Comment Number: OL-10500798
Received: 2/22/2005 7:44:03 AM
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, pg 7560 “Example: If the maximum of a pay band is $30,000, and an employee earning $28,750 is awarded a payout of $3000, then…paid as a bonus.” Concerns – While I understand the point of this example was to demonstrate the split between a basic pay increase and one-time bonus because of the rate range being exceeded, this example brings up other questions. - A $3000 award for a $28,750 employee – average or high performer? - Using the Table 2 – Sample Rating Methodology, pg 7560, what is the value of each share? Is it a dollar value? Or a percentage value? If I earn 6-8 shares is that a 5% raise or 8% or 10% or more? Or is it 2%? Or less? Or is the method of determining the payout something like this: Assume a pay pool of 100 people, assume 15% get the highest ratings and 5% do not meet the standard, then: 15 people(7 shares) + 80 people(4 shares) + 5 people(0 shares) = 105+320+0=425 shares If the pay pool had $50,000, then a high performer would get 50,000/425*7=$823 If the pay pool had $100,000, then a high performer would get $1647 If the pay pool had $200,000, then a high performer would get $3294 Change one assumption, there is no cap on high performers, then: 35 people(7 shares) + 60 people(4 shares) + 5 people(0 shares) = 245+240+0=485 shares If the pay pool had $50,000, then a high performer would get 50,000/485*7=$722 If the pay pool had $100,000, then a high performer would get $1444 If the pay pool had $200,000, then a high performer would get $2888 These examples show that while your system “ideally” is designed to reward annual pay increases based on performance/contribution rather than longevity, which would enable employees to have a greater opportunity to affect their pay through excellent performance, it doesn’t really accomplish this. In the above examples, the high performing employee’s payout is dramatically affected by: 1. the money available in the pool 2. the ratings/shares earned by others in his pool 3. the number of people earning the shares Not one of these factors has anything to do with individual performance! Throw in the fact that the pay pool manager ultimately determines your rating/shares and the employee’s performance is but, a small part of the payout. You’ve actually created a system where the better a large group of employees perform, the less money is available to reward them! Credible and trusted? Not at all.