| Comment Number: | OL-10508974 |
| Received: | 3/15/2005 11:46:33 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:
Sections 9901.231, 9901.332, 9901.372, and 9901.373 all mention that employees will convert to the NSPS system without a reduction in pay (including applicable locality pay). This system will have a negative affect on those employees that are OCONUS at the time this system is implemented. OCONUS employees do not receive locality pay. So when the conversion occurs the OCONUS employees will start out in the lower part of the new pay bands. There is no apparent procedure to make a correction when these employees subsequently return to CONUS. So they will be at a disadvantage in the pay bands throughout the remainder of their careers. The pay conversion to the NSPS needs to include a quasi locality pay factor for OCONUS employees. My recommendation is to use the locality pay rate for the Washington, D.C. area as the factor for OCONUS employees. Currently the calculations for overseas post allowance is based on a comparison of overseas costs to costs in the Washington, D.C. area, so this is a fair factor to use for OCONUS.