| Comment Number: | OL-10512215 |
| Received: | 3/16/2005 11:50:14 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:
The NSPS provides: No salary increases for those that have achieved the top grades / steps through past experience, rewards (WIGI), promotions, etc. Why should some current grade levels be grouped into a larger band? This gives the lower grades ample room to provide for increases in salary, but would not give others at the top end. This is similar to the legal dispute within the FAA where union members were not limited to the pay cap and others were limited, although provided bonuses for their high performances. It not fair that some get continuing rewards through salary and ultimately retirement benefits and others are limited by an arbitary pay band line. If this new performance pay / evaluation system is better than why not do away with ALL pay bands or grades? Pay the workers what they are worth. I have worked for the Army (DOD) for the past 28 years. The preponderance of my performance ratings have been top block. However, I am at the top of my grade level. The only salary increases that I have received have been the Cost of Living adjustments that Congress has provide. I say Congress because the Presidents (that includes ALL Democrats and Republicans) have without fail cited dire economic conditions as to why federal workers should not receive a fair COL adjustment. I can only imagine what the President’s DOD agency will proposed, if any adjustment is ever proposed, to increase a pay band with out some external catalyst. A Key Performance Parameter is to be Credible and Trusted: This parameter is currently lacking due to the absence of any details of how the system will be implemented and how the transition will be made. The planning is definitely NOT clear at this point. The other Key Performance Parameter of being Fiscally Sound: reads that aggregate increases will conform and be managed to budget. Is this saying that personnel cost can be traded off for hardware and other “more important” programs? Keeping personnel cost within whatever is budgeted without regard to cost increases that the workforce is seeing? The grouping of current grades and job series is not defined. Will FLSA exempt and non-exempt personnel be in the same band, such that personnel doing similar type of work, mission, developmental career paths, and competencies will be compensated differently due to classification that some are exempt and others are non-exempt? Will team leader positions, which have not been identified as a supervisory position, but still require a progressively higher level of work and responsibility over other like graded or one to two grade lower team members be now banded together? If so, the team leader positions are not offering advancement and growth potential – and definitely NOT rewards for a higher level of work. Most of the team leaders in my organization represent non-supervisory experts with critical skills to lead, motivate, and are key in the organization meeting its goals. Conclusion: As a high performer, if conversion places my current grade / salary within the lower or middle of a pay band the system would provide incentive to continue to perform at a high level, however as I suspect my grade / salary will be at the top of a pay band, this system would offer nothing and actually will be detrimental. I suspect this based on all previous versions of pay banding, which had the GS13 as a top of a band. I will see if DOD/Army can implement this to show they are sincere about paying / rewarding for performance or if this is more lip service and telling me it is time to take my experience and expertise and apply it to an organization that appreciates it.