| Comment Number: | OL-10500953 |
| Received: | 2/22/2005 5:54:14 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:
To date, there has been a lack of identification as to how the pay bands will be structured. Nowhere within the NSPS web site, or within the proposed regulations published Feb. 14th, is the actual structure of the pay bands discussed. How will the bands be set up relative to the current GS grade and step system. Into which pay band will administrative, technical, and professional positions at the GS-13, GS-14's, and GS-15 levels fall? How can employees and others provide comments on a system that has not fully been disclosed? How can the unions address these issues when they don't know how there covered employees may be affected. The draft pay banding chart that I saw over a year ago was very disproportionate in it's grouping of the bands. GS-13 and 14 employees were grouped in one band while GS-15's were by themselves in a separate "band". This was proposed despite all of the demonstration programs that are currently in-place (SPAWAR, NAVAIR, NAVSEA, etc.) are using pay banding that show GS-14's and 15's together in the same band. What will happen to those employees currently in that pay banmd if the new NSPS system has them included in a lower pay band. That proposed pay banding schedule has disappeared and no-one knows what the final one will look like. Is there a separate pay band for engineering vice professional (executive and managerial) positions? The reason I ask is because within the Naval Facilities Engineering Command, and I am sure within others, many one time engineers are no longer performing engineering related duties. They move up into executive positions and the command keeps them in 800 series positions to make it appear as if they need lots of engineers. Many of these jobs, are executive in nature and not at all related to engineering. If there is a special pay band for scientific and engineering series, how will you insure that this "cheating of the system" doesn't occur and the employees receive additional pay that is really not appropriate? I request that the proposed pay banding structure the pay band levels themselves and the current GS grades that will be included), which is a major critical element and change from the current system, be published prior to the NSPS system going into effect. This will allow all employees and others concerned to voice concerns and provide beneficial suggestions.