Comment Number: OL-10504900
Received: 3/10/2005 12:31:26 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:

Pay & Pay Administration & Performance Management: Pay for Performance is a method of paying people less money for the jobs they currently perform at acceptable levels. Pay for Performance is not a method of paying employees bonus money and offering performance incentives. The current systems has adequate measures in place to reward exceptional performance while offering incentives and bonus pay. I'am very offended that this is being represented to the general public and to myself as a way to pay people more money for their current jobs. This is in no way an idea of how to pay Government people more money and incentives for their jobs. The idea is how to pay low performers less money not how to pay high performers more money. Pay for Performance assumes the 1st line supervisors will fix perceived pay inequities within the current GS system. Pay for Performance turns salary determination into a perception based system with full reliance on the first line supervisor's perceptions of employees performance. The Government/Supervisory Staff will be hard pressed to defend greivances over pay levels since it is all based on individual perceptions. There will be no verifiable means of defending pay level determinations since pay will be based on individual opinions and perceptions. With pay being determined retro actively (After performance I assume) or proactively with next year's pay being determined on my performance last year, what new rights do employees have as far as terminating/resigning employment when they disagree with the perceived pay for performance dictate from Management? How does a pay level set unilaterally by management constitute a formal labor agreement? When there is no agreement for pay on the part of the employee, how does the Government believe that a formal employee/managment labor agreement exist? In my opinion, when this happens there is no binding contract between the employee and management. Effectively, no employment rules and regulations apply since there is not a mutual labor agreement between the parties. If a person performs at a low level and this is used to set their pay for the next year, how are they motivated to improve? Is the motivation that maybe if perceptions change, they can earn more money next year? Or if they increase their output, then they have a chance to earn more money at some point if the future with no guarantees? Since my pay will be set on a perception of my charactor and integrity, how do minorities get equal pay since minorities suffer the most from poor perceptions based on racial steriotypes? Supervisors suffering from racial steriotypes will subconciously set pay lower for minorities without even being aware of their actions. How does Pay for Performance reconcile lower pay for minorities who suffer from perception problems based on their skin color or nationality? I read at first the funding will match current salaries but after that they will try and keep the employment funds at current levels. By reducing employment funds, this will create the need to RIF people. The new rules change the RIF regulations to allow more flexibility. Therefore, funding stream problems will create RIF's and managers will be free to pick and choose how to create a competitive levels and how to work the new system to keep favored employees. With RIF actions arising out of funding problems, why should employees accept this new system? Isn't the new system a way of controlling lower level agencies personnel levels by dictating the amount of pay for performance funding? Isn't the new system just a way to circumvent the current RIF procedures by merely creating a pay for performance funding shortfall? This allows management to do an end run around congressional oversight regarding job losses in certain congressional districts?