| Comment Number: | OL-10507288 |
| Received: | 3/14/2005 9:52:11 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:
Subpart B. Many positions in our agency are multi-function with Administrative, Scientific, and Enforcement aspects. Into which band will they go? The beauty of the GS system has been the freedom from the "knife in the back" from a co-worker who wants a bigger slice of the pie. In the system if you did your job, stayed within the law you got a raise. Smaller, yes, but a raise. Bottom line, BIAS cannot be ruled out in the NSPS system. Every action will potentially end up in court. I fear the NSPS will be too subjective, depending on the good will of a supervisor who has budget pressures and human nature to conquer. Another problem will be some of us have jobs that require us to bring bad news. Bad news is never welcome. Under NSPS, bad news will likely lead to fear of no raise. Bad news with fear of no raise turns into sugar coated news. Sugar coated news leads to bad decisions. Bad decisions lead to accidents, injury, and death. Another point. The GS system has always been a way to rank your job. A GS 9 or a GS 5 usually knows where they are in the food chain. With this new system we will lose this. This culture change will be bad for morale. If the Within Grade Increase are trully the sited problem with the GS schedule, then make WGI's subject to performance alone and leave the rest of the system, ie the across the board increases, rank and colas, intact. Under the wide pay-band concept a civilian transferring from one position to another may be forced into a lower pay range. This will depress mobility, not enhance it. It may also become a race to the bottom of the bands as managers save budgets at the expense of pay Subpart A If the DoD wants more flexibility in assigning people, why not hire more soldiers that they can order to whereever they need..