| Comment Number: | OL-10501505 |
| Received: | 2/25/2005 1:56:53 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:
Subpart/section 9901.322(d). This appears to be just one way of compressing employee’s salaries. The minimum rate can go up by some amount (to attract new employees?), but the maximum rate can remain the same indefinitely, thereby harming good employees who simply happen to be at the high end of the pay band. Subpart/section 9901.342(b) (2). This subpart leaves open the possibility that employees may never receive a pay increase, just a yearly bonus. That possibility would have a very significant impact on the employee’s future retirement pension since the “high three year’s salary” would be drastically lower for use in the retirement formula computation. The application of using bonuses, in lieu of actual pay increases in salary, would most likely have a detrimental affect on good performance. Subpart/section 9901.342(d) (3). Not only are maximum pay band amounts set arbitrarily, but under this section DoD can set a “control point” that would make it almost impossible for an employee to even reach that maximum amount. Employees thinking they had a “wide” pay band in which they could rise to the top, based on demonstrated performance, could find that the “wide” band was in fact very “narrow.” If this “control point” concept remains in the law, then employees should be notified at the start of what the control point is in each of the bands, so they can be aware of the potential likelihood that they may never be able to achieve the advertised “maximum” amount of their pay band. Subpart/section 9901.343(d) (4). This subpart allows for the possibility that an outstanding employee may never receive a pay increase for their performance. This is not only counter-productive to attempting to incentivize good performance, but it is blatantly unfair to employees when it comes to computing retirement pensions.