| Comment Number: | EM-008378 |
| Received: | 3/8/2005 4:29:00 PM |
| 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:
> I think pay banding is a great idea. High performers deserve > to be paid more than low performers. My only concerns with NSPS are: > > 1) overlap in pay bands - No overlap between pay bands is > restrictive for those in the upper region of the band. If the system is > meant to benefit high performers, the benefit should not be restricted to > those in the lower/middle reaches of the pay band. I suggest making > "rubber" pay bands by extending the upper limit by $5000 or so in annual > salary. > > 2) locality in NSPS - The current locality pay system is > misleading and inappropriate. My 16% locality increase in Sacramento is > really just 4.3%, since the lowest rate for any area is 11.72% (not 0%), > according to the tables on http://www.fendonline.com/pay/localpay2005. I > am concerned that locality pay in NSPS will become even murkier and more > unbalanced, in the interest of spending less DoD money on civilan salaries. > I'd like more details on how NSPS will handle locality pay or some > assurance that, at worst, locality pay will remain in its current state. > > 3) possible pay cuts - The risk of receiving a pay cut, > whether it is due to budget problems or poor performance, should be > eliminated. People base their personal budgets on their salaries, so NSPS > should not introduce risk for caring for one's family, paying one's > mortgage, etc. At worst, a poor performer's salary should remain stagnant > from one year to the next. Cuts should not occur. > > 4) reliance on supervisors' evaluations - Supervisors who > are already swamped with work and barely have time to perform employee > evaluations certainly cannot be expected to perform even more in-depth > evaluations to accurately determine pay changes each year. I think this > applies to a substantial percentage of supervisors -- it will be a strain > for them, so the new system may be either moot or recklessly applied by > over-tasked supervisors.