Comment Number: OL-10504501
Received: 3/9/2005 3:02:56 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:

First, I would like to request that another public notice and comment period be made available once the details of the NSPS are determined. An additional public notice and comment period should be provided before NSPS is implemented since the current public notice is too vague to determine if NSPS is in the best interest for federal employees, the public and for national security. It’s true; under the GS system “high performers and low performers are paid alike.” However, at the very least the “high performers” are still being paid what they anticipated and accepted. As it is in my case, I have 4 years of federal service with the same agency. Two years ago I began a 0401 position as a GS 7, knowing that if I performed well, that non-competitively I would be promoted to a GS 9, then to the full potential GS 11. Currently I am a GS 9 and as it now appears, I will never get to the anticipated GS 11 salary (under NSPS) in the time frame that the GS system allows. I have always received top performance ratings and consider myself a top producing employee, but the fear of the unknown is setting in. The public notice states that “Employees in developmental positions may receive pay adjustments as they acquire the competencies, skills, and knowledge necessary to advance to the full potential level.” With that statement, what is the anticipated time frame that people in my situation will face to get to their full performance salary level for the non-competitive promotional position they accepted prior to NSPS implementation? In a discussion with my supervisor, he said that I “will get to that salary level, but under the proposed plan it may take longer since increases from a GS 9 to a GS 11 salary is significant.” That is unacceptable for the federal government to drop their unfulfilled agreement of non-competitive promotions with its high performing employees not at their full performance level. Under the GS system, it was understood that if I worked hard and received top appraisals that in 3 years I would be a GS 11, now I won’t, and won’t receive a comparable salary under NSPS within the same time frame. Section 9901.409(g) the NSPS document states, “A payout determination will not be subject to reconsideration procedures.” Meaning there could not be a review for appeals. The NSPS plan should be changed to allow appeals. Prior to NSPS, I always felt that I would continue working for the Federal Government for the remainder of my career. I enjoy my position, understand the mission and believe in it. The NSPS plan has me now deciding on a possible career change. I chose the government for the stability and for the GS system. If I wanted a position similar to a private sector position, I would have taken one. Mind you, I am a young employee, but I am confident that I could find positions in the private sector that would pay nearly twice as much for experience I have gained and would have a similar job and salary instability as proposed under NSPS. Last, according to the information provided in the February 14, 2005 public notice, NSPS should not be implemented. Revisions are all that the GS system need. Like I said in my second paragraph, fear of the unknown is what has been created. Again, I would like to request another public notice and comment period be conducted after details are determined.