| Comment Number: | OL-10507871 |
| Received: | 3/14/2005 3:38:13 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:
I believe that any proposed system must contain the transparency and objectivity of the General Schedule. Critical decisions on matters such as pay rates for each band, annual adjustments to these bands and locality pay supplements and adjustments must be made in public forums like the U.S. Congress or the Federal Salary Council, where employees and their representatives can witness the process and have the opportunity to influence its outcome. I am concerned that these decisions would now be made behind closed doors by a group of DoD managers (sometimes in coordination with OPM) and their consultants. Not only will employees be unable to participate in or influence the process, there is not even any guarantee that these decisions will be driven primarily by credible data, or that any data used in the decision-making process will be available for public review and accountability, as the data from the Bureau of Labor Statistics is today. A compensation board, like the Federal Salary Council, should be considered to address issues that may not, as the unions recommend, ultimately be subject to collective bargaining.