| Comment Number: | OL-10509155 |
| Received: | 3/15/2005 1:24:21 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:
In general I agree with the concept of pay banding, adjusting labor rules, etc. that are embodied in the NSPS. However, sufficient detail is lacking for one to really provide comments on where changes may have gone too far or may not have gone far enough. Use of "implementing issuances" throughout the document is rather troublesome as it gives the appearance of trying slip something by because it will raise too many issues instead of keeping it all out in the open. NSPS is a concept whose time has come and is needed, however, need the details that would exist in the implementing issuances to be included in the Federal register posting for NSPS. If these details are not present and open for discussion, then the system put in place may not be as good as it could be because input from a wider audience was not considered in flushing out the details for the program. Also, once an implementing issuance has been put in place, what is the process for making any changes after that point in time? Sec. 9901.342 need more details regarding the establishment of control points within a band that limit increases in the basic rate of pay. Issue is how would it be done, will this be consistent across all of DOD or would it be unique for each situations at a local level. Sec. 9901.322 & Sec. 9901.332 Will a certain level of funding be required by law for inclusion into the pay structures. For instance, Congress may authorize 3.0% increase in pay, but doesn't fully fund that pay raise. Would DOD be required to provide that level of increase on average to all employess within NSPS? Current wording cites availability of funds, thus leaves room to deny pay increases when the rest of the Federal Government may receive a raise. If this situation were to occur, may run into an issue of people looking to work for other branches of the Government.