Comment Number: 05-02582-EREG-250-d7391-c32402
Received: 3/16/2005 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
No Attachments

Comments:

Comments on Proposed NSPS Regulations--RIN 3206-AK76/0790-AH82:
Two questions:
1. With pay-banding, how can we know whether or not managers are compensating employees for performance and merit, and not for reasons related to gender, ethnicity, etc?

The current GS system has done much to encourage many of us to believe that women are paid fairly compared to men. Under the current system, step increases within a GS level should be given for experience and merit. Awards are given out for good performance, too. Of course, under the current system, a manager could compensate some employees - based on factors other than performance - through awards and other means, and the rest of us wouldn't know about it. But generally, if a group of engineers are GS12's, and the more experienced ones are higher steps than the less experienced ones, everyone can be fairly confident that people are paid fairly, because the system ensures that a manager is limited for how much a pay difference there can be. (I worked for a defense contractor a few years ago, and learned that I was getting paid 2/3 the salary of my male colleagues, for doing the same job!)

Surveys show that in industry today, women are paid less than men for the same work, even for fields that in years past were primarily occupied by women only, such as nursing. I realize there are many factors involved, which some of these surveys cite; for example, some women do not negotiate for a higher salary to begin with.
Bottom line: how will NSPS earn the same credibility on this point that the GS system has now?


2. The scant information we've seen so far says that NSPS will hold managers and supervisors more accountable. How?
For those who don't pull their weight, the managers and supervisors may or may not be taking any action; the rest of us simply don't know for confidentiality reasons. But for those whose performance has been in the pits for years, it is unclear why the managers and supervisors allow this to continue. Some may blame "the system" and cite things like, "it's hard to fire a federal employee..." I believe that's a myth. The current rules require them to document all the facts, which may be difficult and time-consuming, but that's their job! I believe the real problem is that people are uncomfortable doing unpleasant things.

So... how will NSPS change this? We will still have the same managers and supervisors we've had with the GS system. What makes anyone think that these same people will suddenly develop courage and fortitude? Instead of scrapping the GS system in favor of NSPS, why don't we reform the current system to hold managers and supervisors more accountable?