| Comment Number: | OL-10509015 |
| Received: | 3/15/2005 12:02:27 PM |
| 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:
This is a tremendously massive overhaul to the current pay system. To complete this in 3 months is totally inappropriate , unresponsible, and not-thought-out in any detail. To even think of changing a system as wide and diverse as this, requires a year or more to solidify, obtain consensus and ensure all is complete and thorough. A briefing with questions was provided at the Norfolk Naval Base, Bldg C-9, on 2 Mar 05, and people lined up -- out the door, to question this system...if a system was ready, there should only be a question or two...and the answer for many of the questions from Ms Patricia Adams was: "Noted", and hopefully, somebody was taking notes...no minutes were ever provided of the session...answers were not available, and the system needs more details, to even begin to ask solid, meaningful questions. The proposed rules contain the potential for a serious conflict of interest: nothing in the regulations prohibit supervisors and other managers from being placed in the same pay pools as non-management employees. This means that supervisors could compete against the employees they rate for the same pay pool funds. This is a conflict of interest. Supervisors could intentionally hold down ratings and pay increases of employees to ensure more funds are available for supervisors and managers. The potential for abuse of pay pool funds exist. No limits exist on the amount of pay increases, bonuses and other awards that mgmt can award themselves or others (favored by mgrs), leaving nothing left for remaining employees in the pay pools. The proposed rules do not assure the funds will be allocated fairly. If mgrs and top performers are awarded large pay increases, bonuses, etc, the pools could be depleted, leaving nothing for the remaining employees. The proposal allow for the possibility that my pay could be frozen even if my performance is rated satisfactory or better. This could happen to a fully successful employee's pay with the use of "control points", which can be implemented in each pay band to freeze salaries at a certain level. This could result in employees having their pay frozen, possibly for the rest of their career. This is clearly unfair, could result in distrust of mgmt, decreased morale, lower productivity, and harm national security. No changes should be made to the current pay system used by the Department of Defense agencies until complete and detailed proposals are provided, and a full comment and review period is completed, followed by a full collective bargaining process with the unions representing DoD employees.