| Comment Number: | OL-10506767 |
| Received: | 3/12/2005 10:34:16 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:
My comments relate to the Performance Pay Pools discussed in Subpart In Subpart C. It states "The amount of money available within a pay pool is normally based on the money that would have been available for within-grade increases, quality step increases, promotions between grades that have been banded in the NSPS pay system, and applicable across-the-board pay increases." On its face, it sounds like it would work but the reality is that in any given organization, you currently have a mix of experience that has most employees in the mid-to-high steps in the current system. That means that many only receive step increases every two or three years. Top step people receive no increases (except COLAs) so they are not even facted into the current pay funding. Only a handful are in the 1-3 steps that receive increases each year. On average, an organization might only have 40-60% of its employees getting step increases in a given year right now. Under NSPS, everyone but the equivalent to top step of people today (if they are at the top of their pay band) will now eligible for a full raise EVERY YEAR if they perform well. The old "formulas" used for performance awards could prove inadequate as well, if the framers of NSPS believe this will lead to a more productive workforce. If you use the old pay funding, it may very well prove to be inadquate. If this is truly a performance based system, the pay pool must have adequate funds to reward EVERY top performer--no formulas, bell curves, etc. or it will be just like the old "Merit Pay" system many of us endured in the 1980s and early 1990s. If the pay pool is too low, you now have asystem where DOLLARS drive appraisals, rather than performance. It happened in the Merit Pay sysrem--often. We called it "De-Merit Pay" because your appraisal would be lowered to match the amount of money they could distribute in a given year. Typically, they would rotate the appraislals around--one would get the top appaisal/merit pay share one year and then rotate it around to the next person the following year, etc. This system CANNOT be funded like that. It makes a mockery of pay for performance if it does. More importantly, if the up and down, dollar-driven appraisal system is allowed to exist, it also has tremendous RIF implications since the most recent appraisal could cost someone their job just because it may not have been "their year" for the top appraisal. The NSPS implementation group must ensure the pay pools cannot be underfunded. I've worked in a system that was underfunded. If allowed to occur on a large scale, it will destroy faith in the sytem before it ever gets off the ground.