Comment Number: OL-10507566
Received: 3/14/2005 12:33:37 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:

From your Website's "Myths and Facts" section: MYTH NSPS is just a way to freeze the pay of DoD civilians, since we’re no longer entitled to the automatic January pay increase or within-grade increases. FACT The annual January pay increase, as we know it now, will change. The proposed pay rules provide for periodic “rate range” adjustments, to adjust the minimum and/or maximum rate of a pay band. When a minimum rate of a pay band is adjusted upward, employees will receive an equivalent increase. There are no “steps,” similar to the GS system, in a pay banding system. Instead, pay increases and/or performance bonuses are based primarily on your performance rating. Unacceptable performers are not eligible for pay increases under the proposed system. Please define "periodic" for us. Unless this "periodic" adjustment occurs annually, then it is in fact, a pay freeze for every civilian employee who meets the performance standards! Even assuming DoD uses all the characteristics found on pg 7560 (mission requirements, labor market conditions, availability of funds etc), if it is determined that your pay band doesn't get a rate change this year, it is in effect a pay freeze. Between the undefined periodic and the availability of funds clause, I have no doubt whatsoever, the vast majority of civilian employees will lose money over a 2 year, 5 year, 10 year stretch, irrespective of their performance. Finally, the statement "pay increases and/or performance bonuses are based primarily on your performance rating" is not factual. In fact, the number of people in your pay pool, the amount of funds available to your pay pool, and the ratings of the OTHER people in your pay pool have more to do with your payout (assuming you're meeting the standards), than your performance! If a pay pool has 10 people in it, and $50K available, you can do quite well. If the same pool has 50 people in it, it's simply a token increase/bonus, irrespective of performance. The more people in the same pay pool who score high ratings, the less each share will be worth. These have nothing to do with individual performance.