Comment Number: OL-10508692
Received: 3/15/2005 10:05:26 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:

Section 9901.372 Conversion of employees to NSPS pay system. There are employees overseas in GS positions on temporary promotions whose permanent positions are back in CONUS. Conversion to NSPS will cancel temporary promotions returning employees to permanent grades. But the individuals will not be put in grades with locality pay, but in overseas non-locality pay grades as conversion hits. Thus they may lose significant amounts of pay, even while encumbering jobs that were graded higher overseas, and do not exist at parent locations in CONUS. I think this is one of those unanticipated situations that bear some consideration. True, the parent CONUS commands can immediately re-promote on a temporary basis but despite the optimism inherent in the new hiring flexibilities in the NSPS, I expect numerous delays as the rules are written and the civilian personnel specialist culture tries to change. Thus, employees who have been competitively chosen and influenced by temporary promotions to take assignments overseas will be penalized by pay reductions, since a lateral results in an automatic loss of locality pay which can be significant e.g. 10k and up. I believe consideration should be given to this problem: either as guidence to agencies to look out for this problem, or special case relief in pay setting during mass conversion.