| Comment Number: | OL-10504286 |
| Received: | 3/9/2005 1:12:05 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:
Since the introduction of the Aquisition Demonstration Program, I have repeatedly expressed a concern regarding pay banding and the possibility for negative effects for women and minorities. If you examine EEO data for most agencies you will find that women and minorities consistently occupy lower grades in greater percentages that white males. Under the Civial Service Reform Act, it is possible for women and minorities to be non selected for merit promotion more often and also to receive fewer Quality Step Increases than white males. However, if one does manage to get promoted, unless the superviosr goes to the trouble of rating the employee at less than fully satisfactory, women and minorities are assured of step increases over time (rewarded for longevity). I fully expect to see the same proportions of women and minorities at the lower end of the pay bands as there are now women and minorities in lower graded positions. As long as you leave the pay increase decisions to those same selecting officials you are opening women and minorities to additional adverse impact from subtle discriminatory practices. This is exacerbated by denying employees any representation when setting pay increases which now reflect performance (including awards). At least Unions were allowed in some circumstances to participate in awards committees. I have been in nontraditional career fields for women for the last 30 years. Every year management has denied that discrimination exists, and asserts that this is a new age where this doesn't happen. And yet, the No Fear legislation was enacted out of frustration with lack of accountability in the area of equal opportunity. What will DoD be doing under this new system be doing to prevent the results I have predicted?