| Comment Number: | OL-10506070 |
| Received: | 3/11/2005 11:02:19 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:
The regulation does not provide sufficient information on how the rating system will be managed. What process will be used to prevent the supervisor of one work unit to use 'rating inflation' to allow average performers in his group to receive higher payouts than highly successful performers in another group that does not have rating inflation? The proposed regulation also does not provide sufficient information on how the ongoing pay-for-performance programs within DoD will be rolled into the new system. If the new paybands do not align with the existing paybands, the situation could exist where high-performers at the top of their current payband could find their pay capped as a result of the new system. (for example, a high-performance GS12 could be receiving the equivalent of mid-GS13 pay if their current payband covers the GS11-13 salary bands. If converted to a GS10-GS12 banded system, their pay would be immediately capped with only bonuses available for future performance. This could encourage eligible employees to retire earlier than originally planned because the conversion to the new system would put them at their "high three" in terms of retirement calculations.