| Comment Number: | OL-10510076 |
| Received: | 3/16/2005 2:11:59 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:
I am a career civilian of the Department of Defense and I have serious problems with the "National security Personnel System" as proposed in the February 14 Federal Register. My three specific concerns relate to the proposed new rules on Pay Administration (Part9901 SubpartC). 1. The proposed rules contain the potential for a serious confict of interest. Nothing to the regulations prohibit supervisors and other managers from being placed in the same pay pools as non-management employees. This means that supervisors could compete against for employees they rate (and proviide pay increases and bonuses to each year) for the same pay poolfundss. This is an obvious confict of interest. Supervisors could intestionally hold down the the ratings and pay increasesof employees to ensure that more funds are available for supervisors and managers in the pay pools. 2. The proposed rules contain the 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 (favored by managers) leaving little or nothing for the remaining employees in the pay pools. The proposed rules do not assure that funds will be allocated fairly. If managers and top performers are awarded large pay increases,bonuses. Extraordinary Pay Increases (defined in section 9901.344 and on 7560). Organizational Achievement Recdgnition (described on page 7560) and other payouts from pay pool funds, the pools could be depleted, leaving nothing for the remaining rank-and-file employees like me. 3.The proposed rules allow for the possibility that my pay could be frozen even if my performance is need satisfactory or better. This could happen to a fully successful employee's pay with the use of "control points", which can be implemented in each pay band to freeze salaries at a certain level Section 9901.342(d)(3) states "DoD may provide for the establishment of control points within a band that limit increases in the rate of basic pay. DoD may require that certain criteria be met for increases above a control point."If a control point were set to require an employee to receive the highest rating to be awarded a pay increeases employees who get the 2nd highest rating and lower would receive nothing and their pay would be frozes, possibly for the rest of their career. This is clearly unfair, and would result in distrust of management, decreased morale, and loower productivity, ultimately harming national security. In my view, no changes should be made to the current pay system used by Department of Defense 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. Sincerely;