There have been several developments regarding how compensatory picks are now being awarded since OTC’s last written update on its projection of the 2021 slate of comp picks. Let’s get right to it.

As you can see, the list on the right (or above on mobile) is very long. As it stands right now, 2021 is projected to shatter the record for most eligible compensatory picks at 46. Since the CBA strictly limits the number of awarded compensatory picks to 32, that means that 14 of these eligible picks would be discarded. That includes all 7th rounders, and even a few 6th rounders. Some of this is due to chance that always exists in the formula, but a bit of this is also due to some additional revelations regarding the formula that will be described below.

The Week 10 rule is no more

Week 10 of the 2020 season is in the books. In the past, what this would have meant for compensatory picks is that teams could no longer cut compensatory free agents (CFAs) on their team and be relieved from those contracts counting against them in the formula.

However, in yet another likely effort by the NFL Management Council to cut down on teams circumventing the formula, the Week 10 rule appears to be no more. Back in August, OTC reported that this was the case, and this has since been confirmed by our good friend Brian McFarland of Russell Street Report.

The best way to understand the veracity of these reports is to take Appendix V of the 2020 CBA, which is the binding authority on the compensatory formula, very literally for what it says–and also for what it does not say. There is no paragraph that says that players can get relief for terminating the contracts of CFAs, nor is “Week 10” or “ten weeks” ever mentioned. Therefore, this is more strong evidence that this rule has been abolished.

And it doesn’t take much thought as to why this rule was abolished. The 2019 regular season saw a large number of compensatory free agents that were cut for comp pick purposes. That likely was not a positive experience for any of these players, even if some of them found better opportunities elsewhere. The abolition of this rule also makes managing cancellation charts easier for teams and for OTC’s projection.

For the 2021 projection, the relevant CFAs that have been cut are:

• Gerald McCoy (left Carolina, signed with Dallas)
• Ha-Ha Clinton-Dix (left Chicago, signed with Dallas)
• Vic Beasley (left Tennessee, signed with Atlanta)
• Seth Roberts (left Baltimore, signed with Carolina)
• Jordan Howard (left Philadelphia, signed with Miami)

Perhaps the only question that might remain is if the compensatory formula will still count the entire contract, or only what was earned. For example, McCoy signed a contract for $6.1 million in APY, but only earned $3 million over 1 year. If the formula counted him at $3 million APY, that would help the Cowboys’ comp picks. However, since Appendix V makes no such mention, the projection is assuming that the whole contract will count.

CFAs that are COVID-19 opt outs will still be eligible to award compensatory picks.

Among all the chaos that this pandemic created, it also resulted in collective bargaining that allowed players to opt out of the season by tolling their contract a year. Two compensatory free agents applied for this opt out: Michael Pierce (left Baltimore, signed with Minnesota) and Devin Funchess (left Indianapolis, signed with Green Bay). The best assumption to have made was that these players would still qualify as CFAs, but that they would earn no snap count bonus. The most important part of this, qualification, has indeed been confirmed by Jeff Zrebiec of The Athletic.

Another important part of this question applies not just to COVID-19 opt outs that are CFAs, but to the league as whole, which brings us to the next important change in the projection:

The number of “all players on rosters” could be higher than normal this season

What remains the most difficult part of projecting compensatory picks is determining the number, as defined by Appendix V, of “all players on rosters at the conclusion of a regular season”. This number is important, because this is the denominator of how percentile cutoffs are determined, which in turn determine what round, if any, a CFA’s contract is valued as.

In the past, the best way to guess this number is to only exclude players that are on practice squads, but include all others–including players on reserve lists, such as Injured Reserve. However, the new COVID-19 rules have also resulted in more players on reserve lists. This is not only the 69 players that opted out, as described above, but also potentially a number of additional players on the Reserve/COVID-19 list for active players that have either tested positive or may be at risk to test positive.

If these players are included, that should increase this leaguewide roster count denominator. Previously, the formula was using a rough estimate of previous estimations, which came out to 1,935. However, the formula will now be using a real time count of this number that is pulled from OTC’s database. At the time of publication, that number is 2,050. The end result is that some CFAs may now be valued at a higher round, and some other CFAs that were not projected to qualify now do.

As a result, here are the following changes to watch for in OTC’s 2021 comp pick projections:

• New England: There is a chance that they could earn a net loss of four CFAs. However, this will depend on whether or not Nate Ebner’s contract qualifies. That contract is right on the bubble. Patriots fans should root for Ebner, a career special teams player, to earn some more snaps on defense for the Giants.
  
  However, even if Ebner’s contract qualifies, whether the Patriots get a fourth comp pick will come down to the valuation of Beau Allen’s contract. Currently, it’s on the bubble of the 6th/7th round cutoff. If it’s valued as a 7th, which is possible given that Allen is missing the entire season, the Patriots would add a 6th rounder for the departure of Danny Shelton. But if it’s a 6th, the potential fourth comp pick would be a 7th for Ebner that wouldn’t make the 32 pick limit.
• Baltimore: Their net loss of CFAs could raise to two or even three. The contracts of both Josh Bynes and Patrick Onwuasor are on the bubble of qualifying. If at least one of them do, the Ravens could potentially add a 6th rounder for the departure of Seth Roberts (despite being cut by the Panthers as described above). Like Patriots fans, Ravens fans should root for Bynes to continue play frequently for the Bengals, and for Onwuasor to get off IR and play for the Jets.
  
  However, like the Patriots, this would also depend on whether Derek Wolfe’s contract is valued as a 6th or 7th rounder, a contract is right on the bubble of that cutoff. If it’s a 6th, then the contracts of Wolfe and Roberts will cancel each other out, and like with the Patriots and Ebner, 7th rounders for the contracts of Bynes or Onwuasor will not make the 32 pick limit. The Ravens will decide whether additional playtime for Wolfe, a player who’s contribution has always been valued since entering the league with the Broncos, is worth losing a potential 6th round comp pick.
• Pittsburgh: Tyler Matakevich, primarily a special teamer with the Bills, is also on the bubble of that 6th/7th round cutoff. If his contract is valued as a 6th, there’s a chance the Steelers could add an addition 6th rounder for his departure, but it may be difficult for it to make the 32 pick limit.
• Kansas City: Due to injury early in the season, there was some question as to whether Kendall Fuller’s contract would be valued at the 4th or 5th round. With the cutoffs getting more generous, as long as Fuller stays healthy, the Chiefs should feel more comfortable that they’ll indeed get a 4th rounder for his departure to DC.
• Philadelphia: Ronald Darby’s contract is now more likely to be valued as a 6th rounder, which would possibly give the Eagles a 6th round comp pick for his departure, so long as it can make the 32 pick limit.
• Atlanta: De’Vondre Campbell’s contract may now be valued a 5th rounder instead of a 6th, those boosting a comp pick the Falcons are projected to get from a 6th to a 5th.
• Carolina: It is now more likely that Vernon Butler’s contract will be valued as a 5th rounder than as a 6th. If that’s the case, then the Panthers would get a 5th for his departure instead of a 6th for a different player’s departure.
• Tampa Bay: The question with Beau Allen’s contract as described above under the Patriots also affects his former team in the Bucs. If the contract is valued as a 6th rounder, the Bucs will get a 6th for that contract. If not, they’d only be eligible for a possible 7th rounder for the departure of Jameis Winston (assuming his odd consideration qualifies him at all) that won’t make the 32 pick limit, even if Winston plays as much as the rest of the regular season in relief of Drew Brees in New Orleans.

How will compensatory picks for the hiring of minority head coaches and general managers be handled?

Finally, the NFL finally succeeded in using the compensatory pick system to encourage the advancement of minorities in its highest ranks. The league approved a resolution that will award two or three 3rd round comp picks, one each per draft, to teams that see a coach or executive depart due to being hired as a head coach or general manager elsewhere.

While the resolution itself is straightforward, the application to the compensatory formula is not. The resolution states that “[a]ny compensatory Draft picks awarded pursuant to this Policy will be at the end of the third round following all compensatory Draft picks awarded to clubs pursuant to Appendix V of the NFL-NFLPA Collective Bargaining Agreement”.

However, Art. 6, §2(a)(i) of the CBA is very clear that the number of comp picks are to be “a maximum number of additional Compensatory Draft Selections equal to the number of Clubs then in the League”, which is 32. To confirm how strict this is, when there was a rare exception to this in 2016 when a 33rd pick was authorized due to clarification over how the contract of transition tagged Charles Clay should be handled, that authorization required approval from the NFLPA.

If the intention of the league is to award these minority hire compensatory picks separate from what is laid out in Appendix V, and potentially go beyond 32 comp picks in total, then I would presume that the NFLPA may want to give a similar approval here. Whether or not this is an issue the NFLPA wants to take up is up to them, but the reason why they might want to is straightforward: if there are more than 32 comp picks, that means that there are more incoming rookies that are denied the privilege of undrafted free agency.

Conversely, if the number of total comp picks remains fixed at 32, then that will force more regular comp picks to miss the 32 pick limit. That may be of concern for teams that were counting on a 6th or 7th round pick that won’t get it due to the addition of this new rule.

This is an answer that OTC will try to track down, and if any of our friends in the media are also able to get an answer, that would be greatly appreciated.