Comment Number: OL-10511791
Received: 3/16/2005 5:22:31 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:

9901.313 National Security Compensation Comparability Under this section it states that "compensation of the DOD civilian employees who are included in the NSPS may not be less than the amount that would have been allocated for the compensation of such employees for such fiscal years if they had not been converted to the NSPS, based on at a minimum-- 1. The number and mix of employees.... 2. Adjustments for normal step increase and rates of promotion.... The concern is that while the entire pot of money for merit pay stays the same it could be paid out differently impacting retirement calculations. Currently step increases and rates of promotion would increase basic pay for retirement purposes. Bonuses received for performance would not increase basic pay for retirement purposes. I'm concerned that as a CSRS person looking toward retirement within the next 5 years, the adoption of NSPS may adversely affect the calculation of my retirement. With a longer period before retirement, the new system might level out but for those of us with a shorter lead time, this could mean our retirement earnings are adversely impacted.