| Comment Number: | OL-10500005 |
| Received: | 2/14/2005 2:30:16 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:
PAY BANDING: The concept of pay banding creates inherant conflicts of interest for middle management employees. A probable pay band will most likely be established for current grades 13-15. In my Agency, DCMA, this band includes a majority of middle managers. The banding in this wage range results in three levels of employees who appraise each other,i.e. the current grade 15 evaluates the current grade 14 who in turn evaluates the current grade 13 who evaluates his/her employees who are in a separate pay band.. The creation of the pay band and subsequent pool of dollars available to be dispersed to middle managers can be too easily controlled down the line. I have seen this take place in a similiar system. In the 80's, DCMA had a program which was designed to improve the salary of effective managers. A pool of dollars was created based on a percentage of the total salaries of GS13-15 managers. The incentive money was consistently distributed each year with the GS 15's always taking the "lion's share with the GS-14's getting a "taste" and very few GS13's (none in my office) recieved a dime. Again, the pool was a % of total payroll GS13-15 with the vast majority of GS-13 making up the pool. Needles to say, this system had it's inherent protections for those who got the largest benefits in that all of the employees were managers and to complain would virtually end your chances of getting ahead. It was tacetly implied that GS-13 should "be patient" and that your time would come. the system was eventually abolished. All supervisors were trained under that system. To rely on training managers to implement a system does not insure fairness in that system. This pay band system will probably work fine where a manager is evaluating employees not in their pay band as the first line manager has an incentive to insure the efficiency of the department to get the job done. However, in the managerial band the first line manager will most likely be a bottom feeder in his band who "will have to be patient". The system will work well in an ideal world. Unfortunately we do not function in an ideal world and human nature being what is, this pay banding system leaves too much room for abuse.