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Federal Register / Vol. 86, No. 167 / Wednesday, September 1, 2021 / Proposed Rules
request for additional information to supplement the course approval request.
The impacted employees work in the Washington-Baltimore-Arlington, DCMD-VA-WV-PA area. The Office of Personnel Management OPM lists the hourly pay for Federal employees in the Washington, DC area according to the Washington, DC General Schedule GS
pay tables.25 We estimate that the impacted employees would, on average, be at a step 5 pay, because that is the midpoint of the pay band. OPM records the hourly pay of GS7, step 5

employees as $26.43, and records the hourly pay of GS13, step 5 employees as $55.75. These wages are not fully loaded, meaning they do not account for associated benefits.
To account for the value of benefits to government employees, we first calculate the share of total compensation of Federal employees accounted for by wages. The Congressional Budget Office 2017
reports total compensation to Federal employees as $64.80 per hour and wages as $38.30.26 This implies that
total compensation is 1.69 times the average wages.27 We can, therefore, calculate the fully loaded wage rate for the GS7 and GS13 hourly wage rates by multiplying by 1.69, yielding $44.67
and $94.22, respectively.
All 23 course providers that may offer a modified basic firefighting course must submit a course approval request to the Coast Guard for evaluation. We estimate the costs of this initial submission to industry and the Coast Guard in table 4.

TABLE 4COSTS DUE TO INITIAL COURSE APPROVAL APPLICATIONS
Employee type
Fully loaded wage
Number of course providers
Hours
Total cost
A

B

C

A B C

Industry Cost
Government Cost
Government Cost

Training Specialist
GS7
GS13

$45.4
44.67
94.22

23
23
23

6
1 5

$6,265
1,027
10,835

Total Government Cost

11,862

Total Cost

$18,127

It is common for course providers to submit insufficient supporting information with a course approval request to the Coast Guard. When this occurs, the Coast Guard will request additional information from the course provider. We reviewed new course
approval submissions over 3 years 20182020 to determine how likely it is for a course provider to submit a course approval request without the Coast Guard requesting additional information. We report the total number of course approval applications received
and the number of course approval applications that require additional information in table 5. We estimate that course providers include insufficient information in their application packet 37 percent of the time.

TABLE 5COURSE APPROVAL REQUESTS RECEIVED WITH INSUFFICIENT INFORMATION
Course approval requests received
Course approval requests received with insufficient information
Percent of course approval requests with insufficient information
2018
2019
2020

944
768
699

362
335
199

38
44
28

Total

2,411

896

37

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Year
When course providers submit a course approval request with insufficient information, the Coast Guard would request that the course providers revise their course request and resubmit. The Coast Guard estimates that both the course provider and the Coast Guard would spend an equal number of hours on each resubmittal as they would on the initial submission. In other words, the course provider would spend 6 hours on an
initial approval request and 6 hours on the resubmittal, for 12 hours total, and the Coast Guard would spend 1 GS7
hour and 5 GS13 hours on the initial request, and 1 GS7 hour and 5 GS13
hours on the resubmittal, for 2 GS7
hours and 10 GS13 hours total.28 We request comment on how long it would take to develop and submit a course approval request and the wages that would be paid to those who develop the
25 https www.opm.gov/policy-data-oversight/
pay-leave/salaries-wages/salary-tables/20Tables/
html/DCB_h.aspx.

26 Congressional Budget Office 2017, Comparing the Compensation of Federal and Private-Sector Employees, 2011 to 2015, https
www.cbo.gov/system/files/115th-congress-20172018/reports/52637-federalprivatepay.pdf.

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course materials and submit the approval request to the Coast Guard.
Thus, the Coast Guard estimates that 37 percent of the course providers, or 8
course providers,29 would submit the request for course approval with insufficient information, requiring a second submission taking 6 hours to prepare for submission to the Coast Guard. Similarly, the Federal government would spend an additional 1 hour at grade level GS7 and 5 hours 27 $64.80

divided by 38.30.
provided by an SME from the Coast Guards NMC.
29 23 37% = 8, rounded.
28 Information
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