervisor who regularly oversees the work of contract employees in a manner similar to the way in which a supervisor directs the work of subordinate employees. The appellant does not oversee the work of contractor employees in a manner similar to his subordinate employees. * Responsibility 13 is not met since employee travel and extensive overtime requires approval by a higher-level official. * Responsibility 14 is met since the appellant recommends awards and changes in position classification, subject to approval by higher level officials. * Responsibility 15 is met since the appellant identifies and implements ways to eliminate or reduce significant bottlenecks and barriers to production or improve business practices. Level 3-3b is not met since the appellant’s position is not credited with at least 8 of the 15 responsibilities. Level 3-2c is credited for 450 points. Factor 4, Personal contacts This is a two-part factor that assesses the nature and the purpose of personal contacts related to supervisory and managerial responsibilities. The same contacts that serve as the basis for the level credited under Subfactor 4A must be used to determine the correct level under Subfactor 4B. Subfactor 4A, Nature of contacts At Level 4A-2, frequent contacts are with members of the business community or the general public; higher-ranking managers, supervisors, and staff of other units throughout the activity or at levels below bureau or major military command level; representatives of local public interest groups, case workers in Congressional district offices; technical or operating personnel in State and local governments; reporters for local or other limited media outlets; or comparable contacts. These contacts may be informal, occur in conferences and meetings, or take place through telephone, televised, radio, or similar contact, and sometimes require nonroutine or special preparation. At Level 4A-3, recurring contacts are with high-ranking military or civilian managers at bureau and major organizational levels within the agency, with agency administrative personnel, or with comparable personnel in other agencies; key staff of public interest groups with significant political influence or media coverage; journalists representing influential city or county news media; Congressional committee and subcommittee staff assistants; contracting officials and high-level technical staff of large industrial firms; or local officers of regional or national trade associations, public action groups or professional organizations; or with State and local government managers. These contacts take place in meetings and conferences and often require extensive preparation. The appellant’s contacts meet Level 4A-2. The appellant routinely meets with veterans, physicians, nurses, therapists, staff of other medical center units, the Chief of Staff and Medical Center Director, Congressional staffers, commercial companies, vendors, and contractors. The appellant does not routinely meet with higher-ranking managers within DVA or with the high-level personnel and groups as described at Level 4A-3. In addition, the appellant’s contacts do not normally require the high degree of preparation as described at Level 4A-3. This subfactor is credited with Level 4A-2 for 50 points. Subfactor 4B, Purpose of contacts The purpose of contacts at Level 4B-2 is to provide accurate and consistent information to outside parties; to plan and coordinate the work directed with that of others outside the organization; or to resolve differences of opinion among managers, supervisors, employees, contractors or others. Contacts at Level 4B-3 are to justify, defend, or negotiate in representing the program segment or organizational unit directed in obtaining or committing resources and in gaining compliance with established policies, regulations, or contracts. Contacts at this level usually involve active participation in conferences, meetings, hearings, or presentations involving problems or issues of considerable importance to the program segment managed. The purpose of the appellant’s contacts meets Level 4B-2. The appellant’s contacts are primarily for the purpose of exchanging information, coordinating program activities, advising on program services, and resolving problems. While the appellant represents the medical center with respect to his assigned programs, there is no indication that these contacts regularly require the degree of defending or negotiating as intended at Level 4B-3. Level 4B-2 is assigned for 75 points. Factor 5, Difficulty of typical work directed This factor measures the difficulty and complexity of the basic work most typical of the organization directed. For first-level supervisors, this means the highest grade that best characterizes the nature of the basic nonsupervisory work performed and that constitutes 25 percent or more of the workload. The appellant supervises three employees: one GS-1105-6 Purchasing Agent and two GS-1105-5 Purchasing Agents. Based on our review of the subordinate employees’ position descriptions, we find that GS-6 is the base level of the work directed by the appellant that meets the above criteria. By reference to the chart in the GSSG, Level 5-3 is credited if the highest level of base work is GS-6. Level 5-3 is credited for 340 points. Factor 6, Other conditions This factor measures the extent to which various conditions contribute to the difficulty and complexity of carrying out supervisory duties, authorities, and responsibilities. Two steps are used to evaluate Factor 6. First, the highest level that a position substantially meets is initially credited. If the level selected is 6-1, 6-2, or 6-3, the Special Situations section is to be used to determine if three or more of the eight situations are met. If at least three situations are met, another level may be added. Level 6-2 applies when the work supervised involves technician or support work comparable in difficulty to GS-7 or GS-8, or work at the GS-4, 5, or 6 levels where the supervisor has full and technical authority over the work, and the work requires coordination and integration of work efforts in order to produce a completed product or service. Full and final technical authority means that the supervisor makes all technical determinations without advice or assistance. Level 6-3 involves supervision of administrative, technical, or complex technician or other support work comparable to GS-9 or 10, or work at the GS-7 or 8 levels where the supervisor has full and final technical authority over the work. Level 6-2 is assigned since GS-6 is the highest level of work supervised by the appellant. The appellant has full and final technical authority over the work involving his programs. Although he keeps his supervisor informed of controversial issues, he makes all technical decisions on his own. A high degree of coordination is required to carry out the programs within the VISN’s and to ensure that services are provided to the veteran population. Special Situations (3 or more must be met in order to add another level) 1. Variety of work. This situation is credited when more than one kind of work, each representing a requirement for a distinctly different additional body of knowledge on the part of the supervisor, is present in the work of the unit. A “kind of work” is usually the equivalent of a classification series. This situation is not credited. The appellant supervises three GS-1105 Purchasing Agents. This does not impose additional bodies of knowledge on the part of the appellant. 2. Shift operations. This situation is credited when the position supervises an operation carried out on at least two fully staffed shifts. The appellant does not supervise shift work, so this situation is not credited. 3. Fluctuating workforce or constantly changing deadlines. This situation is credited when the workforce supervised by the position has large fluctuations in size, e.g., seasonal variations in staff. This situation can also be credited when frequent, abrupt, and unexpected changes in work assignments, goals, and deadlines require the supervisor to constantly adjust operations under the pressure of continuously changing and unpredictable conditions. This situation is not credited since the appellant supervises a workforce that does not fluctuate in size. Although the appellant has a large workload, there is no indication that he must constantly adjust operations under pressure and unpredictable conditions. 4. Physical dispersion. This situation is credited when a substantial portion of the workload for which the supervisor is responsible is regularly carried out at one or more locations physically removed from the main unit. This situation does not apply to the appellant. All supervised employees are at the same location. 5. Special staffing situations. This situation is credited when a substantial portion of the workforce is involved in special employment programs, require counseling on a regular and recurring basis, and require job assignments or training that must be tailored to fit special circumstances. This situation does not apply to the appellant since he is not required to resolve difficult human resources management issues such as those described. 6. Impact of specialized programs. This situation is credited when supervisors are responsible for a significant technical or administrative workload in grades above the level of work credited in Factor 5. This situation is not credited since the appellant does not supervise employees above the GS-6 level credited under Factor 5. 7. Changing technology. This situation is credited when work processes and procedures vary constantly because of the impact of changing technology, creating a requirement for extensive training and guidance of the subordinate staff. This situation is not credited. There is no indication that changing technology imposes additional complications on the appellant’s supervisory responsibilities. 8. Special hazard and safety conditions. This situation is credited when the supervisory position is regularly made more difficult by the need to make provision for significant unsafe or hazardous conditions. This situation is not credited. Although the appellant himself must take safety precautions on a regular and recurring basis, there is no indication that he must make similar provisions for his subordinate staff. Since none of the special situations applies to the appellant’s supervisory responsibilities, an extra level is not warranted. Level 6-2 is credited for 575 points. Summary Factor Level Points 1. Program scope and effect 1-2 350 2. Organizational setting 2-2 250 3. Supervisory and managerial authority exercised 3-2c 450 4. Personal contacts 4A. Nature of contacts 4A-2 50 4B. Purpose of contacts 4B-2 75 5. Difficulty of typical work directed 5-3 340 6. Other conditions 6-2 575 Total 2090 A total of 2090 points falls in the GS-9 range (1855 – 2100) by reference to the conversion chart in the GSSG. Grade summary The appellant’s program administration duties are evaluated at the GS-12 grade level, and the supervisory duties at the GS-9 grade level. Since the GS-12 program administration duties are determined to be grade controlling, the appellant’s position is properly classified at the GS-12 grade level. Decision The appellant’s position is properly classified as GS-672-12, with the title at the agency’s discretion. The title should denote the appellant’s supervisory responsibilities.