| Comment Number: | OL-10504733 |
| Received: | 3/10/2005 9:41:41 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:
Frankly, I am not that opposed to the new so-called pay for performance system since I have been in step 10 for years and I should be able to justify pay raises based on my performance. My problem is: 1. What will the performance measures be and how will workload be weighed evenly? In Regulatory, we have some that work on very difficult projects or program improvements that can be hard to measure. Others create actions in our RAMS permit accounting system and their numbers may be artificially "high" and easy actions to process. This system must look beyond "bean" counting and be fair. 2. What is the process to appeal inappropriate ratings - of self and others? 3. Most importantly, I don't see any significant increases in Regulatory budget so that performance can be rewarded with higher pay. Somewhat like an unfunded mandate. You will reward performance but if there isn't any money in the budget to fund such raises, how are you going to do it? We, in Regulatory, have a budget that is overwhelmingly salary-and-employee-benefits-based already, and we seem to get by from year to year by not filling vacancies because Congress doesn't give us sufficient funds to pay all employees (on-board and vacant). I have even heard it said that recent across-the-board-GS annual pay raises by Congress have not been technically covered in our budgets. We just somehow absorb it i.e., not filling vacancies, cutting travel and training, etc.