| Comment Number: | OL-10507801 |
| Received: | 3/14/2005 3:16:21 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:
Comments on Federal Registry dated Feb 14, 2005 regarding the National Security Personnel System (NSPS) (Docket # NSPS-2005-001 and RIN 3206-AK76/0790-AH82) 1. The Case for Action p. 7553; Performance-Based Pay-9901.342 Performance payouts.-(a) Overview (1) p. 7582; Subpart D-Performance Management-9901.409 Rating and rewarding performance. (b) and (c) p. 7586; et. al., and Outreach-Outreach to Employees p. 7556: Under NSPS, ratings, pay increases, and bonuses are stated as being based on “results” and “contributions” (among other factors). However, Secretary Gordon England stressed in the town hall meeting on July 7, 2004 that NSPS would reward risk-taking. If the risk-taking produces inadequate results, then it appears NSPS will punish – not reward – the risk-taker. NSPS must guarantee that the evaluating factors of “innovation” and “performance” will not overshadowed by lack of results caused by factors beyond the employee’s control. 2. Classification-Subpart B p. 7558 and Pay and Pay Administration – Subpart C-Adjusting Rate Ranges and Local Market Supplements p. 7560: Basing local market supplements on “broad occupational career groups” punishes those employees whose function is more critical than the rest of the group. Basing the supplements on occupational series or function seems more logical. 3. Pay and Pay Administration –Subpart C- Adjusting Rate Ranges and Local Market Supplements p. 7560 and Local Market Supplements-9901.333 Setting and adjusting local market supplements (b) p. 7582: Current “locality adjustments” occur in January. To stay consistent with other Federal agencies, the local market supplements should occur at the same time. 4. Pay and Pay Administration–Subpart C-Performance-Based Pay, Annual Performance-based Payouts, and Rating Methodology p. 7560; Performance Management–Subpart D-Performance and Behavior Accountability p. 7562; and Subpart D–Performance Management-9901.406 Setting and communicating performance expectations. (b) p. 7585: Since the method of pay pool “shares” may encourage unhealthy rivalry among employees, the performance measures of “teamwork/cooperation” and “respect for others” need to be standard and emphasized. 5. Pay and Pay Administration–Subpart C-Performance Pay Pools p. 7560: It is not clear whether current Special Act, On-the-Spot Award, or end-of-rating cycle performance award funds will maintain separate from the pay pool under NSPS. 6. Performance Management –Subpart D-Performance and Behavior Accountability p. 7562: The term “misconduct” needs to be clarified to whether it includes actions done outside work during non-duty hours (during travel and non-travel status).