Comment Number: OL-10502460
Received: 3/2/2005 9:01:57 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:

Reference Pay and Pay Administration - Subpart C: Career-ladder Positions: 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. While understanding pay bands have not been established, there is concern from employees in target grade positions that they will lose out on receiving compensation by moving into NSPS. For example: An employee is selected for a GS-07 lead 09 lead 11. S/he converts into NSPS being placed in an entry/developmental band encompassing GS-07/09. Eventually, s/he will be promoted to a full performance band. Unfortunately, the employee will have lost out on a pay increase from the GS-07 to GS-09, which would have been obtained if remaining in the GS pay system. It appears that employees will be given one pay increase for being in developmental positions versus two or three by remaining in the GS pay system. DoD employees would have a disadvantage versus non-DoD employees. In addition, it would create morale issues for the workforce. My suggestion would be to follow the procedures set forth in the Science and Technology Reinvention Laboratory Personnel Management Demonstration Project and not convert employees in target grade positions until reaching their full performance grade. Otherwise, ensure all employees receive the same amount of money as would have received if not participating in NSPS. The intent of a demo project is not to penalize the employees salary-wise. We would not want the employees to receive less money than they would have received had they stayed in the GS system.