| Comment Number: | OL-10505839 |
| Received: | 3/11/2005 9:02:28 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:
A problem that I have observed with the pay band structure is that, at least in my organization, it makes it much harder to promote someone than with the older GS grading system. For example, going from a GS 13 to GS 14 in the older system was much easier than going from a pay band III to a pay band IV which groups the old GS 14 and GS 15 grades together. This is clearly not in the interest of an employee who might otherwise have been promotable from a GS 13 to a GS 14 under the older system, but now cannot be promoted because of the more stringent requirement for going from one pay band to another. Except for this situation, I do feel that the pay for performance idea is certainly superior to the automatic step increase under the older system. However, the new system definitely requires that all managers be totally impartial and fair in grading employees, and I have to seriouly question how this can be quantified and enforced.