Make sure your position description is accurate


Most federal employees, including all of those in the General Schedule, have a position description. Have you ever looked at yours? Does it accurately describe what you do? Does it leave out important duties or describe your work in terms less significant than what you actually do? Does it matter?

Employees in the GS system are subject to a rigid and somewhat mysterious classification system that actually does rely heavily on the position description. The result of an analysis of the position description contents determines both your job series and your grade level. So, the answer to the last question above is: The position description does matter.

Let’s assume you review your position description and you believe it is inaccurate. What can you do? The Office of Personnel Management says in its position classification regulations that you should open a conversation with management about amending your position description, and, if you are unhappy with the results from that conversation, you can have the issue determined by filing a grievance under either the administrative or negotiated grievance procedure. This may or may not result in a change to the position description.

Another option is to ask for a desk audit. This may change the position description, and it could re-determine your grade level, which might go up or down. Some desk audits may evaluate your grade level on a review of your existing PD without any review of what you do on a daily basis.

All of this results in uncertainty and the lack of a fair forum. But, it is quite important because the OPM classification regulations provide the rules for an appeal if you believe your position should be upgraded.

The first rule of a classification appeal, which can be done either at your agency, at OPM or both, is that the appeal cannot concern the accuracy of the position description. At the same time, while OPM says it cannot review the accuracy of a PD, it also gives itself the authority, at its sole discretion, to go into the agency and actually audit your job. What this says to me is that the better job you do of documenting your record concerning why your PD is inaccurate, the more likely OPM might actually do something about it, even if you do not have the right to appeal the issue.

There are several other variations on this theme. Many of you may have been assigned to temporary duties or even a detail apart from your regular job. Those duties may be more advanced than your regular job. You probably will not receive a PD for these temporary duties and you specifically cannot make them subject to a classification appeal. So, for those of you asked to take on extra duties that are not expected to be permanent, don’t expect your PD to be amended or to successfully file an appeal based on your new duties. Hopefully, your work will be recognized with a nice bonus.

A common complaint is that “I do the same work as the guy down the hall and he is a GS-12 and I am only an 11. Can you do something about it?” The answer is probably not, unless you can show that your accurate PD has been improperly classified. OPM regulations preclude employee-to-employee comparisons in deciding classification appeals and permit only a comparison of the existing PD to the classification standards. This does sometimes produce an unfair result, but there is no further review of an OPM classification decision.

If you can show that the disparity in grade levels for similar work is related to illegal discrimination, you might be able to overcome the OPM rule prohibiting position-to-position comparisons, but it might be difficult to prove discrimination based on an inaccurate PD.

If your agency says your PD has you graded too high, it can demote you and you have a classification appeal right. In exercising this right, the first thing to do is make sure your PD is accurate and, if it isn’t, then do your best to make it accurate. Then file an appeal within 15 days, and, if you win, you can receive back pay. While you have the right to two years save grade and indefinite save pay if you are demoted for a classification decision, you have no control over how long the appeal process will take.

These are some of the basic reasons why you should pay attention to having an accurate and complete position description.


About Author

Debra Roth

Debra L. Roth is a partner at the law firm Shaw Bransford & Roth, a federal employment law firm in Washington, D.C. She is general counsel to the Senior Executives Association and the Federal Managers Association, host of the “FEDtalk” program on Federal News Radio, and a regular contributor to Federal News Radio’s “Federal Drive” morning show. Email your legal questions to

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