| Comment Number: | OL-10504872 |
| Received: | 3/10/2005 11:47:10 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:
Subpart F, Sections 9901.601 to 9901.611: The current retirement system implemented for Civil Service personnel (FERS) is not equivalent to that in private industry. For example, the retirement annuity computation formula for Northrop Grumman Corporation is 1.667% times the highest salary of the previous three years. FERS on the other hand provides on 1% of base pay. Industry employees have the same or better 401k and social security plans as well. For the employee, the total package of Pay, Benefits and retirement plan comes down to risk associated with the tenure of employment. That is to say that jobs with increased risk of lay-off, or "RIF" should carry a commensurate increase in pay, benefits and retirement. The NSPS, specifically with regard to workforce shaping, increases the government employee's risk of losing their job without a commensurate increase in pay, benefits and retirement seen in private industry. If the employees are expected to perform under commercial standards and at the same risk of job loss, then the compensation, or at least the ability to bargain for additional compensation by the employee, must also be factored into the system.