| Comment Number: | OL-10505600 |
| Received: | 3/10/2005 6:50:44 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:
My comments regard the proposed pay banding. One of tyhe possibilities I keep hearing about is a proposed three bands which will pigeon hole the current GS employees as follows: Pay Band I: current GS 5-11 Pay Band II: current GS 12-13 Pay Band III: current GS-14-15 What is wrong with this approach? Why does this approach defeat the whole reason we are moving to the pay banding system? It's simple. Consider if you are GS-13 Step 10 supervisor. You will be placed at the highest end of the GS 12-13 band. Your opportunity for pay increases despite superb performance is none. Now consider if you are a GS 14 (any step) - your potential pay raises based on merit now exceed what they are now as you may earn over time with superb performance potentially at the high end of GS-15 level. Now consider if you are one of the GS-12 employees supervised by the GS-13 Step 10 supervisor above. Opportunities to make as much as your boss are opening up under the new system. Why are we creating a glass ceiling for the GS-13? Especially in occupations where the employees tend to be GS13-14 -- (such as Government attorneys) why are some employees losing all opportunity for advancement in pay and others having better opportunities than ever before? That's what happens when you arbitrarily draw lines to create the pay bands. A better approach would be for all those in the occupation (such as Government attorneys) have the same opportunity for advancement. Make the pay band as broad as possible to include ALL employees who work in a particular occupation. For example - Government attorneys should be in a bracket that includes GS 12-15. Consideration also has to be made to provide for opportunities for advancement for the GS-13 Step 10 Government attorney supervisor. We need to be careful about these pay bands and consider the unintended glass ceilings we are creating with arbitrary placement of GS employees in three major pay bands.