Comment Number: OL-10506030
Received: 3/11/2005 10:35:12 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:

Sec 9901.212 Pay schedules and pay bands. Defer pay banding, pending resolution of significant outstanding concerns over sufficiency of funding for pay pools. Pay banding will hurt most employees due to lack of assurance of sufficient funds in pay pools, and the inherent inability of employees to plan on a steady income. The biggest concern is insufficiency of funds to be allocated (by process unknown) to the pay pools. At present, DoD pays performance bonuses using the bonus pool concept. I have personally sat on boards for employees to receive bonuses, where there was insufficient funds in the pool to pay the full bonus earned by the employee. There is no assurance in the proposed NSPS that this will not occur win employees base pay pool. I have been personally affected by the same bonus pool limitation. I have my own appraisal where it is annotated "Performance award changed to within agency performance award monies allocation". Going to the same concept for pay and turning over to management disrection allocation of base pay pools with no more assurance than what in is the draft NSPS is wrong. Personally I don't mind getting nicked due to lack of funds in the bonus pool, but it is wrong to have this occur in the base pay pool. Of course the alternative is to only reward performance to the level you can afford. NSPS as written will cause base pay and performance to be budget-driven, which is wrong and will not serve DoD or the Amercian people well. For these reasons, pay banding should not be implemented in many organizations as proposed for Spiral 1. This appears to be a way for management to either siphon off funds for a favorite project at the expense of employee pay, or to justify a RIF due to lack of pay funding. Defer pay banding until Spiral 2.