U.S. Office of Personnel Management
Office of Merit Systems Oversight and Effectiveness
Classification Appeals and FLSA Programs

Philadelphia Oversight Division
600 Arch Street, Room 3400
Philadelphia, PA 19106-1596

Classification Appeal Decision
Under section 5112 of title 5, United States Code


	Appellant:		[appellant’s name]

	Agency classification:	Program Support Assistant (OA)
				GS-303-6

	Organization:		Community Care
				Geriatric and Long Term Care
		 		Service Line
				VA [name] Health Care System
				Department of Veterans Affairs
				[name] Division
				[location]

	OPM decision:		title at agency discretion (OA)
				GS-303-6
		
	OPM decision number:	C-0303-06-05


/s/ Robert D. Hendler

____________________________
Robert D. Hendler
Classification Appeals Officer

October 1, 2002
_____________________________
Date

As provided in section 511.612 of title 5, Code of Federal
Regulations (CFR), 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 (PCS’s), appendix 4,
section G (address provided in appendix 4, section H).

Decision sent to:

PERSONAL
[appellant’s name]
[appellant’s address]

Human Resources Officer
VA [name] Health Care System
Department of Veterans Affairs
[name] Division
[location]

Deputy Assistant Secretary for
 Human Resources Management (05)
Department of Veterans Affairs
810 Vermont Avenue, NW, Room 206
Washington, DC 20420


Introduction

On June 21, 2002, the Philadelphia Oversight Division of the U.S.
Office of Personnel Management (OPM) accepted a classification
appeal from [appellant’s name]. We received the complete appeal
administrative report on July 11, 2002. Her position is
currently classified as Program Support Assistant (OA), GS-303-6.
The appellant believes the classification should be Management
Assistant, GS-344-7. The position is in the Community Care,
Geriatric and Long Term Care Service Line, VA [name] Health Care
System ([acronym]), Department of Veterans Affairs, [name]
Division, [location]. We have accepted and decided her appeal
under section 5112 of title 5, United States Code (U.S.C.).

General issues

The appellant included a copy of a position description (PD) and
an automated evaluation statement produced by the COHO automated
classification system classified as Management Assistant, GS-344-
7, in the appeal forwarded by the appellant’s agency to OPM. The
documents referring to that PD were signed by the appellant and
her first- and second-level supervisors as part of a process
seeking to promote the appellant. However, this PD is not the
same PD of record (#[number]) certified as current and accurate
by the appellant and her first-level supervisor and provided by
the agency as part of the appeal administrative report.

The appellant stressed the increase of her workload and new
functions that she performs. She disagreed with how her agency
evaluated her position and said that her work is not controlled
by a position at the Baltimore Division (Administrative Support
Assistant, GS-303-7, PD #[number]). She also stated that another
position at the Baltimore Division (Program Support Assistant
(OA), GS-303-6, PD #[number]) was improperly credited with
support for the Community Nursing Home (CNH) program for which
the appellant is responsible. She provided copies of these PD’s
in her appeal request.

The appellant’s rationale points to the description of work in
her proposed PD. However, agency management and the appellant
have certified that the PD of record is accurate. A PD is the
official record of the major duties and responsibilities assigned
to a position by an official with the authority to assign work.
A position is the duties and responsibilities that make up the
work performed by an employee. Position classification appeal
regulations permit OPM to investigate or audit a position and
decide an appeal on the basis of the actual duties and
responsibilities assigned by management and performed by the
employee. An OPM appeal decision grades a real operating
position and not simply the PD. Therefore, this decision is
based on the actual work assigned to and performed by the
appellant.

By law, we must classify positions based solely by comparing
their current duties and responsibilities to OPM PCS's and
guidelines (5 U.S.C. 5106, 5107, and 5112). Other methods or
factors of evaluation are not authorized for use in determining
the classification of a position, such as comparison to positions
that may or may not have been properly classified or comparing
the work that the appellant currently performs with the work that
she previously performed. The quantity of work performed is not
germane to the classification process. Because our decision sets
aside all previous agency decisions, the appellant’s concerns
regarding her agency’s classification review process are not
germane to this decision.

Implicit in the appellant’s rationale is a concern that her
position is classified inconsistently with other positions. Like
OPM, the appellant's agency must classify positions based on
comparison to OPM PCS's and guidelines. Section 511.612 of 5
CFR, requires that agencies review their own classification
decisions for identical, similar, or related positions to ensure
consistency with OPM certificates. Thus, the agency has the
primary responsibility for ensuring that its positions are
classified consistently with OPM appeal decisions.

PD #[number] contains duties that are substantially different
from those listed in the appellant’s PD of record, e.g., “primary
administrative support to the Program Manager and staff for all
Community Care programs.” The appellant has called into question
the accuracy of the PD #[number]. If the appellant believes that
her position is classified inconsistently with those positions,
she may pursue this matter by writing to her agency headquarters
human resources office. In so doing, she should specify the
duties and responsibilities of the positions in question. The
agency should explain to her the differences between her position
and the others, or grade those positions in accordance with this
appeal decision.

Position information

The appellant provides administrative and program support to the
Contract Adult Day Health Care (CADHC) for the [acronym].
Vendors provide services on a contract basis. She tracks program
expenditures, provides current and projected budget reports to
her supervisor for program planning purposes, and certifies
monthly invoices submitted by contract facilities providing
services for payment. She works closely with other [acronym]
components to resolve problems and ensure smooth operations. The
appellant answers questions on eligibility. She deals directly
with her supervisor on requests for services, arranges for social
workers to conduct contract facility inspections, and performs
other related support duties.

She provides similar support services for the Homemaker/Home
Health Aide (H/HHA) program. The appellant receives referrals
from physicians, social workers, and nurses authorizing care and,
in conjunction with her supervisor, establishes the number of
hours of care authorized based on the diagnosis and care needed.
Financial and contract program functions are similar to the CADHC
program. She follows up on family member complaints on the
quality of care and, after sharing her findings with her
supervisor, may arrange for services from a different provider.

The appellant performs similar work for the CNH program. Based
on referral information from care authorizers, she ascertains
level of care and determines proper per diem rate and proper
rates for additional types of care, e.g., ulcer care, infusion
therapy, tube feeding, and medication. The appellant assures
that lengths of placement are correct based on percentage of
service connected disability and that other program requirements
are met. She discusses eligibility and service limitations with
patients’ families. As necessary, she arranges for bed holds for
patients that are sent to private hospitals for treatment.

She provides more limited support services for the [name]
Community Residential Care (CRC) program. The appellant manages
the flow of referrals, tracks program information, and generates
monthly reports. She does not provide program budget support.

The appellant prepares reports and correspondence for the CNH,
CRC, H/HHA and CADHC programs. She monitors educational
requirements for the staff of approximately six to eight
employees who report to her supervisor. She uses International
Merchant Purchase Authorization Cards to purchase supplies for
the program.

We conducted a telephone audit with the appellant on August 29,
2002, and a telephone interview with her supervisor, [name], on
September 3. To clarify information in the record, we conducted
telephone interviews with the appellant’s second level
supervisor, [name], on September 19, and on September 23 with
[name], VISN Business Manager for the Geriatrics and Long Term
Care Line. The PD of record contains the major duties and
responsibilities assigned by management and performed by the
appellant. In deciding this appeal, we fully considered the
audit and interview findings and all information of record
furnished by the appellant and her agency, including her official
PD which we incorporate by reference into this decision.

Series, title, and guide determination

The agency has classified the position in the Miscellaneous Clerk
and Assistant Series, GS-303, titled it Program Support Assistant
(OA) because it requires competitive keyboard skills, and
determined that it is properly graded by application of the Grade
Level Guide for Clerical and Assistance Work (Guide). The
appellant believes that she is performing Management Assistant,
GS-344, work classified by application of the Management and
Program Clerical and Assistance Series, GS-344 PCS. In support
of her appeal, she states that planning for the number of
patients that can be supported in each program area and other
program monitoring constitutes program analysis.

The GS-344 series includes positions that support management and
program analysis. Management and program analysis are staff
functions. The purposes of those programs are to evaluate and
improve the efficiency, effectiveness, and productivity of
organizations and programs. GS-344 work requires a practical
knowledge of the purposes, methods, and techniques of management
and/or program analysis and the structures, functions, processes,
objectives, products, services, resource requirements, and
similar features of Government programs and organizations.

The appellant does not work in a staff office supporting staff
management and/or program analysis functions. She provides
technical and administrative support to a VAMHC operating
function; i.e., Community Care. Therefore, her position is
covered under Exclusion #1 in the GS-344 PCS which excludes
positions that perform clerical or technical support work in
various administrative services essential to the management,
direction, and operation of an organization, e.g., travel,
procurement, budget, personnel, safety, security, and property
and facility management.

The appellant’s position is covered by the GS-303 series. This
series includes positions that perform clerical, assistant, or
technical work for which no other series is appropriate. The
work requires knowledge of the procedures and techniques involved
in carrying out the work of the organization and involves
applying procedures and practices within the framework of
established guidelines. Typical of this series, the appellant’s
work requires knowledge of various community care program and
related budget practices and procedures, and general
administrative support procedures including purchase card
procurement, and using office automation (OA) software packages.

There are no published grade-level criteria for the GS-303
series. The Introduction to the PCS’s states that when there is
no directly applicable PCS, a position should be classified using
criteria that are comparable in scope and difficulty and that
describe similar subject matter and functions. We find that the
appellant’s work is best evaluated by application of the grading
criteria in the Guide for grade level analysis of her program
work. Administrative program support work of the kind described
in the Guide is performed in offices, shops, laboratories,
hospitals, and numerous other settings in all Federal agencies.
Because the GS-303 PCS does not have published titles, the agency
may construct a descriptive title using the titling practices in
the Introduction to the PCS’s using the parenthetical OA to
reflect the qualification requirement.

Grade determination

The Guide describes the general characteristics of each grade
level from GS-1 through GS-7 and uses two evaluation factors for
grading purposes: Nature of assignment (which includes the
knowledge required and complexity of the work) and Level of
responsibility (which includes supervisory controls, guidelines,
and contacts).

Nature of assignment

The appellant’s rationale stresses the increased difficulty and
complexity of her budget and related work. She states that until
2000 each program was allotted a set amount of money each month
and that her work was limited to dealing with increases and
decreases. However, since that time she compiles this
information for budget estimates, reconciles the budget, creates
spreadsheets monthly for statistical analysis, and reconciles the
invoices for each program monthly. The appellant says that she
is asked to create estimates for the next year’s budget,
determine the impact of new or updated contracts on the budget,
compile contract information for each program and distribute the
information to appropriate staff members who use each program.
The appellant’s rationale paraphrases selected portions of the
Guide’s description of the GS-7 work. For example, she says that
she evaluates the appropriateness of justifications for changes
in clerical staffing levels. Our fact-finding revealed that the
appellant equates determining the number of day care placements
that she can make within program resources with determining
changes in staffing work load. She says that she must create her
own guidelines for each program and adapt any new changes to meet
current guidelines and that implementing a decision to decrease
the maximum number of hours of home health care due to a budget
shortfall reflects interpreting guidelines as defined at the GS-7
grade level.

As at the GS-6 grade level, the appellant’s work requires
considerable evaluative judgment within well-defined, commonly
occurring aspects of an administrative program or function. She
performs continuing CRC, H/HHA, CADHC, and CNH program processes
based on direct application of established policies, practices,
and criteria. For example, current year H/HHA services provide
for up to 10 hours of services per patient each week. Based on
the diagnosis and medical care needed, the appellant works with
her supervisor to determine the number of hours to authorize.
The supervisor retains approval authority. Typical of the GS-6
grade level, the appellant identifies issues, problems, or
conditions and seeks alternative solutions based on evaluation of
the intent of applicable rules, regulations, and procedures. For
example, patients are accepted on a first-come, first-serve
basis. However, the appellant assures that authorized deviations
to that procedure are handled properly, e.g., providing services
to seriously ill patients who likely will remain in the program a
short time.

Although her assignments involve a full range of case situations,
they are themselves part of a single specialized program; i.e.,
Community Care, within the broader function of Geriatrics and
Long Term Care. As at the GS-6 grade level, the assignments
requiring evaluative judgment are narrowly focused, address a
single product or action, are relatively clear cut, and resemble
past problems or situations, e.g., screening CNH cases to
determine whether the level of care will be light, moderate, or
heavy; responding to complaints about H/HHA provider personnel;
and reconciling funds monthly to identify potential trends.
Typical of this grade level, work often involves problems or
situations where there is not one absolutely correct solution,
only a best or most appropriate one, e.g. determining the number
of H/HHA hours to provide based on diagnosis and care need. The
work requires practical knowledge of guidelines and precedent
case actions relating to each program area acquired through
considerable work experience, and requires skill to recognize the
dimensions of a problem and express ideas in writing, e.g., using
spreadsheet information to project funds use based on current and
projected patient population.

The budget and related functions performed by the appellant
compare closely with those in the Guide’s GS-6 grade level
illustration. The illustration describes a position that runs a
statistical reporting and records systems for a major division of
a regional office. The division is a relatively stable
organization that does not have widely diverse functions. The
employee consolidates annual funding estimates from subordinate
offices into a complete budget request for the division;
organizes estimates by appropriation, object class, and line item
following current budget instructions; and prepares required
supporting documentation for expenditures such as employee
travel, training, and office equipment and supplies. Funding
requirements for the division are relatively stable from year to
year. The work requires an in-depth practical knowledge of the
division's activities, operations, and established guidelines
relating to work measurement functions, statistical reporting and
records systems, and the budget process. The work also requires
skill to compile and summarize information and data, identify
inaccuracies or anomalies in the information, and make written
recommendations to resolve discrepancies based on interpretation
of applicable regulations and procedures. The employee must
extract and analyze a considerable volume of information to
arrive at an end product. Although the appellant does not
compile budget requests from subordinate offices, her review of
monthly, year-to-date expenditures to project rest-of-year
status, and her use of historical information to project the next
funding year’s needs present equivalent analytical demands.

The appellant’s work does not meet the GS-7 grade level which
consists of specialized duties with continuing responsibility for
projects, questions, or problems that arise within an area of a
program or functional specialty as defined by management.
Assignments involve a wide variety of problems or situations
common to the segment of the program or function for which the
employee is responsible. Each assignment typically consists of a
series of related actions or decisions prior to final completion
based on the development and evaluation of information that comes
from various sources. The work involves identifying and studying
factors or conditions and determining their interrelationships
and taking or recommending actions that are consistent with the
objectives and requirements of the program or functions. The
work requires knowledge and skill to recognize the dimensions of
the problems involved, collect the necessary information,
establish the facts, and take or recommend action based upon
application or interpretation of established guidelines and
practical knowledge of the operations, regulations, principles,
and peculiarities of the assigned program, function, or activity.

Illustrative of such work is advising the manager of a single-
function field office on the practical and technical aspects of
office administration including budgeting, purchasing, supply
management, personnel administration, data processing, and files
management and performing staff support work in each of these
areas. The employee collects data for the office operating
budget, reviews submissions of office staff assistants for proper
format and compliance with agency budget requirements, and
consolidates material into an annual office budget; sets up
controls to monitor expenses during the year; and recommends
budget adjustments including restructuring budget allocations or
work plans to deal with changing situations such as varying costs
for equipment parts, or services, and changes in the availability
of funds. The employee updates the office's supply sources
catalogues; purchases supplies, equipment, and services through
open market purchase by blanket agreement, cash or field purchase
order, or similar methods; processes and tracks purchase
documents; completes requests for personnel actions and writes
PD’s; and distributes forms and instructions for annual
performance ratings and ensures timely and proper completion.
The work includes conducting local recruitment and holding new
employee orientation sessions and maintaining and revising the
office filing system. The employee collects program information
from technical specialists, enters it into electronic or manual
information systems, and searches for it as requested; schedules
use and maintenance of computer equipment; enters and retrieves
information from a variety of systems; and helps field office
employees use the various computer systems.

The employee maintains and transfers funds between several
unrelated appropriated fund accounts and several revolving fund
accounts. The accounts are subject to different regulations and
procedures. The work also involves initiating personnel actions
and tracking virtually all financial, personnel, supply, and
other administrative transactions as the documentation flows
through the office in both electronic form and on paper. The
work requires general knowledge of the mission and functions of
the field office and an understanding of how the office's various
administrative services relate to one another and how they relate
to the office's mission. The work also requires broad
understanding and detailed procedural knowledge of budget,
purchasing, personnel, and information processing functions of
the field office to recognize the dimensions of the problems
involved, collect the necessary information, establish the facts,
and take or recommend action based upon application or
interpretation of established guidelines and practical knowledge
of the operations, regulations, principles, and peculiarities of
the assigned program, function, or activity.

As discussed previously, the appellant’s program support
functions, from entitlement advice and review to screening of CNH
invoices for proper charges, involve applying similar practices
and procedures for each patient service program. Her budget
functions do not involve supporting the wide range of program
functions covered by separate appropriations, a mix of
appropriated and revolving fund accounts working under different
financial regulations and procedures, or budget consolidation and
reprogramming analysis and recommendations found at the GS-7
grade level. Instead, higher level program and business
management staff analyze and make decisions on reprogramming
based on the appellant’s projections on anticipated expenditures
of projected client load and usage. The appellant implements
those changes and assures that they are communicated to [acronym]
personnel who authorize patient services. Although the appellant
processes and tracks virtually all financial, personnel, supply,
and other administrative transactions for the office, those
functions are for an organization substantially more limited in
administrative complexity than illustrated at the GS-7 grade
level. Her duties do not include the more demanding
administrative functions illustrated in the Guide, e.g.,
conducting local recruitment, holding formal employee orientation
sessions, and helping field office employees use various computer
systems. Arranging for home health care visits is not equivalent
to analyzing workload and determining the need for additional
clerical staff to provide administrative support in a multi-
component field office. Implementing changes in hours of
services and per diem rates and tracking their impact on funds
usage is not equivalent to budget analysis and reprogramming for
the more complex administrative support functions illustrated at
the GS-7 grade level. The appellant’s decisions on home health
visits, calculation of proper payments based on contract per diem
and other charges specific to each patient, providing information
on and ascertaining entitlement to services, projecting budget
status based on anticipated patent use and similar work functions
do not involve the more demanding problems, questions, and issues
and their greater analytical demands found at the GS-7 grade
level. Accordingly, this factor is evaluated at the GS-6 grade
level.

Level of responsibility

The appellant works with the freedom from supervision typical of
the GS-6 grade level. As at that grade level, the appellant’s
supervisor assists with precedent assignments by interpreting
policy, e.g., program changes that result in an increase or
decrease of hours of care that may be authorized for patients and
changes in contract rates. 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 appellant uses judgment in interpreting and
adapting guidelines for application to specific cases or
problems, e.g., screening CNH cases to determine level of care
and additional medical services that need to be funded. The
appellant bases her decisions and recommendations on facts and
conventional interpretations of guidelines rather than on theory
or opinion. She 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, e.g.,
contacting her supervisor when a facility reports that a patient
requires a change in level of care.

The appellant’s work situation compares closely to the GS-6 grade
level illustration in which the supervisor makes assignments by
defining objectives, priorities, and deadlines. The appellant
independently gathers data, prepares reports, and makes
recommendations consistent with normal practice, using experience
in solving problems and handling unusual occurrences, e.g., using
a different home health agency in response to a service
complaint. Her completed work is evaluated for appropriateness
and effectiveness, e.g., the appellant’s supervisor makes the
final decision on the number of patients that can be supported
based on budget projections. The supervisor and users of the
data are available to provide advice if significant changes in
operations or data requirements occur. Guidelines include
manuals on the budget process as well as general guidance on
management reporting techniques. The appellant uses judgment in
interpreting rather general guidelines to prepare reports,
evaluate compliance with work measurement requirements, and
develop findings, recommendations, and justifications, e.g.,
developing detailed budget estimates based on current and
historical patient use. Contacts are with co-workers and users
of the information to exchange information, present findings, and
improve reporting and budget development methods and are usually
cooperative, e.g., contacts with higher level program people to
provide and discuss budget projections.

In contrast, at the GS-7 grade level the supervisor makes
assignments in terms of objectives, priorities, and deadlines.
The employee independently completes assignments using accepted
practices and resolves most conflicts that arise. Completed work
is evaluated for appropriateness and conformance to policy. The
employee encounters a wide variety of problems and situations
which require choosing alternative responses. Guides such as
regulations, policy statements, and precedent cases tend to be
general and descriptive of intent, but do not specifically cover
all aspects of the assignments and apply less to specific actions
and more to the operational characteristics and procedural
requirements of the program or function. The employee must use
significant judgment and interpretation to apply the guides to
specific cases and adapt or improvise procedures to accommodate
unusual or one-of-a-kind situations. He or she serves as a
central point of contact to provide authoritative explanations of
requirements, regulations, and procedures and to resolve
operational problems or disagreements affecting assigned areas.

Illustrative of such work is functioning as the office support
advisor previously described when the supervisor makes
assignments by defining objectives, priorities, and deadlines.
The employee works independently, using a general understanding
of the expected outcomes and the scope of the assignments, and
draws upon experience in resolving the more difficult situations
that occasionally arise. The work is reviewed for technical
accuracy, soundness of judgment, and adherence to program
requirements and objectives. The employee uses a large number of
guidelines covering the various aspects of the job. The work
requires judgment in selecting the correct part of the most
appropriate guideline to apply to each of a large variety of
actions, such as budget estimates, tracking annual spending, and
initiating personnel actions. When guidelines change, the
employee may obtain assistance, as needed, from staff specialists
at a higher echelon. Most of the time, the employee follows
procedures, formats, and practices specified in agency
supplements to broad, Governmentwide guidelines. However,
situations often arise which are not specifically covered by
guidelines, requiring the employee to apply general principles to
specific situations. Contacts involve developing and exchanging
information, resolving operating problems and making
recommendations. The contacts are usually cooperative, but there
may be disagreements as to the facts in a case, or disagreements
on the interpretation or application of regulations and
guidelines to specific situations.

Unlike the GS-7 grade level, the appellant preponderantly deals
with cases and scheduled developing assignments, e.g., monthly
budget spreadsheets, rather than broad program objectives,
priorities, and deadlines. Her budget support responsibilities
tracking and projecting future current year use based on past
history do not involve the extensive reprogramming flowing from
changing program situations typical at the GS-7 grade level.
Program regulations and policy statements primarily apply to
specific actions, e.g., how to determine CNH level of care for a
specific patient, rather than to operational characteristics and
procedural requirements of the program or function typical at
this grade level. Unlike the GS-7 grade level, the appellant’s
supervisor makes final determinations of service based on her
analysis of clinical needs. While the appellant serves as a
central point of contact to provide explanations of requirements,
regulations, and procedures to patients and their families, her
supervisor is tasked with resolving operational problems or
disagreements because they are primarily clinical or equivalent
in nature, e.g., authorizing changes in level of care because the
patient can no longer feed him or herself or following up on
charges that a home health worker stole money from a patient.
Accordingly, this factor is evaluated at the GS-6 grade level.

Summary

In summary, since both factors are credited properly at the GS-6
grade level, we find that the appellant’s position is properly
evaluated at the GS-6 grade level.

Decision

The appellant’s position is properly classified as GS-303-6 with
the title at the agency’s discretion, to include the
parenthetical (OA).