| Comment Number: | OL-10500404 |
| Received: | 2/16/2005 5:32:51 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:
Subpart C, 9901.322 makes it clear that an employee may have their rate of pay reduced due to "availablilty of funds". While these changes purport to be for the purpose of rewarding performance in the workplace, the reality is that a high-performing employee can have their pay cut simply because less funding was made available. It's ironic that for years, means already in place for rewarding top performers have not been used, and now the government claims it is important to reward performance. 9901.352 "DoD may set pay anywhere within the assigned pay band when an employee is reassigned" means it can arbitrarily reduce an employee's pay when an employee is reassigned "to a position in a comparable pay band". If the work falls into a comparable pay band, why wouldn't the employee receive the same rate of pay? 9901.353 "Subject to DoD implementing issuances, DoD may set pay anywhere within the assigned pay band when an employee is promoted to a position in a higher pay band." What are these "issuances"? It would appear that an employee could be "promoted", but recieve less pay. 9901.361 appears to give the Secretary the discretionary authority to NOT pay a premium for overtime, Sunday, holiday, night shift, and hazardous duty work. Why do people working in these situations not deserve premium pay? There is absolutely nothing to indicate just how wide the pay bands might be. Could an employees' pay fluctuate by $2000 a year? $5000? $10,000? It's already obvious that under NSPS, funding will affect an employees' pay as much or more than performance. How is that fair to an employee? In general, the proposed changes have nothing to do with "pay-for-performance", and everything to do with reducing federal employee's pay, subjecting them to system in which what few protections they had are removed, and bringing back the cronyism and favoritism that the current pay system was designed to eliminate. The proposed changes will have a severe negative impact on employee moral and productivity, as evidenced by the employee response to the pilot program at China Lake. These changes should not become law.