| Comment Number: | OL-10506822 |
| Received: | 3/13/2005 12:38:29 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:
B. Para 9901.313, Para 9901.321, and Para 9901.355. The sequence of implementation events restricts the opportunity to evaluate the impact of system conversion on the total compensation package. The sequence of implementation events restricts opportunity to provide meaningful comment on impact on total compensation package. Ranges of basic pay for pay bands have not been generally published as of 16 March 2005. This results in a lack of useful information for employees for the purpose of evaluating the impact of the conversion to NSPS prior to the conclusion of the Formal Comment period. To demonstrate; an actuarial assessment of the impact of the conversion on CSRS annuity where an employee’s pay prior to conversion exceeds the amount authorized under NSPS Pay Band placement cannot be made due to the lack of information on the levels at which the “pay capping” would take place. With the current plan to eliminate COLA on base salary beginning in 2007 the net present value of the CSRS annuity of a “pay capped” employee may be radically and unilaterally undermined. This is a “hidden” impact that employees do not have sufficient data to evaluate and react to prior to closing of the comment period of 16 March 2005.