| Comment Number: | EM-022856 |
| Received: | 3/17/2005 1:20:01 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:
March 17, 2005 DoD NSPS Comments , DoD NSPS Comments: Congress, WAKE UP! NSPS proposes a compensation system under which the salary of an employee CAN DECREASE due to adjustments based on ?mission requirements? and ?availability of funds?. Sec. 9901.322(a) and Sec. 9901.333(a) Furthermore, the NSPS proposed rule doesn?t provide ANY of the important information about how the program works! The things we NEED TO KNOW NOW won?t be revealed until sometime in the future when ?implementing issuances? are published. NSPS is not a personnel system. It is a bunch of ?creative? wording engineered to placate the unwary, while delivering a veiled invitation for DoD civilians to ?bend over?. Here?s one example of deceptive wording: Pay and Pay Administration ? Subpart C National Security Compensation Comparability ?In accordance with the NSPS law, to the maximum extent practicable, for fiscal years 2004 through 2008, the aggregate amount allocated for compensation of DoD civilian employees under NSPS will not be less than if they had not been converted to the NSPS. This takes into account potential step increases and rates of promotion had employees remained in their previous pay schedule.? It sounds like pay will remain the same, but what actually happens to the ?aggregate amount? after ?the maximum extent practicable? is considered? Under NSPS, Sec. 9901.322(a) and Sec. 9901.333(a) both state that ?DoD will consider mission requirements, ? , availability of funds, ? and any other relevant factors? when setting/adjusting the limits of the pay band, and setting/adjusting local market supplements. However, in Sec. 9901.332(a), there?s no guarantee that local market supplements will even exist under NSPS. In Sec. 9901.342(a)-(b) is the Pay Pool. There is no explanation in the NSPS proposed rule that even begins to explain how the Pay Pool works. After ?mission requirements? and ?availability of funds? are considered, exactly how much of the ?aggregate amount? is left for employee salaries? . Sincerely,