| Comment Number: | OL-10506460 |
| Received: | 3/11/2005 3:48:09 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:
Pay and Pay Administration - Subpart C Page 7559. The text reads "For fiscal years 2004 through 2008, the aggregate amount allocated for compensation of DoD civilian employees under NSPS will not be less than if they had not been converted." The years following 2008 are given non-substantive language that gives federal employees no clear guidance as to when and how pay bands will be adjusted. One portion of the indicators for future adjustments reads "...for each band in each career group based on factors such as labor market rates, recruitment and retention information, mission requirements, operational needs, and OVERALL BUDGETARY CONSTRAINTS". The fact is that by replacing step increases (that adjust in amount with cost of living) with a pool of performance money controled by Overall Budgetary Constraints, allows the federal government to freeze the entire payroll from one year to the next. That gives nothing to the top performers of that year!! The pay pool for performance pay increases needs to be tied to a combination of the total number of employees and the periodic rate increase (ie: cost of living).