| Comment Number: | OL-10507597 |
| Received: | 3/14/2005 12:57:50 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 "Facts and Myths" section: MYTH Under NSPS, funds for salaries and bonuses will no longer be certain. FACT DoD is committed to ensuring civilian compensation is protected. In fact, the law requires that the aggregate amount allocated for civilian compensation for organizations under NSPS cannot be less than the amount that would have been allocated under the existing system. Under NSPS, the overall amount of money that would have been used for the annual January pay adjustment, within grade increases, quality step increases, and similar payments, will be used for civilian pay, and those funds will be protected. However, the proposed NSPS pay system will distribute those funds based primarily on performance. If this is the case, then why is the phrase "The formula will ensure that, to the maximum extent practicable, in the aggregate, employees are not disadvantaged in the overall amount of pay available as a result of conversion to NSPS..." on pg 7559? If DoD is committed to protecting civilian compensation, why is the phrase "to the maximum extent practicable" required? Especially since you're saying, "the law requires that the aggregate amount allocated for civilian compensation for organizations under NSPS cannot be less than the amount that would have been allocated under the existing system". Why does pg 7560's discussion of rate range changes use the phrase "availability of funds"? Is the money protected or not? You can't have it both ways! Either the funds are protected, or its a question of availability...it cannot be both! The funds are either protected by law or it's to the maximum extent practicable...again it cannot be both. Which one is it?