Comment Number: OL-10510794
Received: 3/16/2005 12:03:06 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:

Federal Register/Vol 70, No.29/Monday, February 14, 2005/Proposed Rules under heading Pay and Pay Administration-Subpart C, Performance- Based Pay, page 7560, paragraph entitled Performance Pay Pools you discuss the amount of money available within a pay pool is normally based on the money that would have available for within-grade increases, quality step increases, promotions between grades that have been banded in the NSPS pay system, and applicable across-the-board pay increases. As the Financial Manager at a Navy activity, I can attest to the fact that we are not funded for within-grade increases, quality step increases, promotions or fully funded for across-the-board pay increases, i.e., cost of living and locality pay. So, I question the source of the funding under the new system and whether it can actually work as proposed. Also, I disagree that cost-of-living increases should be part of the pay pool calculation since there is no connection between performance and overall inflation. I propose that activities be fully funded for within-grade increases, quality step increases, promotions between grades and applicable across-the-board pay increases. Also, I propose that cost-of-living increases based on inflation not be included as part of the pay pool. Federal Register/Vol 70, No.29/Monday, February 14, 2005/Proposed Rules under heading Performance Management-Subpart D, page 7561, first paragraph, you discuss that the current system is burdensome with respect to allowing for changes to performance standards mid-course. Under the current system, standards can be changed at any point, however, you must allow at least 90 days under those standards to assess a performance rating. Consequently, I don’t find the argument that the current system is too rigid with regard to the flexibility of changing performance standards to be true.