Comment Number: 05-02582-EREG-203-d7391-c32338
Received: 3/14/2005 8:00:00 AM
Subject: Notice of Proposed Rulemaking, Request for Comment
Title: National Security Personnel System
CFR Citation: 5 CFR Chapter XCIX and Part 9901
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Comments:

My comment about NSPS concerns Pay Banding. More specifically, the pay banding system is unfair to those employees who are on retained pay (due to an involuntary downgrade from a RIF) and as a result exceed the salary cap for the pay band that they are in. It is also unfair for those employees who are at the salary cap of a given pay band due to seniority (step 10 of their GS grade). Because these employees are at or above the salary cap of their respective pay band, they are not eligible to earn performance increases due to good work performance. At best, these employees earn a one time performance bonus which is invariably constrained by overhead account budget pressures at the District. Thus, these employees may put in a top performance at their job, but will at best earn only a few hundred dollars with a one-time award. This is much, much less than their counterparts (who are not constrained by the pay band salary cap) earn for a similar work performance.

One way of countering this flaw in the pay banding system is to extend the range of the pay band to cover all GS grades. Thus, only those employees at GS-15 step 10 would be disadvantaged by this flaw. Another way of mitigating this flaw is to make mandatory the size of the one-time performance bonuses--mandating that they at least equal in size the amount of money that they would have earned in one year had the employee not been at the salary cap.

This is a very important issue to me. Please try to find a way to fix this flaw in the pay banding system.

Thank you,
Mark Wiechmann, Ph.D.