Comment Number: OL-10502805
Received: 3/3/2005 12:26:28 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:

2 things about the NSPS concern me the most. (1) Will the pay pools give everyone a fair shot at reasonable and fair pay increases? I am concerned that an employee who is a high performer and is in a pay pool with many other high performers (say in a program management group) will get less of a pay increase, based on getting less of a rating ("everyone cannot be great") than someone in another pay band that is clearly better than others in the group. Also, I am concerned that there is no 'norming effects' between pay pools. As a specific example, would there be multiple pay pools at a site that has many competancy units that all contribute employee as members to an Integrated Product Team (IPT)? If so, would there be pay pools covering the various competancies (1 fof Program Management, 1 for Contracts, 1 for Logistics, 1 for Engineering, 1 for Business / Financial Management), or would the entire site constitute the pay pool? If there were sperate pay pools, then how does performance get normed across the pay pools? For example, lets assume that the Program Manager is an oustanding performer (hence his selection and position as Program Manager) gets rated a 5, and is awarded 7 shares. One of his team members from another competancy is not as high a perfomer, but since he is in a whole group of lower performing employees also gets rated 5 and awarded the same 7 shares. The lower perfoming employee therefore gets the same (or nearly the same) perfomance / pay increase as the more derserving Program Manager. What will be done to prevent this inequity from occuring? (2) What controls, processes, chekc and balances will be put in place to prevent supervisors from showing favoritism toward certain employees and not awarding rightful pay raises? In this new system, it is vitally important that any such situation not be aloowed to occur. Otherwise, the whole reson for inplementing the system, to increase performance, will fail as only those who are shown favortism by the supervisors will gain the pay increases. I have a few other concerns. (1) It is stated in the regulations that movement of the pay bands upward over time will be done similiar to the way the GS scale movers with general pay increases and locality pay increase, but how will they be set when all DoD personnel convert to NSPS (and there is no more GS)? (2) It has been said that a primary feature of NSPS is to make the hiring / firing/reassignment process easier to meet the requirements of the 21st Century. What provisions of NSPS actually do make these easier, especially the reassignment process? (3) In relation to major concern #2 above, what part of NSPS will ensure that supervisors do a good and thorough job of assessing their employees, compared to the system in place today? Today, employees are on pass / fail rating systems, and supervisors expend little to no effort in truly understanding individual's perfomance and how it relates to what is required by their customer / sponsor / team. What will prevent supervisors from not doing a thourough job of evaluation their employees? (4) How are GS grades going to be assigned into pay bands? Rumors abound that GS-14s will be grouped with GS-13s and alternatively with GS-15s. In my opinion, the work expected of GS-14s is more equal with that of GS-15s and they should be grouped there.