| Comment Number: | OL-10509813 |
| Received: | 3/15/2005 6:35:52 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:
SUBPART C - Pay and Pay Administration General Comments 1. Potential conflict of interest - Management could compete against non- management employees for pay increases. Nothing in the regulations prohibits 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 (and provide pay increases and bonuses to each year) for the same pay pool funds. This is an obvious conflict of interest. Management could intentionally hold down the ratings and pay increases of employees to ensure that more funds are available for supervisors and managers in the pay pools. Section 9901.342(b) “Performance Pay Pools” states: “DoD will issue implementing issuances for the establishment and management of pay pools for performance payouts.” Since no details exist in this regulation regarding the pay pool structure, the possibility that managers and non-managers could be in the same pay pools is a real concern. This system would result in the distrust of management, decreased morale, and lower productivity, ultimately harming national security. No changes should be made to the current pay system used by DoD 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.