| Comment Number: | OL-10507106 |
| Received: | 3/14/2005 8:51:15 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:
9901.313 – DoD is introducing a new concept it calls 'National security compensation comparability.' DoD says that it will try to ensure that, for fiscal years 2004 through 2008, the overall amount allocated for compensation of NSPS employees will not be less than the amount they would have had if they had not been converted to the NSPS. After that, DoD says it will provide a formula for calculating the overall amount to be allocated for fiscal years beyond FY 2008. The formula is supposed to ensure that employees are not disadvantaged in terms of the overall amount of pay available as a result of conversion to NSPS, while giving DoD flexibility to accommodate changes in the organization that might impact pay levels. In other words, DoD gives itself the right to lower overall payroll amounts to less than other federal agencies. DoD is speaking only of 'overall' amounts of pay – it is making no promise to try to ensure that any individual employee is not disadvantaged because of conversion to NSPS. This is unacceptable.