| Comment Number: | OL-10502375 |
| Received: | 3/1/2005 7:00:54 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:
As a member of a group that volunteered for Spiral 1.1 my concerns are immediate and personal. I am in a developmental position as a functional intern and have been advanced in grade on the first of the year for my non-competative promotions within my career track. If we start the NSPS system this summer and the evaluation process takes 9 months to a year before monies are available for promotions/raises/bonuses then I will not be compensated per the original agreement that was in place when I became a Federal Service employee. My next promotion is supposed to be to the target GS-11 level in January 2006. This equates, with an average annual cost of living increase of 3%, to a $10,000 annual increase in pay. If I am forced to wait for a possible increase under NSPS, considering evaluation of the system, input from management feedback, adjustments to the process, etc., then my original appointment is not worth the paper on which it is written. I have not seen in the proposed regulations where this specific situation is addressed. On page 7561, under Developmental Positions, the regulation states: Employees in developmental positions may receive pay adjustments as they acquire the competencies, skills, and knowledge necessary to advance to the full performance level. This is great stuff once the system is fully implemented but not when we need to spend time initially evaluating the system for an indefinite period. The caveat is further down the page under Career-ladder Positions. It states that: Employees in career-ladder positions below the full performance level will be placed in the appropriate career group, pay schedule, and entry or developmental band. This means that half-way through my progress toward GS-11, I will stagnate in my current grade/salary months longer than I my initial agreement indicated. This is money I should earn and that I will never be able to make up. My question to our DoD leadership is this: Will you address the transition of developmental positions in NSPS as a pro-ration of the promotion? This idea is similar to the transition step increases given in demonstration projects. Although people in similar postitions to mine would still get hosed using this process, it wouldn't be as severe a hose job as ignoring the situation completely.