| Comment Number: | OL-10504233 |
| Received: | 3/8/2005 6:52:31 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:
While I am not opposed to "performance pay" in principle, I believe that for such a system to be effective in the federal government it would need to be carefully designed and well thought out. Based on the proposed regulations posted on 14 Feb 2005, I do not believe DoD has even come close to designing an effective system. "The devil is in the details" - and this document contains very few details. I would expect that by now (less than four months from the date DoD plans to implement NSPS) the agency would have worked out detailed plans for the design of the pay bands, detailed plans as to which specific job series/grades would move to which spot on the pay bands, detailed Reduction in Force procedures and a clear Priority Placement system. Instead, the proposed regulations consist of a vague outline of a system with promises of future "issuances" spelling out the details. A poorly thought out system, especially one not coordinated in advance with employees and labor unions will be disastrous for morale of both labor and management within DoD. Congress should reconsider their authorizing legislation based on this substandard document.