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 75242-9968

/s/Bonnie J. Brandon

_____________________________

Bonnie J. Brandon

Classification Appeals Officer

August 3, 2000

_________________________

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).

Decision sent to:

Appellant:

[appellant's name]

[appellant's address]

Agency:

Personnel Management Specialist

National Park Service

[installation address}

Director of Personnel

U.S. Department of Interior

Mail Stop 5221

1849 C Street, NW

Washington, D.C. 20240

Introduction

On March 24, 2000, the San Francisco Oversight Division (SFOD) of the U.S. Office of Personnel Management (OPM) accepted a classification appeal from [appellant}, the Chief of Administration, [national park], National Park Service (NPR), U.S. Department of the Interior, [city and state]. Due to workload considerations, SFOD transferred the appeal to the Dallas Oversight Division for adjudication on May 10, 2000. The appellant contests the agency's current classification of her position as Administrative Officer, GS-341-12. She believes that her position should be graded at GS-13 due to increased responsibilities since her position was last evaluated in 1995 as well as substantial independence from supervision. She believes Factor 2, Supervisory Controls, for her position should be evaluated at factor level 2-5 instead of 2-4. She also suggests that Factors 1, 3 and 4 could be evaluated at the highest factor levels. The appellant does not contest her position title or series.

The appellant and her supervisor agree that position description (PD) number [number] accurately depicts her two major duties ("park management support" and "personnel management"), but not the percentages of time shown spent on each. Instead of the 50/50 split currently shown on her PD, they agree that 75 percent on park management support and 25 percent on personnel management would be a more accurate reflection of her work situation. We also believe that a statement in the PD that she "serves as Acting Superintendent in (his) absence" is misleading since that role is rotated among the division and office chiefs who report direct to the Superintendent. The Region approved the PD in September 1999. The PD is adequate for evaluation.

We have accepted and decided her appeal under section 5112 of title 5, United States Code (U.S.C.). To help decide the appeal, a Dallas Oversight Division representative conducted initial telephone interviews with the appellant and her supervisor on July 7, 2000, and had additional, follow-up discussions with both. We also spoke with the Park's Personnel Management Specialist and with the Region's Chief, Office of Human Resources.

General issues

The appellant characterized [the national park] as a "developing park," that is, one that is gradually expanding in size and administrative complexity as additional acreage and existing historical buildings are acquired. In addition, the responsibility for various management and office services has been shifted to the appellant's unit from the [region] (contracting for architectural and engineering services) and from other divisions/offices in the Park itself (information management-database management, hardware/software, LAN, telecommunications, housing and space management, and concessions management.

With the approval of the regional office, the Park Superintendent arranged for a contract position classifier to audit and evaluate the appellant's position under PD Number [number]. The classifier evaluated the position at GS-13, based heavily on the appellant's alleged extraordinary independence from supervisory controls (see discussion below on Factor 2.) However, the Chief, Office of Human Resources for the [region], which retains final classification authority for GS-13 positions, rejected the classifier's evaluation of Factor 2, making pen-and-ink changes lowering it to factor level 2-4 and sustaining the GS-12 grade. The Region made no changes in the classifier's other factor evaluations, but did make a pen-and-ink correction to show that the appellant's supervisor (the Superintendent) reports to a GS-15 (rather than an official in the management chain. The Chief, Office of Human Resources, considers the contract classifier's evaluation, as amended by the Region's pen-and-ink changes, to be the agency's current evaluation of the appellant's position.

In her statement, the appellant contends that the Region refuses to allow classification of her position at GS-13 because she is a woman. She suggested that a demographic profile of positions within the Region would clearly show a pattern of gender discrimination, that is, most of the GS-13 positions being held by men.

In adjudicating this appeal, we make our own independent decision on the proper classification of the appellant's position. By law, we must make that decision solely by comparing the appellant's current duties and responsibilities to OPM classification standards and guides (5 U.S.C. 5106, 5107 and 5112). Also, we cannot compare the appellant's position to others as a basis for deciding her appeal. Therefore, we considered the appellant's statements only insofar as they are relevant to making a comparison to applicable standards and guides.

Position information

The appellant serves as the Chief of Administration for the [national park]. The Park is under the jurisdiction of the Park Service's [ area] Region and consists of 5 islands, variously located 11 to 65 miles off the coast of [state], and a headquarters located on the mainland at [city and state]. The Park consists of 125,000 acres of island land and 125,000 acres of submerged land and water surrounding the islands. The Park is open year-round and contains a diverse and unique collection of animal species, breeding colonies, endangered plants and animals, and archeological sites. Management of the Park is complicated by unusual land ownership and jurisdictional issues that require coordination and cooperation with other Federal and state agencies and the local private sector. For example, the Park islands are surrounded by the [marine sanctuary], managed by the [federal government agency]. One of the five islands, [name of island], is owned by the [government department] but managed as part of the Park under a special agreement. The NPS owns only ten percent of [name of island], with the remainder owned by the [conservation organization]. The [Federal government agency] has holdings for navigation aids on three of the islands. The State of [name of state] has jurisdiction for the sea floor and water column in park and sanctuary waters. The former owners of [name of island] have use and occupancy rights until the year 2012, which necessitates management of special use permits and deed restrictions.

The Park has [number] full-time permanent employees, but that number can be enhanced during peak work periods with varying numbers of seasonal employees. Three contract concessionaires provide water and air taxi service to the islands for park visitors and employees. Thirteen of the employees are required, as a condition of their employment, to live on the islands for weeklong periods before rotating back to the mainland. For this purpose, the Park maintains and collects rent for 20 housing units.

Organizationally, the appellant's position is one of eight office/division chief positions reporting directly to the GS-14 Park Superintendent. The Superintendent reports to the GS-15 Assistant Regional Director, who in turn reports to the SES Regional Director. The appellant functions as an integral member of the Park's management team and is responsible for developing the Park's policies and program directions for a variety of substantive management and office services. She works mostly at the mainland headquarters facility in [city], but makes occasional trips to the island facilities to attend meetings, make safety inspections, or conduct other business. She has a staff of six employees who provide substantive management services in four main areas:

Personnel – The Park has its own full-service personnel office, with delegated final authority for recruitment, selection and classification for positions up through the GS-12 level. Final approval for positions above GS-12 rests at Regional and higher organizational levels. The appellant oversees the work of a GS-11 Personnel Management Specialist, who is assisted by a GS-7 Personnel Assistant. The specialist has been delegated appointing authority from the Superintendent and signs all personnel actions.

Budget – The park manages a fairly stable, annual "core" operating budget of about $4.4 million, that is supplemented by varying amounts of additional one-year or no-year funding for specific projects directed by Congress or higher agency levels. For FY 2000, that additional funding is approximately $3 million. The appellant participates in budget formulation and oversees the work of a GS-11 Budget Analyst in budget execution, ensuring that the park's revenues and expenditures are in balance and meet agency guidelines, and provides financial management information and advice to the park's management team.

Contracting and Procurement – The appellant administratively supervises the work of a GS-12 Contract Specialist with a Level III, million dollar warrant, in the competitive and negotiated contracting process for supplies, materials and services, including architectural and engineering services, multi-million dollar construction projects, and concession (i.e., boat and air transportation) operations.

Information Management – The appellant is responsible for providing to the Park information management, telecommunications and office automation advice in support of operational, maintenance, and administrative programs. She oversees the work of a staff member who provides technical support and analysis of computers, software, two local area networks, and telecommunications equipment and services.

In addition, the appellant personally performs a variety of management or office services, such as: (1) managing the Park's strategic plan development, tracking and reporting under Government Performance and Results Act (GPRA) requirements, ensuring appropriate linkage of funding decisions to priority goals and objectives; (2) housing/quarters management, (3) space acquisition and management; (4) safety management, (5) records management, and (6) internal controls. Some of this work involves her entry of data into NPS-standard, automated project management and quarters management systems. She also performs some liaison work in the community, primarily with two local tourism boards and port authority representatives.

The appellant's unit is organized as follows:

Chief: GS-341-12

Personnel Mgt Spec Contract Specialist Budget Analyst Computer Specialist

GS-201-11 GS-1102-12 GS-560-11 GS-334-11*

*Student Trainee

Personnel Assistant Purchasing Agent GS-399-11

GS-203-7 GS-1105-7

The appellant directly supervises the four, two-grade interval "specialist/analyst" positions and functions as the second-level supervisor for the two support/assistant positions. The full-performance level of the specialist positions is GS-11, except for the Contract Specialist, which is GS-12 because of the expert knowledge required, a Level III - million-dollar warrant, and responsibility for negotiating architectural and engineering services and construction contracts for the Park. The grade also recognizes the Contract Specialist's independence from technical supervision by the appellant. The information management (i.e., Computer Specialist) position is encumbered by a GS-11, Student Career Experience Program, employee who is working toward a master's degree. The appellant acknowledges that she occasionally relies on an NPS headquarters automation specialist to advise and assist the GS-11 in developing/maintaining the Park's database and computer/LAN and telecommunications systems, when needed.

Both the appellant and her supervisor acknowledge that she has the specialized experience and training to technically supervise only the Budget Analyst's work. She provides only administrative supervision to the other three specialist positions.

The appellant and her supervisor agree that the following depicts the division of her time:

25% - supervision of her staff;

20% - coordination of the Park's GPRA tracking/updating;

15% - assist with budget formulation and execution;

10% - input to automated budget and project management systems;

10% - coordination with General Services Administration on space management;

10% - personal liaison with community contacts (e.g., tourism boards);

5% - housing management/input to quarters management information system;

5% - information management;

1% - oversee human resources servicing; and

1% - oversee contracting/procurement

Series, title, and standard determination

The appellant's duties and responsibilities, and the corresponding knowledge and skills required, match the Administrative Officer, GS-341, series. That series includes positions responsible for providing, obtaining or negotiating for a variety of management services that support the direction and operation of an organization, such as the [national park]. Like the appellant, Administrative Officers are expected to have an in-depth knowledge of the organization's mission and functions, goals and objectives, operating programs and projects, position structure for carrying out those programs and projects, the kinds of positions and people needed, equipment and materials used, and financial resources needed.

The GS-341 standard describes two common types of work situations for Administrative Officers. The situation that matches that of the appellant involves operation of a central administrative unit that includes specialist positions performing personnel, budgeting, contracting and data processing services, but no single functional or service area is paramount skills-wise.

Although the appellant has a full range of supervisory duties and responsibilities, the GS-341 series standard prescribes only one authorized title for all non-trainee positions in this series: Administrative Officer.

Grade determination

The appellant spends 25 percent of her time supervising her staff, carrying out a full range of supervisory responsibilities. However, only a fraction of that 25 percent is spent providing both technical and administrative supervision (i.e., to the Budget Analyst). Therefore, the General Schedule Supervisory Guide, which requires a full 25 percent in providing both technical and administrative supervision, does not apply for grading purposes.

The GS-341 series standard does not contain grading criteria, but instead instructs that these positions be evaluated using the standards for other, administrative specialty series, such as Financial Management, GS-505; Personnel Management, GS-201; Management Analysis, GS-343; and Budget Analysis, GS-560. We selected the GS-343 series because of the general administrative subject-matter work involved and its coverage of positions that serve as analysts and advisors to management on the effectiveness of agency/organization programs and operations. Such positions require knowledge of agency and organization missions, functions, goals, objectives, programs, policies and regulations; knowledge of management principles relating to planning, organizing, staffing, directing and controlling; and evaluative methods for assessing program status, effectiveness and conformance to regulatory requirements. However, the GS-343 series standard also does not have grading criteria, but instead directs use of the Administrative Analysis Grade Evaluation Guide (AAGEG) for grading purposes.

The AAGEG provides grading criteria using nine factors under the Factor Evaluation System (FES) format where the points assigned under each factor must be fully equivalent to the factor level described. If a factor level description is not fully met, the point value for the next lower level must be assigned.

The appellant disagrees with the agency's evaluation of Factor 2 and she suggests that Factors 1, 3 and 4 could be creditable at the highest factor levels. We have reviewed Factors 5 through 9 and found them to be correctly evaluated, except for Factor 7, Purpose of Contacts. Therefore, we have confined our analysis to the disputed factors 1 – 4 and to Factor 7.

.

Factor 1, Knowledge required by the position

This factor covers the kind and nature of knowledge and skills needed and how they are used in doing the work.

Level 1-6 of the AAGEG applies to knowledge appropriate for analytical and evaluative positions at the first full performance level. Included at this level is knowledge of administrative practices and procedures common to organizations, such as delegations of authority, routing of correspondence, filing systems, and storage of records and files. An illustrative example in the Guide at this level involves the application of factfinding and work measurement techniques to conduct position management studies of clerical, trades, technician and administrative support positions within a single organizational component at the operating (installation) level.

Level 1-7 covers assignments requiring knowledge and skill in applying analytical and evaluative methods to issues or studies concerning the efficiency and effectiveness of program operations carried out by administrative or professional personnel, or substantive administrative support functions (i.e., internal activities or functions such as supply, budget, personnel and procurement which serve to facilitate line or program operations. This level includes knowledge of pertinent laws, regulations, policies and precedents, which affect the use of program and related support resources (people, money, and equipment). Projects at this level typically require knowledge of the major issues, program goals and objectives, work processes and administrative operations of the organization.

As the Chief of Administration, the appellant's role as a key member of the Park's management team and her responsibilities for determining, planning and providing a wide variety of substantive administrative programs and management services (i.e., budget, personnel, contracting/procurement, and information management) that cross all segments of the Park's operations and organizational segments, exceeds level 1-6 and meets level 1-7. The appellant's position requires knowledge of pertinent laws, Congressional budget decisions (the "Green Book"), and implementing regional, bureau and departmental budget regulations and guidelines to ensure that fiscal resources are adequate to meet mission and special needs and are used and managed in accordance with applicable directives. Similarly, she must be knowledgeable of all regulations and guidelines pertaining to GPRA, so she can ensure that the Park's goals, objectives, work plans and the distribution of fiscal resources are adequately aligned with the agency's strategic plan. The appellant also must be aware of other Governmentwide, departmental, bureau and regional regulations and policies that apply to other substantive administrative services that she provides personally or through her subordinate staff.

Level 1-8 is the level of expert analysts who have mastered the application of a wide range of qualitative and quantitative methods for the assessment and improvement of program effectiveness or the improvement of complex management processes and systems. Knowledge characteristic of this level is applied to the design and conduct of comprehensive management studies where the boundaries of the studies are extremely broad and difficult to determine in advance. At this level, knowledge is also applied in preparing recommendations for legislation or in evaluating the content of new or modified legislation for projected impact on agency programs and resources. Illustrative examples for this level in the Guide describe situations where the knowledge is applied to a multi-layered military command and includes developing resource guidance to subordinate activities. The appellant does not apply these types of techniques or operate in that type of organizational structure.

This factor is evaluated at level 1-7 and 1,250 points are credited.

Factor 2, Supervisory controls

This factor covers how the work is assigned, the extent to which the employee is responsible for carrying it out, and how the work is reviewed.

At level 2-4, the employee and supervisor develop mutually acceptable project plans which typically include identification of the work to be done, the scope of the project, and deadlines for completion. Within the parameters of the project, the employee is responsible for planning and organizing the project steps, estimating costs, coordinating with staff and line management personnel, and conducting all phases of the project. This frequently involves the definitive interpretation of regulations and study procedures. The employee informs the supervisor of potentially controversial findings, issues or problems of widespread impact. Completed projects are reviewed by the supervisor for compatibility with organizational goals, guidelines, and effectiveness in achieving intended objectives. Completed work is also reviewed critically by staff and line management officials whose programs and employees would be affected by implementation of the employee's recommendations.

At level 2-5, the employee is the recognized authority in the analysis and evaluation of programs and issues and the work is subject only to administrative and policy direction concerning overall project priorities. The employee is typically delegated complete responsibility and authority to plan, schedule and carry out major projects concerned with the evaluation of programs or organizational effectiveness. At this level, the employee typically exercises discretion and judgment in determining whether to broaden or narrow the scope of the project. The employee's analyses, evaluations and recommendations are normally reviewed by management officials for potential influence on broad agency (i.e., department or subordinate agency/bureau) policy objectives and program goals. Findings and recommendations are normally accepted without significant change.

We find the appellant to have a substantial degree of independence in determining what needs to be done in accomplishing both recurring and non-recurring work assignments that is best captured by factor level 2-4. The supervisor often gives work assignments to the appellant with no more direction than "Take care of this." She then determines what needs to be done and either personally performs the assignment or refers it to an appropriate subordinate staff member for action, depending on the particular subject matter involved and nature of the work to be done. She is considered an authoritative source within the Park on budget matters and GPRA requirements; however, she is not the sole technical expert in those areas, as the supervisor has the experience and training to handle the full range of technical questions in the appellant's absence. The supervisor reviews her budget and GPRA work in a manner that is more consistent with level 2-4, and controversial aspects of her work are also discussed with the Park's management team. In addition, a local budget review committee is currently assisting the appellant and her Budget Analyst in monitoring the Park's year-end budget execution for conformance with agency guidelines and restrictions.

The contract position classifier evaluated this factor at level 2-5, based on finding that the appellant: "…is free of technical controls…," "works independently with no technical guidance from the supervisor…," does not work with the supervisor "…to develop mutually acceptable project plans…," and, significantly, "does not inform the supervisor of potentially controversial findings, issues, or problems with widespread impact." While our interviews found that the supervisor may sometimes give the appellant work assignments with little more instruction than "take care of this", we could not substantiate that that approach applies to all major issues/problems. Further, we could not confirm that the appellant is totally free from having her work reviewed and from having to alert her supervisor to potentially controversial issues or problems with the possibility of widespread impact. Both the appellant and the supervisor denied that she operates with such extreme independence and were uncertain how the classifier concluded that. Further, there is no evidence that the appellant's work regularly influences departmental or agency policies and program goals, which is also typical of level 2-5.

This factor is evaluated at level 2-4, and 450 points are credited.

Factor 3, Guidelines

This factor covers the nature and extent of guidelines for performing the work and the judgment needed to apply the guidelines or develop new guidelines.

At level 3-4, guidelines consist of general administrative policies and management and organizational theories which require considerable adaptation or interpretation for application to issues and problems studied. At this level, administrative guidelines usually cover program goals and objectives of the employing organization, such as agency controls on size of the workforce, productivity targets, and similar objectives. Within the context of broad regulatory guidelines, the employee at this level may refine or develop specific guidelines such as implementing regulations or methods for the measurement and improvement of effectiveness and productivity in the administration of operating programs.

At level 3-5, guidelines consist of basic administrative policy statements concerning the issue or problem being studied, and may include reference to pertinent legislative history, related court decisions, state and local laws, or policy initiatives of agency management. At this level, the employee uses judgment and discretion in determining intent and in interpreting and revising existing policy and regulatory guidance for use by others within or outside the employing organization. Some employees at this level review proposed legislation or regulations, which would significantly change the basic character of agency programs, the way the agency conducts its business, or which modify interagency relationships. At this level, the employee is recognized as an expert in the development and/or interpretation of guidance on program planning or evaluation in their area of specialization (e.g., workforce management, contingency/emergency planning, work measurement, or productivity.).

Guidelines used by the appellant include a wide range of applicable statutes (appropriations bills, the "Omnibus Parks Bill of 1997, and other budget-related laws, GPRA); Department of Interior, NPS and Regional policies, regulations, and manuals (e.g., budgeting, GPRA implementation, housing management, internal controls); Governmentwide regulations (e.g., contracting, personnel management), Office of Management and Budget Circulars (housing management), general administrative policies and broadly-stated directives that must be adapted for the unique aspects of the [national park], such as mandatory employee housing on the islands as a condition of employment, market analysis of rental rates, coordination with other stakeholder agencies. She functions as the Park's lead authority on interpreting laws, regulations and policies relating to the budget formulation and execution process and to the implementation of GPRA requirements. Although she must be familiar with certain statutes, her task is limited to interpreting and applying them within the confines of the [national park] rather than in terms of their impact on the broad scale of a region, agency or department. While the appellant mentions her two-week project assignment to assist the NPS Strategic Planning Office staff with completion of the Park Service's annual performance plan as evidence of broad, level 3-5 responsibility, that detail is not representative of the regular and ongoing focus of her work.

This factor is best evaluated at level 3-4, and 450 points are credited.

Factor 4, Complexity

This factor covers nature of the assignment, difficulty in identifying what needs to be done, and difficulty and originality involved in performing the work.

At level 4-4, the work involves gathering information, identifying and analyzing issues, and developing recommendations to resolve substantive problems of effectiveness and efficiency of work operations in a program or program support setting. This is in addition to analyzing and improving conditions solely of a procedural nature (rather than the substance of administrative operations), which is creditable at the next lower level, 4-3. In contrast to level 4-3, work at this level requires application of evaluative methods and techniques to a wider range of variables. For example, assignments may involve compiling, reconciling and correlating voluminous workload data from a variety of sources with different reporting requirements and formats.

At level 4-5, the work involves varied duties requiring many different and unrelated processes and methods applied to a broad range of activities of substantial depth of analysis, typically for an administrative or professional field. Assignments are complicated by conflicting program goals and objectives, which may derive from changes in legislation or regulatory guidelines, and/or variations in demand for services. Options, recommendations, and conclusions developed by the employee take into account uncertainties about the data and other variables, which affect long-range performance.

At level 4-6, the employee plans, organizes, and carries out studies involving the substance of key agency programs. There is extreme difficulty in identifying the nature of the issues or problems to be studied and in planning, organizing and determining the scope and depth of the study. Difficulty is also encountered in discerning the intent of legislation and policy statements, and determining how to translate the intent into program actions. At this level, the work typically involves efforts to develop and implement agency programs based upon new or revised legislation.

The appellant's duties and responsibilities cover a wide range of the substantive administrative and office services functions of the Park, for which she serves as the Park's lead point of contact with unit managers, higher organizational program offices, and "cluster groups" of administrative specialists across the region and the agency. The work involves a variety of processes and the coordination of issues and the various phases of the work with internal management and with external program and community contacts who have a stake in the results of the appellant's work. The work is complicated by uncertainties and conflicting program priorities, such as meeting Congressionally-mandated deadlines for completing no-year or one-year projects when the necessary funding has not yet been released from higher agency headquarters or from other involved agencies. Although the position requires the appellant to be familiar with applicable statutes and congressional budget directions, she does not develop or revise implementing agency-wide programs, as envisioned at level 4-6.

This factor is evaluated at level 4-5, and 325 points are credited.

Factor 6, Personal contacts / Factor 7, Purpose of contacts

These factors cover the people and level of contacts made in carrying out the work and the reasons for those contacts. Under the AAGEG, these factors are evaluated separately but a combined point credit is determined by determining where the respective levels intersect in a table shown on page 25 of the Guide.

The appellant's regular daily contacts are primarily with her staff, the Superintendent and other Park managers/supervisors. However, she also has frequent contacts outside the park (i.e., with the regional office program staff (weekly), the NPS headquarters program staff (twice per month), managers of other parks and the DOI staff (occasionally), and with local community officials of the [local government agency] and City of [name of city] (weekly to monthly), in moderately unstructured settings. We reviewed and agree with the agency's evaluation of these contacts at level 3.

In evaluating the purpose of those contacts, level "b" applies solely to obtaining or exchanging information. Level "c" covers situations beyond obtaining or exchanging information where the employee is also providing advice to managers on non-controversial organization or program-related issues and concerns. Contacts at level "c" typically involve such matters as: identification of decision-making alternatives; appraisals of success in meeting goals; or recommendations for resolving administrative problems.

At level "d", the purpose is to justify or settle matters involving significant or controversial issues (e.g., recommendations affecting major programs, dealing with substantial expenditure, or significantly changing the nature and scope of organizations).

Many of the appellant's contacts at higher agency levels are to obtain or exchange information and request clarification of policies and guidelines. However, contacts are also intended to advise managers and staff on program-related issues and concerns (e.g., budget changes, status of expenditures against strategic plan and organizational work plans, goals, objectives, policies and directives) and to influence managers or other officials to accept and implement recommendations pertaining to administrative programs, which are characteristic of level "c". We did not find evidence of the appellant's substantial involvement in settling matters on significant or controversial issues or significantly changing the nature and scope of organizations that would be characteristic of level "d."

These combined factors are evaluated at level "3c," and 180 points are credited.

Summary

The appellant's position is properly evaluated as follows:

Factor Level Points	Knowledge required by the position

Supervisory controls

Guidelines

Complexity

Scope and effect

Personal contacts/7. Purpose of contacts

Physical demands

Work environment 1-7

2-4

3-4

4-5

5-4

3c

8-1

9-1 1,250

450

450

325

225

180

5

5 9.	Total 2,890

Using the Grade Conversion Table found in the AAGEG, 2,890 points fall within the GS-12 range of 2,755 – 3,150 points.

Decision

The appellant's position is properly classified as GS-341-12 and titled Administrative Officer.