| Comment Number: | OL-10501384 |
| Received: | 2/24/2005 11:05:46 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:
(Comments continued from previous submittal) 7. What is the purpose of replacing the existing government-wide locality pay system with another type of locality pay called "local market supplement" that is specific only to the DoD? Since no details are provided on this new locality pay system, it appears suspicious. 8. What exactly is happening with annual adjustments to the pay scale based upon cost of living (COLA’s)? The Federal Register mentions that applicable across-the-board pay scale adjustments will be lumped into the "performance pay pool", implying that COLA’s will go away for DoD, and that “periodic” pay scale adjustments will be made, presumably in lieu of annual COLA’s. It is certainly not fair to take money that Congress intended to offset annual inflation and to place that money into a performance pay pool. The performance pay pool sounds like it could become a big shell game used to reward political friends and reduce aggregate salaries of civil servants. Any employee who does not receive an annual inflationary adjustment to pay, essentially gets a pay cut. What is to prevent this type of pay cut from happening year after year for an employee performing at an acceptable level? What is to prevent the pay pool from being raided and manipulated by political appointees and senior level managers? The document lacks adequate details on the pay pool. 9. The Federal Register is unacceptable on subject of challenging performance ratings. The Federal Register says that performance ratings cannot be grieved. Also, nothing related to the way a supervisor measures or determines performance can be grieved. However, it also says that some undetermined process for reconsideration will be developed. Why is that process not yet determined or mentioned at this stage? Will that process be an appeal to the same supervisors who gave the rating, as was done in some of the DoD demonstration projects? Given the enormous new impacts of a performance rating on an employee's pay, pension, working conditions, and job security under NSPS, there needs to be a clear, fair and transparent way for employees to challenge performance ratings. Furthermore, all salaries and ratings should be public knowledge. Imagine how demoralizing it will be to find that a coworker performing the same job at the same level is making $30,000.00 more per year because he is a college buddy of the supervisor? This NSPS reconsideration process must allow an employee request for reconsideration to proceed beyond mid-level management, who will almost always back up their hand-selected first-line supervisors. The reconsideration process must be able to proceed to a neutral third party if necessary. 10. There are waiver clauses for the Secretary of Defense for many matters in the document. Will he use it sparingly or liberally? Will the next Secretary of Defense use it sparingly or liberally? These waivers will promote instability, and therefore are contrary to national security.