Comment Number: OL-10510970
Received: 3/16/2005 1:17:49 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:

Pay administration--- Retain GS pay levels for headquarters organizations, and current employess with over 10 years of continuous civil service performance. As proposed, NSPS penalizes this class of employees. Due to the many ways management can manpulate pay under the NSPS, pay bands have no assurance that basic pay will be consistent from year to year. This is a problem for most employees nearing retirement and calculation of their high-three pay years for retired pay calculation. The employees will lose significant sums over their future years if base pay is allowed to drop from their current level. Ideally these employees with over 10 years would be "grandfathered", or if not that ---given their choice of the Pay band or the existing GS pay schedule, or NSPS implementation should be delayed until this is fairly resolved.