| Comment Number: | OL-10510024 |
| Received: | 3/16/2005 12:01:14 AM |
| 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:
Section 9901.311 DOD intends to establish “broad, occupational career groups” to replace positions and position descriptions. Accompanying this will be “pay bands” to replace pay grades and steps. The proposed regulations would provide for adjustments to pay bands to reflect local market conditions, which seems to contemplate cost-of-living increases though there is no indication as to how these adjustments will be determined or how often they will occur. Individual employee pay will be directly linked to performance ratings, so that two employees working next to each other on the same tasks could be paid the same wages, or different wages, from year to year. The proposed regulations would allow for other “goodies” like a “performance payout,” an “extraordinary pay increase” or an “organizational achievement recognition.” Conspicuously missing is any guarantee that these “goodies” will be funded each year. Section 9901.355 The proposed regulations indicate that when an employee is reduced in pay due to a reduction in force, the employee may get some sort of pay retention but no details are provided. For a system that pretends to be so sensitive to employee morale, this is a terrible oversight. Without having to follow the grade and pay retention statutes anymore, DOD should assure its employees that if they are reduced to a lower pay band without personal fault (e.g., reassignment to a lower paying position to accommodate a disability), they will not suffer a loss in pay.