| Comment Number: | OL-10510342 |
| Received: | 3/16/2005 9:03:55 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:
Pay and Pay Administration - Subpart C - Performance Payout My concern is that under NSPS, persons situated at the top of their payband will take a huge hit to their retirement, especially if they are top performers. Under the current GS system, an employee's annual raise typically is composed of a COLA, locality adjustment and performance bonus. The COLA and locality pay become part of the employee's salary and forms the basis of their CSRS or FERS annuity. The performance bonus is paid as a lump payment and not used for retirement calculations. However, under this Section of the proposed NSPS, someone at the top of their band will receive their "share" of performance payout as a lump bonus that will not become part of their base salary. Since it is not part of their base salary, it will not be used to calculate their annuity for retirement. This is especially egregious for top performers in the CSRS whose retirement is based on years of service and average high-three salary. Further, there is no mention of a mechanism to periodically adjust each payband to account for various economic factors such as inflation. Under the current system, each annual COLA effectively adjusts the pay scale and each annual locality pay fine tunes it for a specific geographic area. It is conceivable that these new pay bands could go for years without adjustment using the excuse of higher budget priorities. Overall, without specific details, the overall impression after reading this is that NSPS has more stick than carrot.