| Comment Number: | OL-10511694 |
| Received: | 3/16/2005 4:49:09 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:
Subpart C Pay and Pay Administration Pages 7559/7581. Does “setting and adjusting rate ranges” replace the general increase that applies across the board? If so, this could mean a pay band could stay the same for years, which would be a de facto pay reduction for people in the pay band. If someone is capped in a frozen pay band, their salary wouldn’t even keep up with the rise in the cost of living. Subpart C Pay and Pay Administration, 9901.342 Pages 7560/7582. The use of “control points” for limiting basic pay increases within a pay band essentially creates more pay bands, doesn’t it? If control points are set based on different types of duties, then it would make more sense to increase the number of pay bands and/or career groups. Since the system allows you to create subgroups, why not decide what the maximum salary should be for that type of job and be done with it? The rating system should be structured to keep someone from rising to the top of the pay band if the performance is not up to the written standard; if performance is to that standard, then he/she should be able to get to the capped point without having to do something extraordinary. For example, if the cap for a clerk is $25,000/year, every clerk should have the opportunity to make it to that point by performing his/her duties to the written standard. If they do “above and beyond” work, then the capped individual could get a bonus or another type of award. Also, what happens with salary negotiations for new hires? Depending on the definition of the control points, if they mean attaining a certain performance appraisal level, a new hire is not qualified to start at anything beyond that, which would, for example, preclude offering a competitive salary to a highly qualified engineer with no prior Government service. Subpart C Pay and Pay Administration, 9901.344 Pages 7560/7583. What is the mechanism to ensure that organizational achievement recognition is applied equally to all members of a team? Individual performance on the team should be rated separately. If a team is rated on its work product, every member should get the same share of the rewards. Subpart C Pay and Pay Administration, Developmental Positions Page 7561. Under “Pay Administration,” the first paragraph, “The new DoD pay system …is designed to adjust individual pay levels based on the acquisition and assessment of competencies, skills, and knowledge and on the basis of performance or contributions to mission,” we need to be aware that the assessment of “competencies, skills, and knowledge” is only interpreted in light of their use to contribute to the mission. That is, we must reward not what employees know, but what they do with it. For example, it would be unwise to award an increase in pay to someone for attaining an advanced degree without seeing if the person’s performance/contribution increases because of it. Subpart C Pay and Pay Administration, 9901.344 Page 7582. The performance payout system using shares is very much like the current GS system. It doesn’t take into account whether someone should receive a huge increase because he/she is being drastically underpaid. The “extraordinary pay increase"criteria don't seem to apply, since (page 7560) a person receiving a high salary could be doing the same thing and should not therefore be eligible for the extraordinary pay increase, too.