| Comment Number: | OL-10509598 |
| Received: | 3/15/2005 4:32:43 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:
It is very difficult to comment on something as ill-defined as the NSPS system – as presented in the Federal Register, it appears to be just a very notional outline that claims it “will do this” or “will do that”. The entire section regarding pay is very vague with no specific procedures - there is an example of ratings being translated into shares, which in turn determine pay. But no details are given; no formulas; no procedures. At least the Air Force Lab Demo pay system has specific rules which clearly define the rating procedures and for converting ratings into pay. Right now, it appears that under NSPS, the Air Force, Army, Navy - maybe even every two-letter organization - could all come up with their own set of procedures. The GS system served us well during the Cold War, so why not stick with it? On p. 7553 of the Federal Register, the claim is made that in the current GS system “high performers and low performers are paid alike”. This statement is simply not supported. There is no automatic grade increase in GS; supervisors are under no obligation to promote employees to higher grade levels if they are not deserving of the promotion. If supervisors are in fact promoting undeserving people in the GS system, then such practice will certainly continue under NSPS.