The 2024 locality pay areas are now finalized due to a final regulation issued by the Office of Personnel Management (OPM) on November 16, 2023. General Schedule employees in the new and modified locality pay areas will receive locality pay under the 2024 pay tables starting in January 2024.
Typically, the pay tables for the next year are issued late in December. The pay tables are usually published about the same time as the release of the president’s executive order finalizing the federal pay raise for the coming year. We anticipate the events this year will follow the same pattern.
72% Expansion in GS Locality Pay Areas Since 2015
OPM issued a proposed regulation on locality pay in June 2023. The purpose of the proposal was “to change the geographic boundaries of General Schedule locality pay areas.”
Four new locality pay areas were proposed as part of the OPM proposal. These four new areas were finalized when the final regulation was issued on November 16, 2023.
Adding new locality pay areas is a routine matter. The Federal Salary Council is primarily comprised of federal employee union representatives, and any action that benefits the federal workforce receives a warm reception. The President’s Pay Agent often approves recommendations from the Salary Council. When a Democrat is in the White House, there is usually a greater likelihood that the Pay Agent will approve the proposals.
Since 2015, the number of federal locality pay areas for General Schedule employees has expanded from 33 to 57, an increase of 72.7%. While we have not been able to learn the number of federal employees now situated in a locality pay area, the number of employees covered by this system has greatly expanded.
Why 2024 Locality Pay Areas are Creating Confusion
How federal employees are approved for inclusion in new locality pay areas is not always apparent. The regulations for 2024 locality pay provide an excellent example of how this expansion is occurring. The subtlety of the explanation underlies the confusion, leading to some questions we have been receiving from our readers.
Here is one example out of many such examples in the new regulations. The initial proposal described one locality pay area in this way:
Burlington-South Burlington, VT
Addison County, VT; Lamoille County, VT; and Washington County, VT. (emphasis supplied)
The final regulation for the 2024 locality pay areas described the Burlington, Vermont locality pay area in this way:
Burlington-South Burlington-Barre, VT—consisting of the Burlington-South Burlington-Barre, VT CSA and also including Addison County, VT, and Lamoille County, VT
For some federal employees interested in whether they were included in the new regulation, they had an obvious question: “What happened to Washington County, VT in the final regulation? Why was this county eliminated from locality pay? Is there an explanation about why it was excluded?”
Resolving the Confusion in Pay Area Descriptions
There is an answer in the final OPM explanation. It may not be apparent at first and not easy to understand. Government documents can be written to explain, obfuscate, or confuse readers depending on the authors’ objective.
The answer is in the Federal Register notice. It reads, in small part:
These comments [on the initial proposal] all expressed concern about locations which, while not listed as individual counties in paragraph (b) of § 531.603, were all included in the MSA [metropolitan statistical areas] or CSA [combined statistical areas] listed for the locality pay area and therefore did not need to be listed as individual counties.
Here is a further explanation of the changes in defining 2024 locality pay areas as explained in the original OPM document:
As explained in the Pay Agent’s December 2022 annual report, the Pay Agent has tentatively approved the use in the locality pay program of the MSAs and CSAs delineated in OMB Bulletin No. 20–01…, pending the issuance of revised locality pay regulations. This proposed rule would implement the change by revising the definitions of “CSA” and “MSA” in 5 CFR 531.602 to link the geographic definitions of locality pay areas to the March 2020 definitions of MSAs and CSAs in OMB Bulletin No. 20–01, and by updating the locality pay area definitions in 5 CFR 531.603 to reflect use of the OMB Bulletin No. 20–01 MSA and CSA definitions.
I was working for OPM as a federal employee in 1978 when President Jimmy Carter issued Executive Order 12044. This Executive Order stated, “Regulations shall be as simple and clear as possible. They shall achieve legislative goals effectively and efficiently.”
Perhaps the large number of people interested in locality pay areas who read this explanation would agree the Carter Executive Order on writing clear, simple regulations—and the clear writing classes held to implement the Carter Executive Order—did not achieve a long-term foothold in the federal bureaucracy.
Few would wade through this government “bureaucratese” explaining locality pay areas.
As we have received numerous questions on this from readers, here is my interpretation and an attempt to write a clearer explanation.
To expand locality pay areas to more federal employees, existing locality pay areas are growing. Combined statistical areas (CSAs) are metropolitan areas grouped together for statistical purposes.
Examples of 2024 Expanded Locality Pay Areas
When the new locality pay areas were announced in the final regulation, some areas, such as Washington County, Vermont in the example quoted above, were not mentioned. But, because Washington County, Vermont is part of the larger CSA, Washington County is now part of the Burlington locality pay area. It was not listed as a separate county because it is in the CSA.
That same situation occurs throughout the new list of locality pay areas.
For example, in the Seattle locality pay area, the new definition includes “Seattle-Tacoma, WA—consisting of the Seattle-Tacoma, WA CSA.” The result is that the 2024 Seattle locality pay area now includes this large CSA. There is no need to list individual counties or other areas within this CSA as they are all included.
Are You in a CSA for Locality Pay Purposes?
How do federal employees know if they are in a CSA for locality pay?
In answering several questions from readers, I have found one way to find out is to use an internet search engine. For example, one reader asked a question like this: “What happened to Merced County, CA? Why are we excluded from a locality pay area?”
To find out, I found a map displaying Merced County, California. It is near San Jose and San Francisco. With more research, I found Merced County is included in the San Jose–San Francisco–Oakland, CA CSA. Therefore, Merced County, California is now in a locality pay area. It was not excluded because this locality pay area, according to the final regulation, now consists “of the San Jose-San Francisco-Oakland, CA CSA….” No separate listing of this county was necessary because it is in the CSA.
Hopefully, most readers will know their geographic area and will know if they are in a CSA. If not, an internet search engine may provide the answer.
As soon as the 2024 pay tables are released, readers will be able to determine their new annual salary. FedSmith will provide more information as soon as it becomes available.
