| Comment Number: | OL-10509850 |
| Received: | 3/15/2005 7:26:09 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:
This is a very broad comment, but it would technically address Classification - Subpart B. By removing 15 grades and replacing them with 4 (+ or -) pay bands, NSPS may very well be destroying the incentive that its advocates purports that it creates. Pay Banding can be accomplished without collapsing the existing pay structure from 15 grades to 4 bands. Reducing the number of grades removes a significant incentive tool from management. One should not discount the significance that promotions have for employees. It means a great deal to be promoted from a GS-14 to a GS-15, from a GS-11 to a GS-12, or even from a GS-06 to a GS-07. Often, these promotions actually cost very little in monetary terms due to the employees step rate at the time of the promotion. Nevertheless, this promotion serves to validate employees efforts in a way that extra money within a pay band cannot. In private sector terms, it is akin to bestowing a title (e.g. vice-president) to someone. There may be very little immediate reward for an employee in terms of money, but the recognition has significant psychological impact that cannot be duplicated by merely increasing an employee's pay packet based on an annual appraisal. I urge the DoD to take its time and look at the experience of other non-DoD agencies that have introduced pay banding. At the Federal Deposit Insurance Corporation (FDIC), pay banding was introduced in the late 1990's. Although the FDIC implemented pay banding, it did so without consolidating grades. Thus, an employee is in the grade 12 pay band or the grade 13 pay band, not a pay band that combines the two grades. The FDIC system still preserves the carrot that sustained hard work and superior contribution may allow an employee to one to one day earn a promotion in the future, as well as the stick in that truly poor performance need not be rewarded with any pay increase whatsoever. A system wherein superior contribution merely allows one to modestly increase their pay from year to year is not as powerful an incentive as the prospect, even the remote prospect, that one day their work may be rewarded, or more specifically, recognized, in the form of a promotion. Again, pay banding can be introduced without collapsing the existing grade structure. Please do not remove the power of the promotion incentive from managers and employees, alike. Constructively submitted,