U.S. Office of Personnel Management

Office of Merit Systems Oversight and Effectiveness

Classification Appeals and FLSA Programs

Atlanta Oversight Division

75 Spring Street, SW., Room 972

Atlanta, GA 30303

Kathy W. Day

Classification Appeals Officer

6/16/99

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 grade 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 servicing personnel 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]

[appellant's agency address]

Director

Office of Human Resources Management

U.S. Department of Agriculture

1400 Independence Ave., SW Room 316-W

Washington, DC 20250

Introduction

On April 13, 1999, the Atlanta Oversight Division, U. S. Office of Personnel Management (OPM), accepted an appeal for the position of Community Development Assistant, GS-1101-5, United States Department of Agriculture, [city/state]. The appellant is requesting that her position be classified as Community Development Technician, GS-1101-6.

The appeal has been accepted and processed under section 5112(b) of title 5, United States Code. This is the final administrative decision on the classification of the position subject to discretionary review only under the limited conditions and time outlined in part 511, subpart F, of title 5, Code of Federal Regulations.

General issues

The appellant contends that the duties she performs are outside the scope of her position description. She has been performing the duties of the GS-6 technician with her supervisor's knowledge. The Rural Development Office consists of four individuals - a manager, a loan specialist, a community development technician, and the appellant, the Community Development Assistant. They all interview applicants for loans. There are four types of loans processed at their office, and they all take turns processing all types of loans/grants. The appellant estimates that she spends 40 percent of her time performing clerical duties, and 60 percent of her time assisting applicants with loans/grants requiring her to examine applications, supporting documents and credit reports, and to assist the applicants with other loan/grants information. She further states that she has been interviewing applicants since 1991. According to the appellant, the Rural Development Local Office no longer services the 1500 borrowers they once serviced. This work is now handled by the St. Louis office. This allows the appellant to spend more time evaluating and analyzing loan applications for eligibility, determining that loan conditions are met, initiating and composing correspondence to applicants, and advising borrowers of available services. The supervisor agrees that the appellant spends a significant amount of her time interviewing applicants for loans/grants and making eligibility recommendations.

Position information

The appellant is assigned to position description number. The appellant, supervisor and agency have certified to the accuracy of the position description. However, we find that the position description does not describe the technician work performed by the appellant for the majority of the time.

The appellant performs routine clerical duties 40 percent of her time including greeting customers, processing mail, ordering supplies, typing, and completing time and attendance and travel vouchers. She prepares monthly, quarterly, and annual reports. She spends 60 percent of her time performing evaluative work including pre-qualifying applicants and determining their eligibility for loans/grants. She reviews applications and documents for completion; assists the applicants by explaining the documents, procedures, and requirements; and prepares documents for loan closings.

The appellant receives general direction from the Community Development Manager. The appellant independently plans and carries out her routine work in accordance with instructions, policies, and accepted practices. She recommends loans/grants eligibility to her supervisor, and he typically concurs. Completed work is usually reviewed for effectiveness, adequacy, and conformity to established policies and procedures.

Series determination

The agency placed the appellant's position in the General Business and Industry Series, GS-1101. We concur. The Business and Industry Group includes positions which perform work requiring a knowledge of business practices and the administration of regulatory provisions and controls. The Rural Development Office is responsible for administering the rural assistance and development programs in its area of jurisdiction, and the appellant's position was established to support the functions of the office. She performs a number of administrative, technical, and clerical functions requiring a knowledge of information management and administrative procedures, instructions, regulations, and directives as they relate to loan/grant programs.

Title determination

There are no published standards for the GS-1101 series. According to the guidance in the Introduction to the Position Classification Standards, agencies may designate the official title of positions in occupational series for which OPM has not prescribed titles. The parenthetical title "Office Automation" is added since the position requires a qualified typist and skilled use of office automation equipment.

Standard determination

Miscellaneous Clerical and Assistant Series, GS-303, January 1979.

Grade Level Guide for Clerical and Assistance Work, June 1989.

Office Automation Grade Evaluation Guide, November 1990.

Grade determination

The GS-1101 series has no grade level criteria for the evaluation of positions. The Grade Level Guide for Clerical and Assistance Work provides general criteria for use in determining the grade level of nonsupervisory clerical and assistance work. Administrative support of the kind described in the guide is performed in offices, shops, laboratories, hospitals, and numerous other settings in all Federal agencies. The guide describes the general characteristics of each grade level from GS-1 through GS-7 and uses two criteria for grading purposes: Nature of Assignment (which includes knowledge required and complexity of the work) and Level of Responsibility (which includes the elements of supervisory controls, guidelines, and contacts).

Clerical/Technical Work

The appellant's position involves performing different kinds and levels of clerical, administrative, and technical work. The highest level of work performed more than 25 percent of the time is grade- controlling. The position is evaluated as follows:

Nature of Assignment

The agency credited the GS-5 level. However, we believe that the appellant's clerical duties compare to the GS-5 level but the technical duties compare to the GS-6 level.

The GS-5 level work consists of performing a full range of standard and nonstandard clerical assignments and resolving a variety of nonrecurring problems. Work includes a variety of assignments involving different and unrelated steps, processes, or methods. The employee must identify and understand the issues involved in each assignment and determine what steps and procedures are necessary and the order of their performance. Completion of each transaction typically involves selecting a course of action from a number of possibilities. The work requires extensive knowledge of an organization's rules, procedures, operations, or business practices to perform the more complex, interrelated, or one-of-a kind clerical processing procedures.

The appellant is responsible for providing general office clerical and essential office automation support for the organization, and she functions as the initial contact for customers requiring the services of the Rural Development Office. This part of the appellant's work meets the GS-5 level.

Technical assistance work at the GS-6 level involves considerable evaluative judgment within well- defined, commonly occurring aspects of an administrative program or function. The work may involve providing direct assistance to specialists or analysts by performing a segment of their work, or it may involve responsibility for various products or continuing processes requiring application of established policies, practices, and criteria. Typical assignments involve identifying issues, problems, or conditions and seeking alternative solutions in accordance with rules and guidelines. Assignments requiring evaluative judgment are narrowly focused, address a single product or action, and are relatively clear-cut. The employee usually deals with problems or situations that remain stable and resemble past situations that require judgment in selecting a best or appropriate solution. The work requires a practical knowledge of guidelines and precedent cases relating to a particular area and obtained through considerable work experience. It also requires skill in recognizing the dimensions of a problem and expressing ideas in writing.

The appellant's technical duties are comparable to the GS-6 level. The appellant performs technical duties associated with the loan/grant programs 60 percent of the time. She is the initial contact for customers. She is responsible for analyzing and processing requests for loans/grants to ensure that applicable requirements are met; identifying possible problems or conditions that may affect borrowing; determining eligibility; and furnishing basic information to the borrowers and other officials. She composes letters to applicants/borrowers in connection with loan/grants information. The appellant's work requires considerable knowledge and understanding of lending policies and credit analysis principles and their application to an evaluation of credit and risk. She identifies issues or problems and seeks alternative solutions consistent with applicable regulations. The work generally requires the appellant to use judgment to evaluate a limited number of factors (e.g., income, debt ratio, credit history, probability of repayment, etc.). This requires research and consideration of a variety of guidelines and precedent cases in making decisions.

This factor is properly evaluated at the GS-6 level.

Level of Responsibility

At the GS-5 level, the supervisor assigns work by defining objectives, priorities, and deadlines and provides guidance on assignments which do not have clear precedents. The employee works in accordance with accepted practices and completed work is evaluated for technical soundness, appropriateness, and effectiveness in meeting goals. Extensive guides in the form of instructions, manuals, regulations, and precedents apply to the work. The employee uses judgment in locating and selecting the most appropriate guidelines for application and adapting them according to circumstances of the specific case or transaction. If existing guidelines cannot be applied, the employee refers the matter to the supervisor. Contacts are with a variety of persons within and outside the agency for the purpose of receiving or providing information relating to the work or for the purpose of resolving problems in connection with recurring responsibilities.

The appellant's clerical duties meet the GS-5 level. The appellant works independently in carrying out the clerical assignments and is responsible for resolving nonrecurring problems and meeting deadlines. Completed work is not subject to detailed review. There are a number of published instructions, manuals, and procedures available that are applicable to the work. Contacts are with coworkers in and outside of the organization and customers for whom services are provided. These contacts are made to obtain or provide information and to resolve problems that arise.

At the GS-6 level, the supervisor assists with precedent assignments by providing an interpretation of policy or the concepts and theories of the occupation. Completed work is evaluated for appropriateness and effectiveness in meeting goals. Guidelines such as regulations, instructions, evaluation criteria, and prior case or action files are available, but they are often not completely applicable to the assignment or have gaps in specificity. The employee uses judgment in interpreting and adapting guidelines for application to specific cases or problems. The employee bases decisions and recommendations on facts and conventional interpretations of guidelines rather than on theory or opinion. The employee contacts others to provide, receive, or develop information in order to identify problems, needs or issues, and/or to coordinate work efforts or resolve problems.

The appellant plans and carries out her day-to-day work independently. Supervisory or other staff assistance is available when there is a need for it. Completed work is generally evaluated for appropriateness and effectiveness in meeting the goals of the office. Regulations, instructions, and prior cases are available as guidance, and the appellant exercises judgment in applying them to specific cases or problems. According to the supervisor, guidelines have gaps in their applicability to each case; therefore, the appellant may have to interpret or adapt procedures. The appellant handles problems and deviations in the work assignments in accordance with policies, past training, and accepted practices. Contacts are with others inside and outside of the agency to explain, provide, or obtain information in order to identify problems, needs or issues for the purpose of assisting borrowers.

This factor is properly evaluated at the GS-6 level.

Since both factors are evaluated at GS-6, the overall evaluation of the loan/grant programs work is GS-6.

Office Automation Work

The office automation work is evaluated against the Office Automation Grade Evaluation Guide which is written in the Factor Evaluation System format. These duties do not impact the grade of the position, therefore, a summary evaluation follows:

FACTOR

LEVEL

POINTS

1. Knowledge Required by the Position

1-3

350

2. Supervisory Controls

2-2

125

3. Guidelines

3-2

125

4. Complexity

4-2

75

5. Scope and Effect

5-1

25

6. Personal Contacts and

7. Purpose of Contacts

1a

30

8. Physical Demands

8-1

5

9. Work Environment

9-1

5

Total

740

In accordance with the grade conversion table in the guide, a total of 740 points falls within the range of GS-4, 655 to 850 points.

Summary

The highest level of substantive work, which is performed for 60 percent of the time, is evaluated at the GS-6 level. The office automation work is evaluated at GS-4. The position is properly evaluated at the GS-6 level.

Decision

This position is properly classified as GS-1101-6, with the title at the discretion of the agency to include Office Automation.