| Comment Number: | OL-10507079 |
| Received: | 3/14/2005 8:31:49 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:
In a recent publication ciruclated about NSPS, the following paragraph appeared: "MYTH There will be no locality pay under NSPS. FACT The proposed NSPS pay system includes a locality-based component of pay called a local market supplement that is paid in addition to an employees basic pay. The local market supplement will be based on market conditions related to geographical and occupational factors, and may differ from one occupation to another in a given locality area. Employees will be entitled to increases to the local market supplement, unless they are performing at an unacceptable level." My concern is about the last sentence. I understand the rationale to base pay increases (formerly achieved by time-based step increases and step increases given for an appraisal) on performance. I agree with the performance-based pay increases or non-increases. However, it doesn't seem to me that locality and performance should be linked. I believe locality supplements should be the same for everyone (in a certain job series) in that locality, without regard to performance. Performance increases will be achieved through other means. By giving increases in the local market supplement to only those achieving at a certain level, you are mixing two issues that have nothing to do with one another - reward for performance and cost of living. I recommend keeping these two issues separate as DoD tries to move forward with a more fair and flexible pay system.