| Comment Number: | OL-10502203 |
| Received: | 3/1/2005 11:13:11 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:
The intent and concept behind NSPS seems generally good, but I some concerns: (1) Regarding step increases: The conversion may have the effect of denying pay for step increases, especially for employees that would otherwise be due step increases shortly after conversion. A reasonable solution would be to prorate the next scheduled step increase. Increase the pay by a portion of the next scheduled step increase, based on the ratio of the amount of time since the last step increase to the total time between the last and next scheduled step increase. For example, someone who has been at step 8 for 2 years would get 2/3 of the difference between step 8 and step 9 added to his pay upon conversion. (2) Regarding pay bands: There is little detail regarding pay bands, other than that they are at the DoD’s discretion. How many pay bands will there be? Will there be separate pay bands for various localities? What is the pay range of each band? Which pay band will my position be in? These questions are not answered. The regulations should answer these questions and have sufficient detail to enable me to determine which pay band I would be in and where in the pay band my salary would fall. If the regulations are adopted without this information, the parts of NSPS relating to pay bands should not be implemented until such time as these questions are answered and an additional comment period, etc., is afforded. (3) Regarding performance: The current civil service system was enacted to address various pay and performance previously present in the Federal sector. It seems that under NSPS, the pendulum is swinging back to pre-Civil Service Reform Act days, leaving an increased potential for unequal and unfair treatment of individual employees than under the present system. (4) Training: We have had very little training on NSPS. For the most part, it has been limited to internet links and requiring us to do our own research. Additional, preferably classroom style training is needed before implementation. Many employees likely do not yet know even enough to make meaningful, well-thought-out comments to the proposed regulations. (5) Leave: Will the current provisions for earning and using leave (i.e. annual, sick, military, court, etc.) and credit hours be retained? If not, the particulars need to be shown and an additional comment period, etc., given before implementation.