Comment Number: OL-10506523
Received: 3/11/2005 5:41:54 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:

General - The absence of specific implementing instructions impedes the ability to comment coherently. Sect. 9901.212 - Until the grades included in each pay band are specified, comments can only be limited to generalities. Pay banding may be positive in theory, but specific formulations may have differing pros/cons. Sect. 9901.322 - When implementing the Lab and Acquisition Demonstration Projects, employees were guaranteed to receive no less than the salary amount they would have received under the former system for the initial year. Such a guarantee would help in this change. Further, both of the aforementioned demonstration projects were not entirely revenue neutral--each cost a small percentage more than the former system. Each was viewed as a positive example and successful for improving the quality of employee/organizational achievement thereby justifying the small increase in salary costs. Sect. 9901.353 - Disagree strongly with setting promotee's pay anywhere within the band when being promoted to the next higher band. Promotees' pay increases should be set at 10% or another similar constant. The proposed flexibility will give credence to accusations of favoritism. Sect. 9901.409(g) - Change to state that changes in appealed ratings will result in commensurate changes to payouts.