Washington, DC

U.S. Office of Personnel Management
Classification Appeal Decision
Under section 5112 of title 5, United States Code

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Damon B. Ford
Classification Appeals and FLSA Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance


02/16/2022

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Date

As provided in section 511.612 of title 5, Code of Federal Regulations (CFR), this decision constitutes a certificate which 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 (Introduction), appendix 4, Section G (address provided in appendix 4, section H).

Introduction

The appellant’s position is currently classified as Security Specialist, GS-0080-09, but she believes it should be graded at the GS-11 level.  The appellant is assigned to Plans, Training, Operations, and Security (PTOS), Operations and Readiness Division (ORD), Irwin Army Community Hospital (IACH), U.S. Department of the Army (DA), at Fort Riley, Kansas.  We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

General issues

The appellant makes various statements about her agency’s evaluation of her position and compares some of her duties and responsibilities to higher-graded positions in her agency.    In adjudicating this appeal, our responsibility is to make an independent decision on the proper classification of her position.  By law, we must classify positions solely by comparing their 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 other positions that may or may not be properly classified as a basis for deciding her appeal.  Because our decision sets aside any previous agency decisions, the appellant’s statements regarding the classification practices used by her agency to classify her position are not germane to the classification appeal process.

The appellant cites an increase in the volume of the work she performs and an upgrade in her security clearance level from secret to top secret as support for her requested increase to the GS-11.  However, neither the volume of work performed, nor a position’s security clearance level can be considered when determining the grade of a position (The Classifier’s Handbook, chapter 5).

Position information

Both the appellant and her acting supervisor certify that her official position description (PD) number EM319000 accurately describes the major duties and responsibilities of her position.  However, while we agree it accurately describes the nine factors, we note a discrepancy in the level and number of points assigned to Factor 8, Physical Demands.  The PD shows Level 8-2 assigned with 20 points credited which conflicts with the Fort Riley Civilian Personnel Advisory Center (CPAC) evaluation assigning Level 8-1 and crediting 5 points.  Nevertheless, the total points assigned in the PD agrees with the CPAC evaluation.  While not a substantive error, the agency should correct it to conform with the CPAC evaluation of this factor. 

Fort Riley, Kansas is a United States Army Forces Command (FORSCOM) installation and the home of the Army's 1st Infantry Division.  IACH is a 47-bed hospital located within Fort Riley, which provides a variety of medical and behavioral health care to active and retired military personnel and their families.

The appellant spends approximately 90 percent of her time providing administrative and technical support for IACH’s personnel security clearance program.  She provides technical guidance to ensure consistent interpretation and implementation of existing personnel security policies and guidelines; develops and updates IACH’s standard operating procedures (SOPs) and policies for IACH’s personnel security program, and coordinates with and advises IACH management concerning the development and implementation of personnel security policies and procedures for IACH and tenant activities. 

The appellant reviews and processes a wide variety of requests for background and personnel security investigations (i.e., Tier 1, Low Risk, Non-Sensitive, Physical/Logical Access; Tier 2, Moderate Risk, Public Trust; Tier 3, Non-Critical sensitive, Confidential and Secret Information; Tier 4, High Risk, Public Trust; Tier 5, Critical Sensitive, Special Sensitive, Top Secret, and Sensitive Compartmented Information), and special access requirements for military, civilian and contract personnel (i.e., applicants) assigned to IACH and ancillary commands, such as Dental Command (DENTAC), Warrior Transition Battalion (WTB), Veterinary Services (VET SRVCS), and facilities at Rock Island, Illinois.

The appellant interviews applicants, obtains fingerprints, conducts local investigations and background check for security levels and clearances, prepares applications (i.e., Official Personnel File, Criminal Investigation Division (CID), Provost Marshal Office, Medical Record, and OPM documents); recommends eligibility of interim clearances; conducts follow-up interviews, investigations, and fingerprinting when directed by current guidelines; and forwards rebuttal packets to the Central Clearance Facility for further consideration.

The appellant conducts Joint Personnel Adjudication System (JPAS) and Defense Clearance and Investigations Index (DCII) screenings and requests criminal history checks for personnel who require immediate verification of security status but lack documentary proof of clearances and investigations.  She follows established protocol when authorizing access to restricted areas for domestic and foreign visitors.  The appellant also identifies potential security concerns associated with adverse or derogatory personal information and recommends appropriate actions such as downgrading an employee’s security clearance or limiting or revoking access to classified areas of the facility for personnel with expired clearances.

The appellant ensures all periodic reinvestigations (PR) are conducted in accordance with established guidelines and notifies applicable military, civilian and contract personnel concerning PR requirements.  She also serves as the account manager/system administrator for a variety of electronic investigative systems and databases, such as the JPAS, DCII, Investigative Records Repository (IRR), and Electronic Questionnaires for Investigations Processing (e-QIP); and maintains all computerized personnel roster and security folders, e.g., Security Clearance Access Roster (SCAR).

The appellant spends approximately 10 percent of her time serving as an Alternate Classified Document Custodian for IACH which includes duties such as uploading and maintaining IACH’s classified and accountable documents and other related media materials and providing guidance on use of Secured Terminal Equipment (STE), classified computer (SIPRNET), digital combination safes, secure fax, and other equipment and devices that protect IACH’s sensitive and confidential information.

In reaching our classification decision, we have carefully reviewed all information provided by the appellant and her agency, including her official PD which we incorporate by reference into this decision.  In addition, to help decide the appeal, we conducted separate telephone interviews with the appellant and her acting supervisor, as well as subsequent telephone and e-mail communications.

Series, title, and standard determination

The agency classified the appellant’s position in the Security Administration Series, GS-0080, titling it Personnel Security Specialist and the appellant does not disagree and we concur.   Positions in the GS-0080 series are evaluated by reference to the grading criteria in the position classification standard (PCS) for Security Administration, GS-0080.  Our evaluation of the grade level of the appellant’s position follows.

Grade determination

The GS-0080 PCS uses the Factor Evaluation System (FES), which employs nine factors.  Under the FES, each factor-level description in a FES 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, unless an equally important aspect that meets a higher level balances the deficiency.  Conversely, the position may exceed those criteria in some aspect and still not be credited at a higher level.  Each factor level has a corresponding point value.  The total points assigned are converted to a grade by use of the grade conversion table in the PCS.

The agency credited Level 1-6 for Factor 1, Knowledge Required by the Position; Level 2-3 for Factor 2, Supervisory Controls; Level 3-3 for Factor 3, Guidelines; Level 4-3 for Factor 4, Complexity; Level 5-3 for Factor 5, Scope and Effect; Level 6-3 for Factor 6, Personal Contacts; Level 7-2 for Factor 7, Purpose of Contacts; Level 8-1 for Factor 8, Physical Demands; and Level 9-1 for Factor 9, Work Environment.  The appellant disagrees with her agency’s assignment of Levels 2-3 for Factor 2 and 4-3 for Factor 4, believing they should be assigned Levels 2-4 and 4-4 respectively.  After careful consideration of all available information, we concur with the agency’s evaluation of Factors 1, 3, 5, 6, 7, 8 and 9.  Therefore, our analysis focuses on Factors 2 and 4.

Factor 2, Supervisory controls

This factor covers the nature and extent of direct or indirect controls exercised by the supervisor, the employee’s responsibility, and the review of completed work.

At Level 2-3, the supervisor defines the employee's scope of responsibilities and the objectives, priorities, and deadlines.  The employee is provided with more detailed assistance in unusual situations which do not have clear precedents.  The employee plans and carries out the steps involved, handles deviations from established procedures, and resolves problems that arise in accordance with agency or local standards, previous training, and experience, established practices, or other appropriate security controls.  Projects typically involve conflicting interrelationships between security and subject-matter requirements requiring investigation and solution by the employee to determine the methods and procedures to use in the assignment.  Completed work is usually evaluated for technical soundness and appropriateness in relation to the nature and level of security required by the controlled materials, information, or facility involved.  Techniques used by the employee during the course of the assignment are not usually reviewed in detail.

At Level 2-4, the supervisor sets the overall objectives and decides on the resources available.  The employee consults with the supervisor in determining which projects to initiate, develops deadlines, and identifies staff and other resources required to carry out an assignment.  The employee, having developed expertise in the particular security specialty area, is responsible for planning and carrying out the work, resolving most of the conflicts that arise, integrating and coordinating the work of others, and interpreting policy in terms of established objectives.  The employee keeps the supervisor informed about progress, potentially controversial matters, or developing security conditions or requirements with far-reaching implications.  Finished work is reviewed from an overall standpoint in terms of feasibility, compatibility with other security program requirements, or effectiveness in meeting objectives and achieving expected results.

Level 2-3 is met.  Like Level 2-3, the supervisor defines the scope of responsibilities, objectives, priorities, and deadlines for the appellant’s ongoing assignments.  The appellant independently carries out the multiple steps and processes involved in security and background investigations and resolves problems that arise in accordance with established Federal regulations, and IACH and DA practices, controls, and protocols.  Comparable to Level 2-3, upon completion of individual personnel security and background investigations, the appellant provides the results of electronic background checks and investigations and provides recommendations to her supervisor and other IACH officials to determine whether an employee, student, or Federal contractor poses a security risk to IACH.  Similar to Level 2-3, the appellant’s completed work products, including investigation results and recommendations, are reviewed by her supervisor for technical soundness, adherence to prescribed procedures, and timeliness.  Like Level 2-3, the supervisor does not typically review in detail the methods and techniques used by the appellant to perform her daily work.

Level 2-4 is not met.  Unlike level 2-4, the supervisor’s control of the appellant’s position is more structured than simply setting overall objectives and deciding on which resources are available.  For example, the appellant is required to attend daily meetings with the acting supervisor who assigns and discusses work and receives progress reports from the appellant.  Unlike Level 2-4, neither the appellant nor the supervisor determines which projects to initiate, nor are they responsible for developing deadlines for the completion of background and security investigations.  Instead, the type and quantity of investigations is based solely on the number of requests received; the type of work being performed (administrative, medical professional, etc.); and which agency program, computer systems, offices, and building each IACH employee, student, and Federal contractor will need to access in order to perform their work.  Contrary to Level 2-4, the appellant does not interpret DA or IACH policy in terms of established objectives.  Instead, she closely follows established guidelines and seeks guidance and direction from her supervisor or an appropriate agency official if she has questions concerning interpretation and implementation of established guidelines.  Unlike Level 2-4, the appellant is not assigned supervisory or work leader responsibilities and is not responsible for integrating or coordinating the work of others.  Unlike Level 2-4, in which the supervisor examines the employee’s work only in terms of overall feasibility, effectiveness, and compatibility with other security program requirements, supervisory review of the appellant’s work is more structured and regimented and includes elements such as technical soundness, adherence to prescribed procedures, and timeliness.  

This factor is evaluated at Level 2-3 and 275 points are assigned.

Factor 4, Complexity

This factor covers the nature, number, variety, and intricacy of tasks, steps, processes, or methods in the work performed; the difficulty in identifying what needs to be done; and the difficulty and originality involved in performing the work.

At Level 4-3, employees perform various duties requiring the application of different and unrelated methods, practices, techniques, or criteria.  Assignments characteristic of this level include: developing alternate security plans for a facility which describe options in levels of protection and the costs involved for a Federal or private sector facility where the minimum protection requirement is well-defined and accepted techniques are appropriate; adjudicating security clearance requests involving mixtures of such things as derogatory information, applicants or employees with hard to get skills, and management willingness to accept a nominal security risk; defining information storage requirements involving mixes of classified information requiring separate controls for access; or developing security plans involving separate, although similar, protective systems for communications and ADP facilities requiring separate security considerations within an established physical and information security protection system. 

Employees at Level 4-3 compile, analyze, and summarize information relating to the designated security requirements; develop plans for approaches that may be taken; define the level of risk involved for each plan; develop the costs for implementing each of several options; and recommend a course of action to meet assignment objectives.  The work requires consideration of program plans, applicable policies, regulations and procedures, and alternative methods of implementing and monitoring security requirements. Employees identify and analyze relationships among organizational needs and objectives, costs, requirements of security guides, and related information in reports such as mission statements, levels of guard or police protection available, personnel skill requirements, and facility plans.  Recommendations concerning the implementation of specific security systems and alternatives are based on factual information such as funding available, minimum regulatory requirements, delegated authorities to local managers to accept different levels of risk, and others that define the range of acceptable security decisions, programs, or systems related to the assignment.

At Level 4-4, employees perform assignments consisting of a variety of security duties involving many different and unrelated processes and methods relating to well-established areas of security planning and administration.  Typically, such assignments concern several broad security program areas or, in a specialty area, require analysis and testing of a variety of established techniques and methods to evaluate alternatives and arrive at decisions, conclusions, or recommendations.  Programs and projects may be funded by, or under the cognizance of, different organizations with differing security requirements or variations in ability to fund system implementation.  The implementation of established security policies, practices, procedures, and techniques may have to be varied for a number of locations or situations which differ in kind and level of security, complexity, and local conditions or circumstances requiring adjustment or modification in established approaches.  Implementation of the results of analysis may have to be coordinated with other organizations and security systems to assure compatibility with existing systems and demands on available resources. 

In deciding what is to be done, employees at Level 4-4 typically assess situations complicated by conflicting or insufficient data, evidence, or testimony which must be analyzed to determine the applicability of established methods, the need to digress from normal methods and techniques, the need to waive security and investigative standards, or whether specific kinds of waivers can be justified.  Employees make many decisions involving the interpretation of considerable data; application of established security methods, equipment, techniques, and objectives to a variety of situations with variations in the level of security required; and ability to meet or exceed minimal acceptable levels.  The employee plans the work, develops recommendations, and refines the methods and techniques to be used.

Level 4-3 is met.  Like Level 4-3, the appellant uses a variety of different and unrelated methods and criteria to perform background investigations (e.g., National Agency Check (NAC), National Agency Check with Inquiries (NACI), National Agency Checks with Credit (NACLC), Periodic Reinvestigation-Secret (PR-S), Initial Secret Investigations (ANACI), and Single Scope Background Investigations (SSBI)) used to adjudicate security clearance requests for military, civilian, and contract personnel performing work for IACH.  Similar to Level 4-3, the appellant utilizes established and specific Federal regulations, and DA and IACH security program guidelines, protocols, and requirements (e.g., AR 380 regulations) to compile and review the results of electronic security and background checks.  The appellant uses the results of security and background checks to estimate the level of risk involved in hiring personnel and authorizing access to secure IACH buildings and offices and reports this information to her supervisor and/or the appropriate IACH officials.  The appellant fully considers DA and IACH programs, policies, and regulations when implementing personnel security methods and processes and uses her understanding of the relationship between operating costs and IACH’s personnel security needs and objectives when developing security plans and recommending improvements to current personnel security processes and procedures.  Like Level 4-3, all personnel security recommendations made by the appellant are based on current facts and information, such as personnel documents, results of electronic security and background investigations, available funding, and DA and IACH guidelines.  The appellant uses information derived from security and background investigations to determine if employees, students, and Federal contract workers pose security risk for IACH, and documents and presents the results of all personnel security investigations to her supervisor and all appropriate IACH officials for consideration and further action.

Level 4-4 is not met.  Unlike Level 4-4, the appellant’s work is specific to the IACH and does not require consideration of a variety of security policies, practices, procedures, and techniques in order to adequately implement personnel security for a number of locations with differing security requirements and funding sources, complexity, and local conditions, nor does it require her to coordinate IACH’s personnel security systems, methods, and processes with those of other organizations.  Unlike Level 4-4, her assignments do not routinely involve analyzing and testing personnel security techniques and practices to determine applicability, since those currently in use are established, well-defined, and required by Federal regulation and DoD and IACH policy.   Consequently, there is no need to digress from normal methods and techniques or waive security and investigative standards.

This factor is evaluated at Level 4-3 and 150 points are assigned.

Summary

Factor	Level	Points
1.  Knowledge required by the position	1-6	950
2.  Supervisory controls	2-3	275
3.  Guidelines	3-3	275
4.  Complexity	4-3	150
5.  Scope & effect	5-3	150
6.  Personal contacts	6-3	60
7.  Purpose of contacts	7-2	50
8.  Physical demands	8-1	5
9.  Work environment	9-1	5
Total Points		1920

A total of 1920 points falls within the GS-09 range (1885-2100) on the grade conversion table in the GS-0080 PCS.  Therefore, the appellant’s position is properly graded at the GS-09 level.

Decision

The appellant’s position is properly classified as Personnel Security Specialist, GS-0080-09.

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