Comment Number: OL-10500902
Received: 2/22/2005 2:02:48 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:

REF: Pay and Pay Administration—Subpart C, Pay Administration, New Appointments/Reinstatements [Federal Register / Vol. 70, No. 29 / Monday, February 14, 2005 / Proposed Rules, 7561] By way of background and illustration, my agency has been selected for conversion in Spiral 1.1. I am a GS-1102-12, Step 6 who was reinstated in June 2004. My previous period of federal employment ended in 1978, at which time I was classified as a GS-1102-12, with 11 months in Step 1. During the intervening 26 years, I had diverse and progressively responsible experience in Government contractor and commercial contract management, program management, business development, and sales and marketing. Positions held were up to the senior management level with P&L responsibilities. Due to existing hiring practices in June 2004, this experience could not be taken into consideration in the grade offered at reinstatement (other than a 5-step increase in the grade I had previously held). Under NSPS, relevant non-Federal experience should be taken into consideration, not only for new hires, but for reinstatement cases, such as myself, in placement within pay bands. I strongly urge that this scenario be factored into the system design in order that such assets can be properly utilized and inequities by reason of pre-NSPS reinstatement precluded. Thank you for your attention.