Comment Number: OL-10500554
Received: 2/17/2005 8:34:45 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:

How will you ensure that this system does not become driven by congressional funding vice market conditions/performance/changes in duties. It seems that after 2008, unless funds are specifically designated for payroll, commands will be able to shift funds from labor to support at the expense of the competitive reasons for which the system is designed. Funds designated for payroll that are not used for payroll should be required to be returned to the government to pay down the debt. I have personally seen funds shift from payroll to support to purchase new furniture for a commanding officer, etc. There must be some level of trust that the funds are truly earmarked for a specific purpose and unavailable for cost transfer to another purpose. In addition, There have been concerns floating in the civil service community, that in areas such as those in california that have piloted pay banding, the pilot only resulted in reduction in payroll funds under the guise of transformation.