Chief Rubin's Response

Dear Council Members Mendelson, Cheh and Schwartz:
 
A concern has been raised about the accuracy of statements made at the Fire & EMS recent oversight hearing before the Committee on the Judiciary on 2/12/08.  (See attached email dated February 13, 2008, from Mr. Kenneth Lyons, President AFGE Local 3721).  The issue under discussion in the exchange between myself and Councilmember Cheh, was the very important issue of pay and benefits parity between single-role and multi-role personnel. As you know, the Mayor’s EMS Task Force Recommendation 1 (d) states: “All employees shall have the same basic pay and benefits.  The City Administrator shall develop a plan, no later than March 31, 2008, to transition to pay and benefits parity between single-role medical providers and dual-role providers.”  I have supreme confidence that the City Administrator, working in conjunction will the appropriate stakeholders, will meet this deadline.  I also pledge to do my very best to implement this plan and achieve this important objective.  
 
Mr. Lyons questions the basis for statements I made at the hearing discussing the current comparative gross pay between single-role and multi-role providers.  I thank him for raising the question, and I am happy to outline the basis for these statements.
 
First, a technical correction.  My staff has reviewed the segment of the hearing referenced in the email and has found that one technical clarification needs to be made.  I misspoke when I stated that overtime for single-role providers begins when they exceed 8 hours in work day.  This is incorrect.  Overtime or compensatory time for single-role personnel is earned under the following conditions: 
 
  • Comp Unit 1, non-supervisory single-role personnel on compressed work schedules do not begin receiving overtime or compensatory time pay until they have worked more than 48 hours in a long week, or 36 hours in a short week.  The normal rule for work in excess of eight hours in day or 40 hours in a week does not apply, as the 12-hour shift is considered to be part of the scheduled tour-of-duty.  
 
  • Single-role EMS supervisors on compressed schedules receive overtime pay or compensatory time for authorized work in excess of forty (40) hours in a pay status in a work week. 
 
I can assure you that this technical error was unintentional, and please let the record reflect the accurate facts.  On the substantive issue being discussed however, that of comparative gross pay between single-role and multi-role providers, the facts as stated are correct.    
 
There is no argument that there are significant disparities in benefits for single-role providers versus multi-role providers, as they currently participate in different retirement systems, as was described in my testimony.  The issue of pay parity, however, is far more complex.  The most simplistic analyses of pay parity between single versus multi-role personnel simple look at the base salaries as listed in the DCHR pay schedules for the two different groups and draw conclusions based upon those data points.  However, the base salaries for single-role providers in as listed in the pay schedule do not reflect numerous structural components which increase the actual take-home pay of these personnel.  These items include: Night Differential: 10% premium for hours worked on a regularly scheduled tour of duty falling between 1800—0600 hrs; and Sunday Premium: 25% premium for hours worked on a regularly scheduled tour of duty between 0000—2400 hrs on Sunday.  These two structural components do not exist for multi-role personnel (firefighters).  In addition, single-role providers earn overtime or compensatory time at a time-and-a-half rate, while firefighters commonly earn overtime or compensatory time at a straight time rate. 
 
These structural components can comprise a significant portion of actual earnings for single-role providers.  For example, an independent analysis of real take-home gross pay for single-role EMS supervisors conducted by DCHR in June 2007 analyzed the earnings of EMS supervisors for calendar year 2006 and found that on average, single-role supervisors earned an additional 30% above their base salaries with overtime and premium pay. 
 
An external analysis of gross pay for all members of FEMS, using a selection of pay periods from CY2007, conducted by the Office of the City Administrator in June 2007 found that while base salaries for firefighters are generally higher than that of their single-role peers, at all levels below that of Lieutenant, single-role providers actually earned more than their peer counterpart firefighters at both the median and 90th percentile level.:[1] 
 
  • Single-role EMTs                     Median: $54K, 90th Percentile: $68K: 
  • Firefighter/EMTs                      Median: $53K, 90th Percentile: $65K
 
  • Single-role Paramedics           Median: $73K, 90th Percentile: $111K
  • Firefighter Paramedics            Median: $70K, 90th percentile: $95K
 
  • EMS Preceptor                         Median: $78K, 90th percentile: $132K
  • Fire Sergeant                          Median: $85K, 90th percentile: $112K
 
For supervisors*, the numbers were:
 
  • Supervisory Paramedic           Median: $88K, 90th percentile: $116K
  • Fire Lieutenant                        Median: $99K, 90th percentile: $114K
  • Fire Captain                             Median: $116K, 90th Percentile: $133K
 
*Note that after this analysis was completed, a compensation change was implemented on 10/03/08 to increase the salary of all current single-roleEMS supervisors (Management Supervisory Service employees-MSS) to reduce the impact of step compression and to move their salaries closer to a comparable range within the MSS salary schedule to that of their peer fire officers.
 
The specific reasons that actual take home pay for single-role providers so often exceeds that of their peer multi-role counterparts are multi-factorial.  As I noted during the hearing, these reasons include structural pay components (such as Sunday premium pay and night differential) that are unique to civilian personnel and are not received by firefighters.  In addition, single-role providers earn overtime or compensatory time at a time-and-a-half rate, while firefighters commonly earn overtime or compensatory time at a straight time rate. All of these findings require further detailed analysis and discussion, but I think that you will agree that any truly valid comparative analysis of pay issues between the two groups (or between various sub-groups) must also look at actual earnings versus simply comparing base salaries from a pay schedule. As we work together to solve the issues of pay and benefits parity, I know that you will agree with me that it is critically important that we seek the most accurate understanding of the underlying issues.
 
Thank you for allowing me to present additional information to inform our analysis of these complex and challenging issues, and I thank you for your continued support as we work to maintain a fair and equitable workplace, and strive to improve the quality of emergency medical services in the District of Columbia.
 
Sincerely Yours,
 
Dennis Rubin, Fire/EMS Chief
 

Copyright (C) 2007-2008 by AFGE Local 3721