| Comment Number: | OL-10512055 |
| Received: | 3/16/2005 8:42:48 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:
I have the following concerns regarding the proposed NSPS Regulation: 1. “Pay and Pay Administration – Subpart C”. The proposed regulation does not clearly identify how “pay pools” will be established and managed. Suggest developing “pay pool” regulations detailing the minimum requirements and guidelines for the development of “pay pool”. In addition, these “pay pool” regulations should be issued co-currently with the final NSPS regulation. 2. “Pay and Pay Administration – Subpart C”. Since many “pay pools” will be established within each organization, it is not clear under the proposed regulation, how employees in different “pay pools” performing the same job with be affected. In certain situation, organizations with excess or increasing funds may be able to poach employees from organizations losing funding, due to arbitrary – non-performance based – pay differences. For example, several DOD organizations are located with the same commuting area and one of these organizations is gaining substantial new funding for their pay pool due to new missions coming on line. How will the other organization be able to compete for employees if each organization will be developing their own procedures for their “pay pool”?