| Comment Number: | OL-10509816 |
| Received: | 3/15/2005 6:37:24 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:
Potential for abuse of pay pool funds – No limits exist on the amount of pay increases, bonuses, and other awards that management can award themselves or others, leaving little or nothing for the remaining employees in the pay pools. Nothing in these regulations limits the amount of pay increases and bonuses that management can award themselves or others each year, other than the maximum salary rates of their respective pay bands, and the amount of money in the pay pools. Since pay pool funding is limited, once the funding is gone, no other payouts can be made. If managers and top performers are awarded large pay increases, bonuses, Extraordinary Pay Increases (defined in section 9901.344 and on 7560), Organizational Achievement Recognition (described on page 7560), and other payouts from pay pool funds, the pay pools could be depleted, leaving nothing for the remaining employees. Section 9901.342(c) “Performance Shares” states: “DoD will issue implementing issuances regarding the assignment of a number or range of shares for each rating of record level, subject to paragraph (c)(2) of this section.” Since no details exist regarding the range or value of shares, the possibility exists that managers or other “top performers” could be awarded many shares worth a significant portion of the pay pool funding. For example, in a pay pool of 20 employees, with $20,000 of available pay pool money, management could decide that the top 4 performers deserve $5,000 each, leaving nothing for the 16 other employees in the pay pool. This is clearly unfair, and would result in 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.