| Comment Number: | OL-10502023 |
| Received: | 2/28/2005 5:40:09 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-Adjusting Rate Ranges and Local Market Supplements: Local market supplements (similar to locality pay) should be a fixed per centage for all employees. A career group or pay band should not factor in to who will receive this supplement. Local economic trends affect all persons regardless of one's function. Cost of living raises should be automatic regardless. Inflation impacts us all. Performance Based Pay: In some regards this is already in place. Currently, if one performs, one receives a high appraisal and performance award. This award is based on a percentage of money available for this purpose which will be the same case for performance based pay i.e. the performance pay pool and/or bonus. It too will be distributed base on the funding approved for that year and ear-marked for that pot of money. Performance Management-Subpart D: The register implies that while employees of a specific career group can have the same performance elements, there could be differing performance goals for the individual. It seems this could give way to favoritism or, the extreme, guaranteed failure if the supervisor dislikes the employee. Potential for back-stabbing/undue tension exists as employees vie for the good projects or attention getting assignments. There will be no team work when competing for dollars comes into play. And while like-graded employees get the same pay regardless of work ethic, it's a much better atmosphere than worrying who's doing what in the next pod. Actually, there already exist procedures the supervisor can initiate to weed out non-performers. Many supervisors do not want the hassle of the paper work to follow through on this. Perhaps restructuring this process is more practicable than revamping the current system. Recruitment and Competitive Examining: I'm unclear on this. Will vacancies be offered first to current employees? Or does "DoD will provide public notice for all vacancies in the career service and accept applications from all sources" do away internal promotions and utilization of experienced employees. It very hard in the current climate to compete with the "total person score" concept when those with a few years in service but a college degree can come out ahead of the experienced "senior expert." While much talk is said about the impending loss of seasoned, knowledgeable employees, there seems to be a trend to score more for education than experience. NSPS will only facilitate that attitude. I feel there are too many questions left unanswered in the Federal Register. But in general, I think NSPS creates more problems than it resolves. It will cause mistrust in our supervisors, create animosity between co-workers, create tension in the work place, lessen team work, create uncertainty in future financial security.