| Comment Number: | OL-10509268 |
| Received: | 3/15/2005 2:06:44 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:
Classification - Subpart B, page 7558 Pay bands need to be structured to allow recognition of high level scientific work. The establishment of a supervisory/managerial pay schedule should not create a system where highly technical employees must move into management in order to move up in the pay band structure. To automatically adjust employees salaries based upon their positions, series, education levels or anything other than performance or contribution is inconsistent with a true performance-based culture. Vagueness of FR makes a proposed change difficult to make, however recommend creating a classification system that provides a dual track for positions that require technical excellence. Pay and Pay Administration - Subpart C - Performance Pay Pools, page 7560 This section states that performance and incentive award funds may be used to fund the paypool but the incentive awards provisions remain in place. Where will the additional funding come from if the paypool is funded with the awards money? In order to maintain appropriate cost controls, recommend leaving the incentive awards money out of the paypool funding. Pay and Pay Administration - Subpart C - Rating Methodology and Performance Pay Out, page 7560 The example provided shows a five level rating methodology with associated share ranges. Identifying a share range payable for specific ratings limits management’s ability to manage the workforce and appropriately compensate individuals. Recommend delegating to management the ability to assign shares. Control points should not limit management's ability to recognize and reward exceptional performance. The example indicates the highest performance rating must be achieved to receive a full increase in base pay. Flexibility must be built in to recognize low paid, high performers who may not receive the highest score but deserve larger increases than the control points may allow. Recommend delegating to management the ability to determine control point criteria. Pay and Pay Administration - Subpart C - Pay Administration - Promotion, page 7561 This section describes promotion pay increases from a lower band to a higher band in the same cluster. This is the only section where cluster is referred to. Recommend providing the meaning of cluster. Labor-Management Relations - Subpart I, 9. Determination of Appropriate Units for labor Organization Representation, page 7570 This section states employees engaged in all types of personnel work are excluded from the unit, to include work of a clerical nature. This needs to be expanded to include employees who advise management on personnel-related issues in their organization. These employees would include management and employee analysts working in the organizational units. Recommend expansion of the bargaining unit exclusion to include employees who provide personnel management advisory service in the organizational units. Labor-Management Relations - Subpart I, 14. Multi-Unit Bargaining, page 7572 This section provides the authority to conduct multi-unit bargaining over particular issues. Since the labor relations portion of this legislation applies to organizations excluded from NSPS, how will the bargaining process impact existing union agreements between excluded organizations and the local union chapter? How will excluded organizations operate with local unions? Recommend clarification of bargaining obligations for excluded organizations.