Comment Number: OL-10502996
Received: 3/3/2005 4:26:19 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:

When determining the pay bands, please group GS-13 with GS-14 as a minimum, but ideally GS-13 should be grouped with GS-14 and GS-15. In most instances at HQ the GS-13 is performing work of the same difficulty & responsibility as those in the GS-14/GS-15 positions (especially in DoD). Most GS-14s are in non-supervisory billets. During a demo project held at my activity from 1999-2002, GS-12/GS-13 were in one payband, and GS-14/GS-15 were in another. When the demo was halted, there were myriad GS-13s and GS-15s and few GS-14s and GS-12s when we converted back to the General Schedule. Ideally, inclusion of more pay grades in the top band would ensure a more even distribution of workers within the band, versus clusters at the top of smaller bands.