| Comment Number: | OL-10502650 |
| Received: | 3/2/2005 2:51:51 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:
p 7574, left column The phrase, .."the marginal cost of the accelerated payment of earned WGIs is difficult to estimate…" needs revision. Under the transition scheme, primary organizational elements will transition to NSPS over time. Give the allocation of folks in the POEs, HR data shows who is eligible for WGI and when they are eligible. HR data can show what fraction of WGI employees are due at the proposed date of transition. From that analysis, a POE can get an estimate of the WGI buy in required. And a summation of all POEs that transition on a target date is the Department estimate. A Department down estimate maybe difficult to do, but a POE summation up is do-able. Given the budgetary impact of the transition cost to a POE, the POE is going to be required to do the estimate anyway, why not sum up all the POE's cost and come up with an estimate. I dispute the degree of difficultly that really is required. Waving off something as difficult, doesn't remove the obligation of POEs to know what impact this transition will have on the organizations mission dollars available.