| Comment Number: | OL-10500730 |
| Received: | 2/19/2005 1:49:40 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: Initial Conversion pg. 7561 This proposed rule should not be accepted until the paybands are defined, and each position/GS grade is mapped to its payband and published in the Federal Register. I worked hard to be a GS11 and some alternate personnel systems have lumped GS5-GS11s together. This hurts the 11s and helps the 5s, and to me it is not acceptable to cut someone's pay. Also, I have a position that uses a special table and locality rate...I forsee my pay getting cut by this system. The section on page 7561 called 'Reduction in Band' also contains another way pay can get cut. If someone is not on the 'favorites list', their manager can decide to rewrite their job description and put them in a lower band and reduce their pay 'not to exceed 10 percent UNLESS A LARGER REDUCTION IS NEEDED...' I forsee this causing a lot of unnecessary pain, and it will not help morale any...NSPS might also be used to get rid of older workers by denying them raises using the 'performance' ruse. The current system has all the rules needed to manage performance. NSPS will not fix management problems. I forsee that any employee who can, will be looking for a job in an agency that still goes under the GS system rules. This will cause a loss of good employees. The performance payout section 9901.342 on page 7582 is not specific enough. It should be well defined with specific examples (which are not anywhere else in the document either). I suspect a manager is going to get a headache when they try to calculate 'shares' and do the rest of the math and spreadsheets needed to figure out what everyone will be paid. That's assuming that there will be money in the pay pool.... This new system will not be good for most employees.