| Comment Number: | OL-10500926 |
| Received: | 2/22/2005 3:42:24 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:
Sec 9901.322 Setting and Adjusting Rate Ranges: I recommend that regulations mandate that both the minimum and maximum rates for a pay band be increased by the same percentage that Congress authorizes for pay raises for non-NSPS employees. For example, if Congress authorizes a 3% pay increase, then the minimum and maximum rates of a pay band should be increased 3%. Otherwise, pay banding compression – similar to what has happened in the FAA – will result. Currently, the top pay grade, GS-15, step 10, is increased automatically each year by the percentage authorized by Congress. Under NSPS, there is no obligation to increase the maximum pay available - DOD has complete discretion. Given the regularity of the Administration’s opposition to the size of Congressional pay raises, I would be shocked if DOD raises the upper pay band limit the same percentage that Congress authorizes for non-NSPS GS-15, Step 10 employees. This ultimately affects the amount of money the government matches for TSP, life insurance and the retirement base for long term employees, who are performing at a fully satisfactorily level. (Over a 20 - 30 year career, this will cost an employee tens of thousands of dollars in reduced compensation, which is why I believe one of the unstated reasons for NSPS is to save money on personnel costs.)