| Comment Number: | OL-10500706 |
| Received: | 2/18/2005 3:49:26 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 and Pay Administration Subpart C page 7560. There is a lot of subjectivity allowed one supervisor in performance rating. My experience at several DOD Districts under the current system is that most supervisors do not give performance awards. They tend to resist any additional paperwork in rating and give an average rating regardless of above average and outstanding work performance. The few that get performance awards are usually supervisors at elevated grades. Thus the benefits of automatic GS step increases compensate for this. I predict that this rating philosophy will not change much under the new system. The majority will not receive objective ratings. This will hit especially hard after 2008 when pay pool potential amounts will probably be significantly reduced. I believe the demonstration projects have an inherent bias to prove results and would reflect higher ratings and pay performance. Pay and Pay Administration, Subpart C page 7560under Performance payout. Two groups of employees can be especially negatively impacted under the new system. First, employees at Level 1 of their career group. These employees that are near the top of Level 1 may only receive a bonus payout or partial bonus and not an increase to pay. There would be no future adjustment compounding (paycompounding) or retention on this amount because it is not a pay increase. These employees at that level have normally put a lot of years in, and probably have considerable experience. They will suffer at their pay banded level which also happens to be the lowest pay compensating level. Additionally the supervisor might characterize a lower rating so as as not to cause a differentiation that would include two attributes of the payout. The important point here is that if there are not periodic and equitable rate adjustments these employees do not get much pay incentive. And under our current federal deficit there may not be many optimist that believe the rate adjustments will offset guaranteed increases in the cost of living. Additionally the proposed regulations allow differences in the minimum and maximum rate adjustments. Please consider the predicament of the above mentioned group of employees who have been in the trenches and served the agency well. The other group of employees that will most likely be hurt are also at Level 1of their pay band. That is, at the entry level or minimum pay rate of their band. Under the current General Schedule System these employees automatically receive approximately a three percent Step Pay increase every year for their first four years. It is probably very doubtful that compensation will be equivalent under the newpay for performance system. Again minimal rate range adjustments can really hurt salary value. page 7553 Supplementary Information, under the The Case For Action refers to positive results in career growth, attracting skilled, talented and motivated people and also retaining the existing workforce. The proposed new pay banding system when compared to the current GS System above indicate a potential future pay loss to a current experienced employee promoting to a higher pay level. No doubt more responsibility is assumed for the promotion position at rewards not comparable to the GS current system. At one time discussions were mentioned of getting DOD employees pay comparable to the private sector. I fear that elimnation of automatic steps and potentially low rate adjustments will steer perspective valuable employees toward the private sector. I do know that there is federal employee sentiment that we have rolled with the punches for so long and seen government reorganized and reinvented so many times that we are frustrated. Some of us old timers remember when the DOD did a lot more in house work. We had a few more full time employees, accomplished a lot. Now we are made to contract at much higher cost and difficulty. Please keep us and DOD's future in mind.