Comment Number: | OL-10503694 |
Received: | 3/7/2005 12:38:24 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:
The NSPS statute requires that between 2004 and 2008, to the maximum extent practicable, the amounts allocated for compensation of employees covered by NSPS cannot decrease below what it would have been if NSPS had not been implemented. After 2008, to the maximum extent practicable, NSPS regulations must provide for calculating the overall amount to be allocated for compensation of employees covered by NSPS in a way that will ensure that in the aggregate employees are not disadvantaged. Please define practicable as it pertains to the statement above. After 2008, it appears as though amounts allocated for employee compensation has the potential to decrease, provided that the overall amount allocated for compensation is calculated in a way that ensures that in the aggregate, employees are not disadvantaged. Why do the regulations distinguish between the time befoe 2008 and after 2008? Is there an anticipated decrease in funds allocated for copensation after 2008? Wouldn't any decrease in pay following 2008 result in disadvantages to "the aggregate"? Please define "the aggregate". The NSPS statute should require that to the maximum extent practicable, the amounts allocated for compensation of employees covered by NSPS cannot decrease below what it would have been if NSPS had not been implemented. The time limitation for this provision should be eliminated to ensure that compensation allocations will never decrease as a result of the propsed NSPS program.