| Comment Number: | OL-10510998 |
| Received: | 3/16/2005 1:27:32 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:
Various Sections. The guiding principles say that NSPS is to be cost effective and a key operational characteristic is that NSPS must be fiscally sound. Meanwhile, setting and adjusting locality supplements calls for DoD to consider the availablilty of funds and, similarly, under performance based pay, it says that the performance payout is a function of the amount of money available. Worst of all, the part about adjusting the rate ranges (the replacement for the COLA we now get each year from Congress) says that DoD may within its sole and exclusive discretion adjust the ranges subject to the availability of funds. We are in an environment where tax cuts, budget deficits, and the cost of war are threatening many programs, causing cuts to shipbuilding and aircraft procurements, and even threatening to reduce the fleet of aircraft carriers. How can employees have any reasonable assurance that if they perform at least acceptably that adequate funding will be available for pay raises (locality adjustments, COLAs, and/or performance increases)? Everything in the proposed regulation is tied to the availability of funds and left to DoD's sole and exclusive discretion. While pay for performance makes a lot of sense academically, the reader of these proposed regulations is left with a distinct impression that the effective outcome of NSPS is going to be a long-term reduction of the pay for DoD civilian employees. It would seem to be a given in the current funding environment that increases over time will not keep up with what acceptable performers would have seen under the previous GS system. This alone totally undermines this effort before implementation issues of fairness and transparency even come into play.