U.S. Office of Personnel Management Office of Merit Systems Oversight and Effectiveness Classification Appeals and FLSA Programs San Francisco Oversight Division 120 Howard Street, Room 760 San Francisco, CA 94105-0001 Classification Appeal Decision Under section 5112 of title 5, United States Code Appellant: [The appellant] Agency classification: Housing Manager GS-1173-11 Organization: [The appellant's organization] OPM decision: Housing Manager GS-1173-11 OPM decision number: C-1173-11-05 _____________________________ Carlos A. Torrico Classification Appeals Officer June 24, 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). Decision sent to: Appellant: [The appellant's address] Agency: Ms. Roberta A. Allen Director, Human Resources Center U.S. Department of the Navy HRSC Southwest 525 B Street, Suite 600 San Diego, California 92101-4418 Mr. Will Maltbie, Director Office of Civilian Human Resources (OCHR) Nebraska Avenue, Complex 321 Somer Court, NW, Suite 40101 Washington, DC 20393-5451 Mr. Allan Cohen Office of Civilian Human Resources (OCHR) Nebraska Avenue, Complex 321 Somer Court, NW, Suite 40101 Washington, DC 20393-5451 Director, Plans, Programs and Diversity Office of the Deputy Assistant Secretary of the Navy, Civilian Personnel (CP/EEO) Department of the Navy 800 North Quincy Street Arlington, VA 22203-1998 Ms. Janice W. Cooper Chief, Classification Appeals Adjudication Section Department of Defense Civilian Personnel Management Service 1400 Key Boulevard, Suite B-200 Arlington, VA 22209-5144 Introduction On January 25, 2002, the San Francisco Oversight Division of the U.S. Office of Personnel Management (OPM) accepted a classification appeal from [the appellant]. On April 3, 2002, the Division received the agency's administrative report concerning [the appellant's] appeal. Her position is currently classified as Housing Manager, GS-1173-11, but she believes it should be graded at the GS-12 level. The appellant works in the [appellant's organization/location]. We have accepted and decided this appeal under section 5112 of title 5 United States Code (U.S.C.). General issues This decision is based on a review of all information submitted by the appellant and her agency. In addition, an Oversight Division representative conducted separate telephone interviews with the appellant and her immediate supervisor. Both the appellant and her supervisor have certified to the accuracy of the appellant's official position description (PD) [number]. The appellant compares her position to several GS-1173-12 and GS-1173-13 Housing Manager positions in other divisions of her agency, as well as to similar positions in other Federal, state, county and city agencies, and positions in non-public organizations. She contends that her responsibilities and workload surpass those of the other housing-related positions, and thus her job should be graded at a higher level. In adjudicating this appeal, our only concern is to make our own independent decision on the proper classification of the appellant's position. However, volume of work and salary comparability cannot be considered in determining the grade of a position (The Classifier’s Handbook, chapter 5). By law, we must make our decision solely by comparing the current duties and responsibilities to OPM standards and guidelines (5 U.S.C. 5106, 5107, and 5112). Since comparison to standards is the exclusive method for classifying positions, we cannot compare the appellant's position to others as a basis for deciding her appeal. Position information The appellant manages the military family housing program for the naval base consisting of approximately 800 housing units, a 17-lot mobile home park, and associated community facilities. In addition to on-base military family housing, she is responsible for managing an off-base housing referral service that locates rental housing suitable for military families in the communities surrounding the base. The appellant is responsible for overseeing or carrying out the full range of housing management functions. She ensures the performance of quality assurance evaluations of work performed on family housing buildings, grounds, streets, and utility distribution systems. She is responsible for developing and/or implementing management plans and directives concerning operation and utilization of housing assets at the installation, including housing inspections, occupant relations, and short and long range plans and related activities for maintenance, repair and improvement. She helps formulate the annual budget for the housing program under her jurisdiction and, once the budget is authorized and allocated, monitors various accounts to ensure limitations are observed. Based on past and current expenditures, she estimates future short and long-term operations and maintenance budget needs. Within the limits of her authority, the appellant can reallocate funds from one control point or account to another to cover shortfalls or unanticipated expenses. In other instances, she may request variances from her supervisor and the financial management specialist assigned to the family housing program at [appellant's installation]. The appellant is also the first-level supervisor of nine personnel assigned to the [appellant's branch]. These employees perform administrative and technical support work in the housing management field, and their positions range in grade from GS-5 to GS-9. The results of our interviews, the appellant's position description, and other materials of record provide more information about her duties and responsibilities and how they are performed. Series, title, and standard determination The agency has assigned the appellant’s position to the Housing Management Series, GS-1173, and the appellant does not disagree. We concur with the agency's series determination. As described in the position classification standard for the Housing Management Series, GS-1173, dated September 1981 (reissued in WCPS-1, August 2001), that series covers positions like the appellant's whose duties involve either managing or assisting in managing one or more family housing projects, billeting facilities, or other accommodations such as transient or permanent individual and family living facilities, dormitory facilities and restricted occupancy buildings including adjacent service facilities and surrounding grounds. Positions in this occupation require a variety of housing management and administrative knowledge and related practical skills and abilities in a number of housing-related activities. The appellant’s work involves managing, operating and maintaining military family housing units and associated utility distribution systems, streets and grounds located at the [appellant's installation] site. She is also responsible for managing the off-base housing referral service. Housing Manager is the authorized title for positions at GS-9 and above that are involved in the direct, onsite management and administration of housing projects, facilities or complexes. That title implies supervisory responsibilities; therefore, no modification of the title is necessary to identify the appellant's position as supervisory. The standard for the Housing Management Series, GS-1173, is appropriate for evaluating the grade level of appellant’s housing management duties. As noted above, the appellant supervises nine personnel assigned to her organization, and fully meets the coverage requirements in the General Schedule Supervisory Guide for evaluation as a supervisor. The grade level coverage in the GS-1173 standard recognizes that some housing management positions may also perform supervisory duties which are directly associated with the scope of the management responsibility, and that those tasks were taken into consideration in the development of the grading criteria. However, the standard does not provide grade-level criteria for classifying positions in which the supervisory qualifications and responsibilities are of greater weight in the evaluation of the position than are the housing operations responsibilities. In such cases, the position should be evaluated by reference to the General Schedule Supervisory Guide (GSSG), dated June 1998, and reissued in WCPS-1, August 2001. This is not the case in the appellant's position. We found that by application of the GSSG, the grade of the appellant's supervisory duties would not exceed the grade of her housing management responsibilities, and thus have limited our grade analysis to discussion of her housing management duties. Grade determination The GS-1173 standard uses the Factor Evaluation System (FES), which employs nine factors. Under the FES, each factor level description in a standard describes the minimum characteristics needed to receive credit for the described level. Therefore, if a position fails to meet the criteria in a factor level description in any significant aspect, it must be credited at a lower level. Conversely, the position may exceed those criteria in some aspects and still not be credited at a higher level. Our evaluation with respect to the nine FES factors follows. Factor 1: Knowledge required by the position, Level 1-7, 1250 points This factor identifies the nature and extent of housing management concepts, principles, policies, regulations, procedures, and processes the employee must know to do acceptable work, and the nature and extent of skills required to apply the knowledge. Assignments at Level 1-7 involve the planning, cost management, scheduling and coordinating of housing program requirements with housing residents, local authorities, regulatory agencies and others, and the development of administrative procedures related to the construction, maintenance, improvement, use, and management of housing projects and facilities. This level requires a comprehensive knowledge of a wide range of Federal and agency housing policies, requirements, and procedures to perform broad management planning, budgeting, and coordinating of work forces and resources, for the effective implementation of housing program requirements and negotiating with management or tenants on broad programs and problems related to the operation and use of housing assets. In addition, assignments at this level require a comprehensive knowledge of and skill in the application of housing management principles, concepts, and methodology to a variety of difficult and complex work assignments involving the full range of housing activities including operations and maintenance, cost management and financial planning, assignments and use, annual inspections and special surveys, new construction and improvements, management-tenant relations, and referral services or furnishings management where applicable. Level 1-7 also requires knowledge of appropriate laws and regulations governing the construction, occupancy, eligibility, use, and operation of housing facilities to develop overall policies, plans or procedures for housing administration; coordinate the housing management program with other agencies and with the major functions and departments of regulatory agencies; and recommend major changes or amendments that would improve housing administrative policies, practices, and methodology. At Level 1-8, the position demonstrates mastery in the housing management field and exercises related expert knowledge of Federal, State, and regional housing policies, concepts, regulations, and laws including related legislative matters and legal precedents to provide expert advisory services to management, technical, and supervisory personnel in government. Employees at this level explore and develop new management techniques and methodology, and provide advice to effect solutions to unique or unusually complex problems regarding housing or community facilities, tenants, services, or equipment. This level also requires an extensive knowledge of regional housing trends and market acceptability concerning such factors as design features, labor and material costs, construction methods, etc. The appellant's position meets Level 1-7 but falls short of Level 1-8. Similar to that level her work requires in-depth knowledge of and skill in applying a wide range of housing policies, requirements, and procedures in managing a comprehensive family housing program for the installation. She is responsible for the entire range of activities related to the operation and use of housing for military families assigned including cost management, operations, referral, maintenance, furnishings, inspections, assignments, construction and improvements, etc. She is required to exercise skill to resolve conflicts and improve housing administrative policies, procedures and methods. The position does not meet Level 1-8 where the employee has demonstrated expertise in the housing management field and of Federal, state, and regional housing policies and trends. The management advice provided by the appellant does not encompass the breadth and expertise of advisory services typical of Level 1-8. This factor is evaluated at Level 1-7 and 1250 points are assigned. Factor 2: Supervisory controls, Level 2-4, 450 points This factor covers the nature and extent of direct or indirect controls exercised by the supervisor, the employee’s responsibility, and the extent of review of completed work. At Level 2-4 the housing supervisor sets the overall objectives and establishes the resources available. The employee and the supervisor jointly establish project deadlines, scope, and level of work to be accomplished. Based on expertise in the application of housing management principles and practices in a variety of routine and unusually difficult assignments involving Government-owned, assisted, leased, rented, or privately owned housing projects and facilities, the incumbent is responsible for planning and carrying out the assignment, resolving most of the conflicts which arise, coordinating the work with others as necessary; and interpreting policy on his/her own initiative in terms of established objectives. Completed work is reviewed only from an overall standpoint in terms of feasibility, compatibility with other work, or effectiveness in meeting requirements or expected results. At Level 2-5 the supervisor provides administrative direction with assignments in terms of broadly defined missions or functions. The employee is responsible for independently planning, designing, and carrying out programs, projects, studies, or other work. The results of the work are considered technically authoritative and normally accepted without significant change. If the work is reviewed, the review concerns such matters as fulfillment of program objectives, effect of advice and influence of the overall program, or the contribution to the advancement of technology. Recommendations for new projects and alteration of objectives are usually evaluated for such considerations as availability of funds and other resources, broad program goals, or national priorities. Level 2-4 is met. The appellant is responsible for planning and accomplishing work related to the application of housing management program objectives and policies at her installation. She works independently and is considered the technical expert for the family housing program, and assignments are made based on consultation with the supervisor regarding the timeliness and scope of projects. She conducts her program within the policies, procedures, and objectives established by the agency for administering its housing program. She plans and carries out her assignments independently, resolving most conflicting issues that arise, interprets policies, and coordinates work with others as necessary. Level 2-5 is not met. The appellant operates under closer supervision than purely administrative as described at this level. Unlike Level 2-5, her work products, recommendations for new projects, or alteration of objectives are more closely reviewed. This factor is evaluated at Level 2-4 and 450 points are credited. Factor 3: Guidelines, Level 3-3, 275 points This factor covers the nature and extent of guidelines and the judgment needed to apply them. At Level 3-3 the employee is provided a number of agencywide regulations, standards, handbooks, guides, and other materials related to major housing activity areas. These materials are usually not directly applicable to specific work assignments, or they may lack sufficient detail on many elements of housing management operations on which to base management decisions and actions. The employee is required to use judgment and initiative in selecting, interpreting, and applying the guides and, where necessary, make compromises and adaptations within the intent of the guides to meet established housing objectives. The employee must also evaluate the impact of the application of standard agency practices and procedures on housing operations and recommend changes to address new or unique situations or correct deficiencies. At Level 3-4 the work is characterized by the availability of agency policies, general program management guides, and legal opinions or precedents related to the management, use, and operation of housing projects, facilities, and other resources. These guides are usually inadequate for dealing with the unusually difficult problems associated with the broad management planning typically encountered at this level. The employee is required to select, adapt, and apply housing policies and principles to assigned projects where precedents are not directly applicable to the coordination of work forces and resources, or the negotiation of major issues and conflicts normally required at this level. In addition, the employee must develop new operating techniques and use experienced judgment in selecting approaches and evaluating management programs and related housing trends or developments. Level 3-3 is met. The appellant is provided numerous Federal regulations, a number of Navy wide regulations, standards, handbooks, guides, and other materials applicable to the major aspects of administering the installation's family housing management program. These materials do not address all of the possible situations that the appellant routinely encounters in managing the family housing program. She uses judgment, initiative, and experience in selecting, interpreting, and applying the available guidance, making compromises and adaptations where warranted to resolve unusual problems encountered during the course of her work. The guidance provides a sufficient degree of flexibility for adaptation and interpretation to resolve problems encountered at the appellant’s organizational level. The appellant reviews proposed policies and procedures and recommends changes to existing procedures to accommodate new or unique situations. Level 3-4 is not met. The guidelines used by the appellant, while sometimes not directly applicable to specific assignments, are not entirely inadequate for dealing with unusually difficult problems. Most problems encountered can be resolved within the parameters described in existing guidelines, and precedents are available and applicable to resolve unusual issues. Additionally, the appellant is not responsible for the development of new operating techniques characteristic of this level. This factor is evaluated at Level 3-3 and 275 points are assigned. Factor 4: Complexity, Level 4-4, 225 points This factor covers the nature, number, variety, and intricacy of tasks, steps, processes, or methods involved in the management, operation, and use of housing assets and resources; the difficulty in identifying what needs to be done; and the difficulty and originality involved in performing the work. At Level 4-4 the work consists of continuing assignments involving direct responsibility for the management control of one or more housing projects, facilities, or complexes. It typically involves the application of the full range of methods and processes related to the planning, acquisition, construction, operation, occupancy, maintenance, improvement, and use of a variety of housing assets, including Government-owned, assisted, leased, rented, or privately-owned facilities. Decisions regarding what needs to be done require the assessment of such operations as project organization and fiscal management; reporting systems; furnishings, supplies and equipment; maintenance conditions and general housekeeping; occupancy and assignment activities; and tenant relations. The work usually requires assessment of such critical project activities as occupancy turnover rates, current and projected operating costs, utility conservation efforts and structural or physical condition of housing assets to formulate recommendations or directives governing housing operations and maintain control of allotment obligations and expenditures to ensure funding limitations are observed. The work also requires analysis of problem areas or deficiencies; determining the feasibility of improvements or repairs within established cost targets; and the development of recommendations and justification concerning funds, personnel, and materials to accomplish all housing activities. At Level 4-5, the work consists of assignments involving management planning, cost control and coordination of work forces and resources; negotiating with management and tenants on complex program matters and problems; and/or providing expert advisory services to management, technical, and supervisory personnel in the agency; in other government agencies, and in public or private institutions regarding housing management programs and the development, acquisition, operation and use of housing assets. Decisions regarding what needs to be done include the identification and definition of the nature and scope of novel and obscure problems that often require analysis and evaluation of such factors as general housing trends, market conditions, construction methods, material costs, sources of supply or services, housing prices, and/or applicable area ordinances, regulations, or laws governing the occupancy and operation of housing projects. Such factors are subject to continuous change resulting from national or regional housing policies or priorities, construction industry developments, utility cost fluctuations, and various other general business activities. The work requires the identification of the latest techniques, procedures, and concepts in the field of housing management to develop and appraise program policies and procedures; the research and analysis of altered management concepts or methodology and the extension of existing practices to new and unusual applications; and the conduct of novel and unprecedented studies to develop management criteria and prepare advisory materials on matters of regional or national importance. Level 4-4 is met. The appellant's work involves the application of the full range of methods and processes related to the management planning, operation, occupancy, maintenance, and utilization of the assigned housing facilities and other assets. The work also includes responsibility, during the planning phases, for the acquisition or construction of additional housing facilities. Decisions regarding what needs to be done include the assessment of problems encountered which can pertain to any and all phases of project management, such as in areas of occupancy and assignment, project maintenance, and tenant relations. Critical assignment problems can occur because of heavy influx of transferred personnel or long waiting lists of housing applicants. Similarly, problems may arise in the accomplishment of recurring maintenance work. The appellant must be alert for possible trouble areas to avoid discontent among tenants or local area residents, and must continually evaluate housing functions and data to identify variations or conflicts. Her work regularly requires making or approving decisions concerning such factors as maintaining optimum occupancy levels; evaluating operating and maintenance costs; planning, scheduling, and coordinating recurring maintenance work; analyzing current and projected utility costs or consumption and establishment of conservation methods; and monitoring or controlling expenditures to assure limits are observed. The appellant also develops proposals and justification for additional funds or materials to facilitate corrective measures deemed appropriate. Level 4-5 is not met. The appellant’s work assignments do not normally involve highly complex program issues and problems requiring her to identify and define novel or obscure problems characteristic of this level. She is not required to extend existing practices to new or unusual applications, or develop housing management criteria or prepare advisory material on matters of regional or national importance. Situations normally encountered by the appellant are not subject to continuous changes resulting from those factors cited at this level. Her assignments generally involve conventional situations, problems and issues that have been experienced before, either at the installation or at various other family housing locations. This factor is evaluated at Level 4-4 and 225 points are credited. Factor 5: Scope and effect, Level 5-3, 150 points This factor covers the relationship between the nature of the work in terms of the purpose, breadth, and depth of housing assignments, and the effect of work products or services both within and outside the organization. At Level 5-3, the purpose of the work is to plan, schedule, coordinate, and/or monitor the operational management and efficient use of housing projects, facilities, and resources; analyze problem areas; and recommend or implement corrective measures within the framework of housing program requirements. The work involves treating a variety of occupancy related problems, formulating directives, and evaluating the adequacy of services provided. It affects the efficiency of housing program operations and living conditions of those housed. At Level 5-4, the purpose of work is to provide expertise as a specialist in housing management techniques and methodology by furnishing advisory services to other agency organizations on specific problems, projects, programs, and functions. The work involves the development of management plans and criteria related to the application of agency housing policies. Work products affect major segments and activity areas of the agency’s housing policies and programs. Level 5-3 is met. The work involves planning and coordinating the management and use of housing, and treating a variety of housing problems at the installation. The appellant is responsible for ensuring that assigned housing activities conform with housing policies; serving as a technical expert in housing management in advising installation level officials on the methods, processes, and agency policies relating to housing management; monitoring the state and utilization of housing and related facilities; and analyzing problems and recommending solutions or implementing corrective actions for occupant related problems. Her work affects the efficient operation of the family housing services of the installation, and the living conditions of military personnel and their families. Level 5-4 is not met. The appellant’s position is not focused on development of management programs and criteria related to the application of the [agency's] housing policies, nor does it impact major segments and activities of the agency's housing policies and programs. The appellant is not responsible for providing advisory services on housing management to other [agency] organizations. This factor is evaluated at Level 5-3 and 150 points are assigned. Factor 6: Personal Contacts, Level 6-3, 60 points This factor includes face-to-face contacts, telephone or other dialogue with persons not in the supervisory chain. Levels described under this factor are based on what is required to make the initial contact, the difficulty of communicating with those contacted, and the setting in which the contact takes place. At Level 6-3 contacts are with a variety of management officials and representatives of public, private, and law enforcement agencies; housing committees; tenant action groups; contractor representatives; and officials of professional business organizations. On occasion, contacts are made with local groups and representatives of civic, welfare, or recreational organizations. They are held at the employee’s workplace or at the workplaces, meeting halls, conference facilities, or other locations available to the persons contacted. Level 6-4 contacts are with high ranking officials from outside the agency including Members of Congress, nationally recognized housing officials, State governors, city mayors, and presidents of large national firms. These contacts are usually in highly unstructured settings, conducted under a variety of different ground rules, and may be established during routine or unscheduled problem related visits, or at special investigative hearings, task group discussions, or other proceedings initiated by the persons contacted. Level 6-3 is met. The appellant's personal contacts are with individuals and groups from within and outside the [appellant's installation]. The contacts include a variety of management officials, housing personnel and committees, tenant groups, other installation program specialists, and contractor representatives. These contacts are made at the appellant's work place, or that of those contacted. Level 6-4 is not met. The appellant rarely if ever has personal contacts with those described at this level. This factor is evaluated at Level 6-3 and 60 points are credited. Factor 7: Purpose of Contacts, Level 7-3, 120 points This factor addresses the purpose of the personal contacts that were used as the basis for the level credited under Factor 6, above. Purpose of personal contacts ranges from factual exchange of information to situations involving significant or controversial issues and differing viewpoints, goals, or objectives. At Level 7-3 contacts are made to influence or persuade agency or local housing specialists, tenants, and local special interest committees or groups to accept plans, schedules, technical or policy requirements, and methods that have elements of conflict; to negotiate or mediate agreement among conflicting parties; to cooperate with and coordinate law enforcement efforts; or to justify the feasibility or validity of proposals concerning housing facilities or resources to agency officials or committees that are composed of housing specialists and others authorized to grant approvals. The persons or groups contacted may be skeptical or uncooperative, and such contacts may require skill in approach or methodology to obtain the desired effect. At level 7-4 the purpose is to justify, defend, negotiate, or settle significant or highly controversial matters pertaining to housing policies or programs. The work often involves presenting agency goals and objectives at professional conferences or committees convened to plan long range housing programs and develop standards and guides for broad activities. The work involves meeting with other experts having a variety of viewpoints or objectives on issues of considerable importance; presenting the agency’s rationale or position on specific problems; and participating in the problem solving process by negotiation, compromise, or developing suitable alternatives. The appellant's position meets Level 7-3. Like that level she must persuade tenants and local special interest committees to accept housing plans and schedules, changes in technical or policy requirements, and mediate agreements among conflicting tenants or other parties. She must exercise tact and skill in approach to persuade skeptical or uncooperative individuals or groups to accept various housing rules or program requirements. The appellant’s position does not meet Level 7-4. Unlike that level she is not required to justify, defend, or settle significant or highly controversial matters concerning housing policies or programs. She is not faced with meeting with experts to discuss and resolve issues of considerable consequence or importance to the agency, and presenting the agency's rationale on specific problems. This factor is evaluated at Level 7-3 and 120 points are assigned. Factor 8: Physical Demands, Level 8-1, 5 points This factor covers the requirements and physical demands placed on housing managers and others by the work assignments. This includes physical characteristics and abilities and the physical exertion involved in the work and, to some extent, the frequency or intensity of physical exertion required. The appellant’s physical demands meet Level 8-1 where the work is principally sedentary. Like that level, she typically works in an office or similar setting, but some walking, bending or standing is required. No special physical demands are required. The position does not meet Level 8-2 where the work requires some physical exertion, and long periods of standing or walking over uneven surfaces, climbing stairs, etc. This factor is evaluated at Level 8-1 and 5 points are assigned. Factor 9: Work Environment, Level 9-1, 5 points This factor covers the risks, discomforts, or unpleasantness that may be imposed upon employees by various physical surroundings, environmental conditions, or job situations including the use or wearing of safety equipment or devices associated with such conditions. The appellant's position meets Level 9-1 where the work involves normal risks or discomforts associated with an office environment. Like that level her work area is usually adequately lighted, heated, and ventilated. However, there may be occasional exposure to dusty or dirty conditions while visiting housing units or facilities undergoing repair, maintenance, or renovation. Unlike Level 9-2, she is not frequently exposed to moderate discomforts, risks, or unpleasantness such as high level noises and vibrations, dust and grease, irritant fluids or fumes, moving parts of machines, and external weather conditions. Her work does not require the use of protective garments or devices such as hats, masks, boots, goggles, or shields when visiting construction sites, most of which would be required for credit at Level 9-2. This factor is evaluated at Level 9-1 and 5 points are credited. Summary Factor Level Points 1. Knowledge required by the position 1-7 1250 2. Supervisory controls 2-4 450 3. Guidelines 3-3 275 4. Complexity 4-4 225 5. Scope and effect 5-3 150 6. Personal contacts 6-3 60 7. Purpose of contacts 7-3 120 8. Physical demands 8-1 5 9. Work environment 9-1 5 Total 2540 The appellant's position totals 2540 points which falls in the GS-11 range (2355-2750). Therefore, in accordance with the grade conversion table in the GS-1173 standard, her position is graded at GS-11. Decision The appellant's position is properly classified as Housing Manager, GS-1173-11.