| Comment Number: | OL-10505747 |
| Received: | 3/11/2005 7:39:27 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:
Setting and Adjusting Rate Ranges (p 7559-7560) - According to the Notice, rate ranges in lieu of locality pay may differ by "career group, pay schedule, or pay band. This means that persons working in the same locale may receive vastly different adjustments, even thought the cost of living is equal for each person living in the same area. In the event that this occurs, the result would be extreme animosity between those who may receive greater adjustments and those who receive lower adjustments or no adjustment at all. This would create an enormous amount of resentment between and among employees and supervisors and have a negative effect on the work environment. There must be a continuous audit of rate range adjustments to ensure that "pay pools" are distributed justly across the board and establishing a continuous audit would necessitate allocation of funds, thereby reducing the overall amount available for adjustments. This concept appears to be dangerously flawed and should be thrown out entirely, particularly since the ability for workers to challenge the pay system is purposely restricted. Performance Based Pay (p 7560) - Distribution of pay adjustments and bonuses based on individual performance is a wonderful idea to allow the DOD to deal with problems related to poor performers. However, many DOD employees whose work relies heavily on individuals or entities outside of his or her control could be negatively affected by this concept. I work for the Army Corps of Engineers in Regulatory. My ability to finalize permit applications under Section 404 of the Clean Water Act depends entirely on the level, quality, and timeliness of information submitted by an applicant or applicant's agent. Therefore, I lack significant control over my productivity. It is unclear whether there is a sufficient mechanism in the NSPS to deal with such an environment. Overall, there is not enough information to determine how implementation of the NSPS would affect the work environment in the DOD. The DOD should conduct extensive research and trial over an extended period of time (several years) with a sample group or groups in order to fully understand how implementation of this program would affect the DOD workplace. The system gives too much control of pay to supervisor staff and appears to allow for and encourage favoritism and discrimination, thereby bringing back the "good 'ol boy" system that the GS pay system was designed to eliminate, while restricting the ability of employees to challenge the high potential for unfairness. The DOD has touted the need to be more responsive regarding the pay system, particularly related to the need to deal with poor performers. Yet, the Notice does not mention consideration of alternatives to the NSPS, such as maintaining the GS system while removing limitations for hiring, retention, and dealing with poor performers. Generally, the NSPS lacks forethought to a variety of potentially detrimental effects of its implementation. Knee-jerk implementation would have wide-spread and long-lasting negative repercussions. It is apparent that the system is being developed to facilitate an underlying political agenda rather than simply to make it easier to hire and fire government employees and make the DOD more parallel the private sector. More research should be performed to investigate alternatives to achieve the stated goals of the NSPS while maintaining the GS system.