Comment Number: OL-10503784
Received: 3/7/2005 3:40:36 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:

My comments relate to pay banding and the abolishment of the annual cost of living raises. The following was posted on your web site. "The proposed pay system is intended to attract, develop, retain, and reward high-performing employees through appropriate compensation. The regulations provide a framework for the Department to move towards market sensitive pay based on consideration of local market conditions in setting pay band rates and in setting pay for new hires. Annual performance increases will be based on performance/contribution, rather than longevity. Larger increases will go to outstanding performers; unacceptable performers will not receive an increase. Adjustments to rate ranges will be determined by the Secretary. Increases associated with rate range adjustments will not be given to unacceptable performers" It is my understanding that the cost of living raises would be abolished under this plan. As a top step GS-14, I have nothing to look forward to in terms of a raise except the COL raise and any award my supervisor may feel I deserve. The GS-14's are not pay banded with the GS-15's so there are no performance raises allowed under your proposal for GS-14's other than a possible pay band shift or a possible supervisory performance award. I fail to see how this is a better system or even equivalent to what we have today. In effect, I believe it will reduce any raises I may have had over time, which will in turn even effect my retirement. I believe that the cost of living raise is just that. It should not be tied to performance. It costs more to live every year... period. My performance is at an acceptable level and I receive a bonus each year. I do not see an equivalent reward under this system. I believe that the real purpose of this system is to hold down the cost of civilian employees across the board, not your advertised purpose of rewarding those that truly deserve it, hiring, retaining, rewarding, etc.. I see it having the opposite effect. Apparently, the pay band will move when the Secretary feels like moving it, thus holding down all government salaries. If Congress were to approve a 3% COL raise and the President wanted 2%, how far do you think the Sectretary will move the payband? I know what I would do. Under this system, if you are at the top of a pay band, do you move with the pay band? Does the pay band move each year? If the answer to both or either of these questions is no, then you only confirm what I already believe as stated above. This is a bad idea and I can't find anyone who thinks it has merit. I think everyone would agree that the performance award system needs to change, but this proposal punishes those already performing at a high level and are unfortunate enough to be at the top step of their paygrade. This will take away the authority of Congress to grant annual cost of living raises and put that decision in the hands of one man, the Secretary. I believe this is wrong, I had a say in electing my representatives, I had no say in selection of the Secretary.