Comment Number: EM-017386
Received: 3/11/2005 12:33:32 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:

INTERNATIONAL FEDERATION OF PROFESSIONAL AND TECHNICAL ENGINEERS March 11, 2005 Program Executive Office, National Security Personnel System, Attn: Bradley B. Bunn, 1400 Key Boulevard, Suite B-200, Arlington, VA 22209-5144. Dear Mr. Bunn: The reckless speed at which the National Security Pay System (NSPS) is being implemented is alarming. It appears that this system was hastily cobbled together and will be shoved down the throats of supervisors and employees alike. Pay Banding is unfair to those employees who are on retained pay (due to involuntary downgrade from a RIF) and therefore 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 due to seniority (step 10 of their GS grade). Because these employees are at or above the salary cap of their pay band, they cannot earn performance increases due to good work performance. At best, these employees earn a one-time performance bonus, which is subject to Overhead Account budget pressures at the District. Thus, these employees may put in a top performance but only earn a few hundred dollars in a one-time award. This is much less than their counterparts earn for similar work performance. Various government agencies have been testing performance pay systems for more than 20 years and invariably, the results have been that the majority of workers feel cheated when advancement, promotion and pay decisions are given over to the sole discretion of a supervisor. The process typically reduces salaries and morale. It is too autocratic and eliminates any redress for decisions made on the basis of considerations other than merit. There is very little opportunity for redress because the employee's options are severely curtailed. Regards,