| Comment Number: | OL-10508766 |
| Received: | 3/15/2005 10:39:14 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:
General comment: Many areas discuss a general subject only in terms of the initial change from GS or FWS to NSPS. This is only good one time. The Federal Register must also spell the rules of the subject after NSPS is in effect. This is of concern for those of us who are coming from demonstration project bases. 1. Subpart B, Classification Process, P. 7559 Though Table 1 is only a sample, it indicates that managers/supervisors will have separate pay bands from non-managerial/non-supervisory positions. Has this been determined yet? It is not stated as such in para. 9901.212. 2. Subpart B, Classification Process, para. 9901.221 (a), P. 7579 “DoD will develop a methodology for describing and documenting the duties, qualifications, and other requirements of categories of jobs…” We hope that there will still be a review of the classification by personnel specialists so that supervisors cannot whimsically make up classifications. 3. Subpart C, Settings and Adjusting Rate Ranges, P. 7559. Who will do the local market supplements and gather the data? Will it be the local base? Will the local market survey poll the contractors doing tandem work with government employees and value the government employees (fully burdened salaries) equivalent to the fully burdened contractors’ salaries? 4. Subpart C, para 9901.322 (b), P. 7581 “DoD may determine the effective date of newly set or adjusted rate ranges.” This leaves the door open for a continually sliding the start date into the future. It should state that once the initial date is set, it must be maintained. Additionally, it must be evaluated and modified if necessary on at least a yearly schedule. 5. Subpart C, Performance Pay Pools, P. 7560. “In addition, the proposed regulations allow DoD to establish “control points” or other mechanisms within a band, beyond which basic pay increases may be granted only for meeting criteria established by DoD.” First, define control points. Will the control points be set locally? Who reviews the criteria to see that they are realistic? 6. Subpart C, Performance Pay Pools, P. 7560. Section explaining pay pool funding only covers initial settings for converting from GS & FWS system. How are those of us in Acquisition Workforce demonstration projects going to convert over? Explain the pay pool setting rules that will be in effect after that. 7. Subpart C, para. 9901.342 (a), P. 7582. Pay performance distribution will be based on individual performance, individual contribution, organizational performance or a combination of those elements. Does that mean each employee has an individual performance rating and also an organizational rating? Who rates and reviews the organizational review? 8. Subpart C. para. 9901.304, P. 7580. There is a definition for model rating in here but we could not find anywhere where it was talked about. How is a model rating going to be used? 9. Subpart C, Performance Pay Pools, P. 7560. “Subject to DoD guidelines, pay pool managers will have the discretion to determine the proportion of an employee’s total performance payout paid as an increase to basic pay or as a bonus.” Since it is discretionary as to which portion of an employee’s total performance payout will be paid as an increase to basic pay or as a bonus, what happens when an employee is granted a bonus for 2 years in a row? Shouldn’t the employee’s basic pay be commensurately adjusted to the lower of the two bonuses (within the pay band)? After all, if the employee truly deserves the performance payout and has maintained the level of performance for more than 1 year, shouldn’t the employee receive the true pay raise? MORE IN ANOTHER SUBMITTAL - RECEIVED RUNTIME ERROR ON ATTEMPT TO ATTACH FILE