Comment on DOD-2026-OS-1321-0001

The proposed amendment to Accelerated Compensation for Developmental Positions (ACDP) would extend pay‑setting flexibility to the NH‑IV broadband level, allowing developmental positions to receive pay increases of up to 20%. However, ACDP, as outlined in 82 FR 52168, is intended to support gradual pay progression for entry‑level and developmental positions. NH‑IV corresponds to the GS‑14/15 pay range, and Appendix D of 82 FR 52104 defines Level IV as encompassing expert‑level professionals, branch or division chiefs, and key program administrators. These duties reflect senior leadership, advanced technical expertise, and major program responsibility, which are not aligned with developmental career stages. Levels I, II, and III are appropriate for ACDP because their definitions correspond to entry‑level, early career, and developmental progression. In contrast, Level IV represents fully proficient senior professionals, making its inclusion in ACDP inconsistent with the framework’s intent. Additionally, the description of the Out of Cycle Within Broadband Pay Increase authority although cannot be adopted from the Army Research Institute STRL demonstration project (89 FR 13548) already provides a mechanism that achieves the intended flexibility for positions in broadband level IV.