| Comment Number: | OL-10510785 |
| Received: | 3/16/2005 11:59:07 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:
The proposed regulations to establish the National Security Personnel System (NSPS) are lacking in important details, which make it difficult to provide meaningful comments. A major concern for me is: how will it affect my retirement pay? I am a CSRS employee with 30 years of service, but I still need at least 8 years of additional service to be retirement eligible (age 55). I am concerned that these changes will adversely affect my future retirement income. I have read that a similar system was adopted by the FAA, and that there are serious concerns about a reduction in retirement income because a larger portion of the employee compensation will be in performance pay (while the retirement will be calculated on the employee’s “base pay”). I have not seen any details that address my concerns. Apparently, compensation will be a combination of a base pay, local market supplements, and performance pay. How will my retirement pay be calculated and on what portion of the total compensation will it be based? I have discussed the proposal with other employees, and many have expressed concern about the “pay banding” and how the current grade structure will translate over to the new pay bands. Why have no details been provided? Is this portion of the proposal still being discussed? Although the Proposed Rules state, “A comprehensive outreach and communications strategy is essential for designing and implementing a new HR system”, I have not seen an evidence of it at my level. There has been no attempt at my base to educate the average employee on the proposed system. I believe this is due to the lack of detailed information on NSPS at all levels. If “DoD and OPM are crafting NSPS through a collaborative process involving management, employees, and employee representatives”, why haven’t we received more detailed information on the proposed rules? You are requesting comment on the proposed rules, but in the 15 months since the National Defense Authorization Act, what briefings or training have we received? None. Although I agree that Civil Service reform should be pursued, it should not be rushed, nor should it be cloaked in secrecy. I received an email stating the Proposed Rules were available for review on February 14, 2005 and that comments would be accepted through March 16, 2005. In the absence of other information (other than that of a general nature), it appears that this “opportunity to comment” is more show than substance.