| Comment Number: | OL-10500675 |
| Received: | 2/18/2005 1:42:10 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:
Section 9901.212; 9901.231: Spiral One will be implemented this year. When (i.e. specific date) will DoD issue the implementing regulations that will tell the workforce how their grades will convert to particular pay bands? Section 9901.313 After FY-08, under what circumstances will DoD allocate less for aggregate civilian compensation than would have been allocated under the current general schedule system? We are at war. We will remain at war for the foreseeable future. Will the continued necessity to fund the war on terror be used to justify allocating less funds for aggregate civilian compensation? Section 9901.322 This section gives DoD “sole and exclusive” discretion to establish pay bands lower than the pay ranges associated with salary range of the general schedule grades to which the pay bands correlate. Is DoD’s intent to save money by paying its employees LESS than employees in other agencies? Why does DoD need “sole and exclusive” discretion? What could be wrong with a little outside review for reasonableness? Section 9901.323 Is there any required correlation between the “rate range adjustment” and the percentage of the annual general schedule pay increase enacted by Congress? Does DoD intend to adjust rate ranges annually to correlate with the annual general schedule pay increase enacted by Congress? If not, is it because DoD intends to fund the war on terror with funds that otherwise would be used to pay the civilian workforce that helps the U.S. fight that war on terror? Section 9901.342(d)(5) This section says DoD will determine the effective date of increases in basic pay. If DoD selects a date of 1 July, for example, then employees upon conversion will go a year and a half without a pay raise. Does DoD recognize this? Does DoD intend to implement a mechanism to avoid a prolonged stagnation of pay associated with the first year of conversion? Section 9901.372 This says the initial pay ranges “may” link to the ranges of the grades from which the pay band is converted. Why the equivocation? Does DoD intend to do this or not? Does DoD intend to set the range lower in order to save money? Section 9901.373 This section does not mention any pay increase to compensate the converting employee for time earned toward what would have been his/her next step increase. E.g., if an employee converts to NSPS one year after advancing to step 6, will he or she get credit for half of the increase to step 7? If you do not adjust for this situation, conversion to NSPS will result in an immediate negative and long-lasting impact to the employee’s pay and retirement. Stand by for morale problems. Subpart D DoN has a pass/fail system because the earlier, multi-tiered system was a failure. Supervisors and managers inflated evaluations because employees filed EEO complaints unless they got what they wanted. Supervisors and managers would rather give the higher evaluations than spend the next three years defending their personal and professional reputations against allegations of racism, sexism, etc. The NSPS makes no changes to the EEO system, yet expects managers and supervisors to suddenly make the “hard choices” associated with not only grading employees, but setting their pay. I’m not optimistic.