Comment Number: OL-10507361
Received: 3/14/2005 10:33:00 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:

The goal of NSPS is laudatory, but the system needs to obtain employee support almost immediately or the overall mission of DoD and the Military Services will be adversely impacted. One area that will lead to employee distrust of NSPS is the discretionary aspect of raising the cap on the pay band -- the issue is not just one of take-home pay but also of the direct impact on retirement benefits. Current news reports on the morale impact of FAA employees being capped out would be magnified throughout DoD. In order to avoid this potential quagmire, the proposed regulations should be modified and commit to, at a minimum, increasing the pay band by a non-discretionary amount. It doesn't matter what economic tool is used, whether it's based on increases in consumer prices or increases in the cost of wages; it doesn't matter if the non-discretionary increase to the pay band maximum is the full amount of the CPI or CPI minus .5%; what matters is that such a non-discretionary tool would help employees have confidence and trust in the new system.