If you document that it is a different job, it should be okay. Region looks at differences between the jobs. Must include a very clear comparison of duties and responsibilities, showing all differences between the jobs. It is helpful if jobs are in different occupational classifications, but it is not fatal if jobs are in same occupational classification, but at different levels. Certifying officer has stressed that it is a very fact-specific analysis and determination, so it is important to include as much information as possible on both jobs.
Region takes conservative view.
SESA requires strong showing that positions are substantially dissimilar and are not part of ordinary progression. Unacceptable, absent a full NOF and rebuttal and proof of a different, completely different job. Essentially, the positions have to be substantially dissimilar. Flag it for expedited processing as it is in the regulations. Yes, and they are done quickly as little as 30-45 days from SESA to approval by Region.