| Comment Number: | OL-10501338 |
| Received: | 2/24/2005 4:18:41 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:
Pay and Pay Administration - Subpart C National Security Compensation Comparability --"to the maximum extent possible" (when addressing funding to be allocated for years 2004 - 2008) Funding for the new NSPS is very vague and not very well defined. Setting and Adjusting Rate Ranges "The system will have a rate range with a minimum and a maximum rate..... This system seems to be discriminatory toward older workers who are likely to be at the higher end of the range. Pay raises and bonuses cannot exceed the maximum rate, so won't that leave workers at the higher end of the pay band with nowhere to go regardless of performance? In general - throughout the NSPS proposed rules, the system is being described as a pay for performance system. Yet in the legislation H.R. 1588 - 252 5404 HUMAN CAPITAL PERFORMANCE PAYMENTS (a) (2) " The number of employees in an agency receiving payments from the Fund, in any year, shall not be more than the number equal to 15 percent of the agency's average total civilian full and part-time permanent employment for the previous fiscal year." I did not see these quotas addressed anywhere in the proposed rules. How can this be a pay for performance system, if it is already predetermined that only 15% of employees are worthy of payment? In the business world, bonuses are usually tied to profits or how well your business is doing. In high profit years, the "pot of money" the company has is very full and you get a good bonus/payraise. In low profit years, the pot is not full and the bonuses are slimmer. In Government there is no profit. If your agency is very efficient, that could mean a reduction in your budget (how often have we heard, "Do more with less"). Under this new system, there is no assurance that the funding for salary increases won't be diverted to some other requirement.