Comment Number: OL-10512050
Received: 3/16/2005 8:39:38 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 and Administration - Subpart C Since pay and compensation are of major concern to all affected employees being converted over to the new NSPS system, how can you proceed ahead without even having established Pay Bands. In the various demonstration projects we have been able to review, the pay bands and carrer groups were clearly identified and could be evaluated. Your proposed regulations do not have such detail. How can you assume you are addressing all valid concerns when you have not even established "Career Groups" and "Pay Bands"? Once these are established, you should have another 30-60 day public review and comment period before implementation. This is the only fair and reasonable thing to do before inacting a system that affects a persons pay and compensation. Especially people with 20-30 years vested in the Civil Service System. You describe setting and adjusting minimum and maximum levels within a pay band, and establishing a "Local Market Supplement" in lieu of locality pay. Currently, locality pay counts towards your "High-3" for retirement calculation purposes. Does your proposed "Local Market Supplement" count toward your "high-3" retirement in the new proposed N.S.P.S. system? I did not find any sections descussing how retirement or retirement benefits are calculated and earned under this new N.S.P.S. System. Are they the same as they currently are under the CSRS and FERS retirement systems? and Well those currently in the CSRS system receive the same benefits as under the CSRS system (ie: percentage of pay, sick leave counting towards time of service, etc)? Since this is a "Performance Based Personnel System", will your performance award count toward your high-3 retirement pay? It should if you are truly trying to reward high performers!!! What is your basic salary under this new system? Is it the minimum salary within a pay band? Is it the amount of pay you are awarded each year above the minimum but below the maximum? Is it the maximum amount of pay in a band if you are awarded that amount or over each year? or is it the amount you are awarded each year? It seems that if you are at the top of your pay band and are a top performer in that band, all compensation should be credited towards your high-3 for retirement. You need to clarify how retirement pay (ie: high-3) is calculated. By that I mean, what portions of your pay (ie: basic, performance, and local market) make up your high-3. Further, as mentioned above, you need to clarify and define what your basic pay is within the new Career Groups and Pay Banding systems. As stated above, these issues are of great importance to all employees that will be serviced under the new N.S.P.S. system, and should be fully defined and clarified prior to implementing any of the Spirals. To do this, You need to establish these Career Groups and Pay Bands and have a supplemental 30-60 day review and comment prior to sending to Congress for approval/implementation. I know for myself personally, I am sending these concerns to my Congressional and Senatorial Representatives and other members of the Congress and Senate that have positions of influence in the implementation of this new proposed DOD personnel system. Thank you for your consideration and response to my comments.