Comment Number: OL-10511705
Received: 3/16/2005 4:52:04 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:

NSPS Reform: Pay for Performance sounds good but must be done right to achieve the desired results. It is a major change in how we’ve done it in DoD an will take years to perfect. Seems like the schedule won't allow time for adequate training. Recommend taking small baby steps to ensure we are ready to strap this on. Pay Banding is good and performance based awards would easily fit into this construct. However, recommend an alternative. Continue with some level of periodic increases within the payband (not necessarily same rate as current within grade increases but something similar) and allocate awards using the pay for performance process. This would do two things. 1) Allow time to develop experience with this new way of recognizing performance. 2) Soften the immediate impact and potentially increase acceptance from across the workforce. Also recommend: Allow people within 5 years of retirement a one-time window of opportunity to opt out if they chose. People with 20 plus years may be more resistant to change than others. Give them an option to compete for pay increases under NSPS or continue with WIGIs and only compete for incentive awards. It may be that few would exercise this option but would do wonders for easing anxieties just to know that there is a fallback. And finally, my last recommendation. Adopt pay banding, continue with traditional within grade increases, simplify the process for denying increases, compete for performance-based increases. Thank you for the opportunity to comment.