 Dear CHCOs, Deputy CHCOs, and HR Directors,
The U.S. Office of Personnel Management (OPM) reminds agencies of the flexibility to set pay above step 1 (up to step 10) under the superior qualifications and special needs pay‑setting authority for newly appointed General Schedule (GS) employees. Used proactively, this pay-setting flexibility can enhance an agency’s recruitment initiatives for highly-skilled technical positions, early career talent, and other critical workforce needs.
Setting Pay Above Step 1 While newly appointed GS employees generally enter Federal service at the step 1 rate, OPM regulations permit setting pay above step 1 based on a candidate's superior qualifications or a special agency need. (See 5 CFR 531.212.) Agencies may extend an initial offer directly at the higher step where the justification supports doing so — considering factors such as the quality of the candidate's skills, position criticality, Federal and non-Federal pay disparities, and labor market conditions. (See 5 CFR 531.212(c).) Agencies are not required to make an initial offer at step 1, await a rejection, and then renegotiate.
Proactive, Uniform Pay Determinations Agencies may also establish a uniform policy to assign a specific higher step rate to all candidates with similar qualifications applying for similar positions, provided the agency approves and documents each individual determination consistent with 5 CFR 531.212(e).
For example, when recruiting for GS Tech Force positions, agencies may determine in advance, based on documented market data and a special agency need, that a standard higher minimum step is warranted. Under this approach, agencies may offer the predetermined higher step rate directly and need not wait for a candidate to request pay above step 1.
For additional information, agencies may refer to OPM’s fact sheet on the Superior Qualifications and Special Needs Pay‑Setting Authority here: https://www.opm.gov/policy-data-oversight/pay-leave/pay-administration/fact-sheets/superior-qualifications-and-special-needs-pay-setting-authority/, or contact OPM at PayPolicy@opm.gov.
U.S. Office of Personnel Management
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