Comment Number: OL-10509535
Received: 3/15/2005 4:03:47 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:

Pay and Pay Administration Subpart C, Pay Administration, Initial Conversion. The proposed regulation states that on initial conversion the employee will be placed in the appropriate band with no loss of pay. How is sustained high performance figured in? It seems like a person that has had sustained high performance for a number of years should fall into the band at a particular location on the band relative to his/her past performance. Or at least a minimum it should be considered in some manner. As it is it seems like a poor performer at a step 10 would be initially placed ahead of others with sustained high performance.