Comment on DOD-2026-OS-1321-0001
AnonymousOpposeOther
Summary: The commenter argues against extending Accelerated Compensation for Developmental Positions (ACDP) to NH-IV developmental roles. They contend that positions above the GS-09 or GS-11 levels are journeyman-level roles requiring full technical expertise and do not meet the criteria for developmental compensation.
While the amendment proposes extending Accelerated Compensation for Developmental Positions (ACDP) to NH‑IV developmental roles, accelerated developmental compensation should not be applied to positions above the GS‑09 or GS‑11 equivalent levels. Positions beyond these thresholds are considered journeyman‑level and require fully developed technical expertise. Because these roles already demand independent technical proficiency rather than developmental progression, they do not meet the intent or criteria of ACDP. Expanding ACDP beyond true developmental levels risks misalignment with established career progression frameworks and may inadvertently apply developmental flexibilities to positions that are no longer developmental in nature.