| Comment Number: | OL-10500658 |
| Received: | 2/18/2005 12:19:36 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:
After careful, lengthy review of the NSPS Federal Register, it becomes very apparent that DOD still has not a clue what NSPS actually will be. The Federal Register neither defines, nor gives substance to NSPS. Only vague references are made to “Pay Bands” and other components of NSPS without any concrete definitions. The entire NSPS Federal Register does little more than elaborate on the vague descriptions published earlier. Even more bewildering is the stated “Case for Action” which is supposed to convince the reader that NSPS introduces some new capabilities and flexibilities for managing the DOD workforce. Merit based pay already exist under the current General Schedule. Many incorrect statements are made to convince the reader that under the current General Schedule that pay increases are solely dependent on longevity. This simply is not the case, and as presented is misinformation. General Schedule Step Increases are only granted to employees performing at an acceptable level of performance (Full Successful rating) and may be denied to poor performing employees. Additionally, the General Schedule provides Quality Step increases to compensate the best performing employees by increasing their basic rate of pay faster than the scheduled Step Increases. Incentive and Performance Awards are also available under the General Schedule to compensate those outstanding employees who have progressed to the top Step of their pay grade. The only thing “new” NSPS provides for is moving Union bargaining from the local level to the national level. This could be accomplished through other methods not requiring the expense and time required to establish NSPS. The only ‘flaw’ with the current General Schedule is the way it is currently utilized by DOD management. If properly utilized, the General Schedule can be a powerful incentive pay system providing all the benefits NSPS promises. The insane notion that establishing NSPS will somehow correct bad management is just plain wrong. It is truly a shame that while our Nation is at war, top DOD management would use that fact to introduce, attempt to justify, and champion such a worthless, no value added, personnel system as NSPS. If NSPS is institutionalized, it will lead to lower employee moral, additional administrative overhead, retention problems and great difficulty in attracting new skilled workers to the workforce.