| Comment Number: | OL-10508828 |
| Received: | 3/15/2005 10:57:33 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:
After carefully reading the proposed NSPS plan, I am intrigued by the possible results stemming from Subpart/Section 9901.342 dealing with Performance payouts. Under the proposed plan, employees who are performing at an acceptable level can expect (perhaps) to receive a payout of some sort (pay increase/cash bonus/combination of both) provided they are not at the top of their pay band. Those unfortunate folks that are at the top of their pay band are very unlikely to receive a pay increase (no annual cost of living increase, no locality pay adjustment, and no step increase) for many, many years at a time. As a result, I can foresee a situation where those employees will feel compelled to lower their performance to something close to just acceptable, or slightly higher, and then remain in government service until the age of 65 or 70 in order to earn a decent pension in retirement. Since the computation formula for calculating a pension remains the same, and since one of the variables (salary) will become a constant, the only other variable (time in service) will have to be increased in order to bring up the pension amount. This scenario would appear to create just the opposite affect of what NSPS was intending. Instead of bringing in new, younger employees who are great performers, the system will generate older employees who are just putting in time as mediocre performers. If that is the underlying hope of the new NSPS plan then that's fine, leave thnigs just as proposed; but if not, then I would strongly encourage a change to NSPS to ensure that employees at the top of their respective pay band receive yearly pay increases (not bonuses) commensurate to their demonstrated, yearly performance.