| Comment Number: | OL-10503002 |
| Received: | 3/3/2005 4:36:17 PM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| Attachment: | final_pay.pdf Download Adobe Reader |
Comments:
I support an attempt to improve the employee compensation system. I have expertise in the evaluation of such systems, and served the federal government with respect to improving the operation of the General manager program some years ago. A colleague and I have studied the pay banding system proposed in the Federal Register article under consideration, and we have noted a significant and, we believe, important problem with pay equity. The pay banding system, as defined, will not pay employees in a manner that is independent of group membership. We have documented our research in an article that is provided as an attachment. I believe it is imperative to remedy this deficiency in the current proposal in the interest of conformity to law and basic principles of fairness in our great nation.