| Comment Number: | OL-10501005 |
| Received: | 2/23/2005 8:22:25 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:
1. There is a lot of fluff in these regulations-- the introductory section is roughly half of the document. I see very little value added from "The Case for Action" (p 7552) through "Outreach" (p 7556). Regulations should not attempt to explain why they exist- that is the job of other items (doctrine, implementing documents). It confuses employees and supervisors who are just trying to read the reg and understand the system. 2. Most of us employees will be primarily interested in section 9901.342 (Performance Payouts), since that will affect every employee's pay. Unfortunately, the regs are relatively vague as to a) how much money goes into the pool and b) how the performance shares are set. There are all left to the implementing regulations. The format and GS grades merged into the broad bands (9901.321) are also undefined. All of these items were very well described for predecessor systems (AFRL lab demo, China Lake lab demo), but are not defined in these regs. Given the lack of explicitness, it is otherwise difficult to say anything about the system. 3. My concern is that the "pay for performance" seems to really only affect FUTURE pay increases. Thus, it locks in past "seniority pay". Therefore, if you have an older employee with a relatively high pay, who is not performing, he has far less incentive to improve performace than a new employee. For example, take two hypothetical employees, a new GS-12/1 hard-working employee (Mr. Henry Hardworking) and a more senior but less motivated GS-12/8 employee (Mr. Larry Lazy): Original GS system FY05 ROUS Pay: Mr. Hardworking- $60576 Mr. Lazy- $74704 Assume under the system there is a max 5% annual raise due to performance. Mr. Hardworking is a strong mission-focused performer and gets the maximum raise every year, but Mr. Lazy gets 0% because he hardly works and shuffles paper at his desk: FY06 pay: Mr. Hardworking- $63605 Mr Lazy- $74704 FY07 pay: Mr. Hardworking- $66785 Mr Lazy- $74704 FY08 pay: Mr. Hardworking- $70124 Mr Lazy- $74704 FY09 pay: Mr. Hardworking- $73631 Mr Lazy- $74704 FY10 pay: Mr. Hardworking- $77312 Mr Lazy- $74704 In effect, Mr. Hardworking could be working twice as hard as Mr. Lazy, and getting the max bonus, yet it takes SIX years before his pay even reaches Mr. Lazy's pay. Thus, depending on the cap in annual raises, this system is not a DIRECT performance pay system-- the system is highly affected by people's entering seniority. I'm not completely clear how this keeping of existing "seniority pay" through the starting base pay will meet the governments stated "compensate based on performance/contribution to mission" (p 7555). This above situation seems to be the exact problem you're trying to "fix"-- but I'm unclear that it really provides incentives for Mr. Lazy, since he already has high pay based upon pre-NSPS seniority. I suggest that the lower the entering "base pay" and the higher the max annual increases, the more performance-based the system will become. 4. As a USAF employee who lives in a Spiral 1/first increment location (Eglin AFB), I am very interested in how you will be changing my pay and assessment, but I fear there is little "hard" information yet, even 5 months before proposed implementation. We're looking forward to some real details.