| Comment Number: | OL-10503355 |
| Received: | 3/5/2005 8:41:53 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:
This is where we really have to hold onto our hats. The proposed regulations do away with the General Schedule and Wage Grade systems, so Congress will no longer be involved in setting or adjusting basic pay or in providing cost of living increases. Instead, the proposed regulations provide that each employee’s pay will depend on his pay schedule and pay band, his rate range, his local market supplement and his performance payout (based on his performance rating). And all this will be set by DOD, not Congress. And how DOD will go about making these determinations will be revealed later in “implementing issuances.” Will there be wage surveys in which unions can participate? How will DOD determine what jobs in the local labor market are comparable to DOD jobs? Which local markets qualify for a supplement and which don’t? How often will DOD conduct wage surveys and adjust basic pay? How can anyone comment on this new pay system without knowing any of its details? Despite the lack of detail, there are a couple of provisions that are particularly troubling. Section 9901.343 would allow DOD to reduce the basic pay of an employee whose performance or conduct are unacceptable by up to 10 percent. A supervisor could bombard an employee with these actions to the point of cutting the employee’s pay in half in 5 years. The proposed regulations also provide that, upon promotion, an employee’s pay can be set anywhere in the higher pay band. This eliminates the provisions of current law, which control the exact grade and step an employee receives upon promotion. The opportunities are rife for abuse as management officials vary the pay of each new employee promoted, depending on how much they like the employee, whether the budget that year is tight, whether they were told they were too generous with the last promotion, etc.