Comment Number: OL-10508966
Received: 3/15/2005 11:43:14 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:

NSPS will allow managers to offer new hires a higher more competitive salary in order to attract the best and brightest employees. This is definitely an advantage if you're a new federal employee. But, there are no additional funds allocated for salaries in this new pay system. All money comes from a pay pool. This means basically that some employees have to lose in order to pay a higher salary to new employees. The losers are supposed to be the poor performing workers. But, who are these poor performing workers? Only an extremely small percentage of federal employees ever see an unacceptable performance rating. This is where the additional funds are supposed to come from in order to pay high performers and the best and brightest new employees. Unfortunately, I see numerous disparate impact complaints from older workers on the horizon. In addition, managers may have a full-time job defending against performance rating challenge claims.