Comment Number: OL-10501871
Received: 2/28/2005 10:57:00 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. The NSPS creates a "pool" of funding for performance-based salary increases, peformance award bonuses, and/or a combination of both. This "pool" is created from funds generally allocated for awards (e.g. 1.5% of base labor, etc.) as well as annual Cost of Living Allowance (COLA), excluding locality pay. COLA's are not performance based and should not be utilized within this "pool". Every employee should recieve a COLA, unless that employee's performance warrants reduction in pay, then that employee would not recieve a COLA. This will be a very senestive issue of the NSPS program. 2. The "National Security" Personnel System has absolutely nothing to do with National Security. If it does, then why isn't the implementation plan nationwide across all governemental in all govt. agencies at the same time. 3. The current pay and rating system is performance based already. NSPS touts that it is pay for performance. WIGIs, under the current system, are not to be awarded unless an employees performance is acceptable level. Additionally, employees may be reduced in pay if their performance doesn't meet established standards, not only for the series, but the indiviudal position and employee standards. 4. All the objectives of the NSPS can be attained within the current pay and rating system, including RIF based on performance (as it is already, however it isn't the prirmary factor - but one simple change could ensure that performance is - although I don't believe performance should be the primary factor when assessing RIF due to the fact that supervisors do not and will not fairly rate employees across the board). 5. The NSPS will be offers more chances for abuse than the current system. Local managers will not be permitted to determine award amounts based on the fact that those who make larger amounts of salaries will be taking the larger share of the pool, leaving little for field managers/supervisors. The implementation needs to be clear as to who is responsibile for what task within NSPS prohibiting local HR or non-field personnel from dictating awards, etc. to the field. This is a serious issue that needs to be addressed well prior to implementation.