| Comment Number: | OL-10512270 |
| Received: | 3/17/2005 3:47:33 AM |
| 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:
1. Page 7560, Performance Payout - States in part...."increases to basic pay my not cause the basic pay of an employee to exceed the maximum of his or her pay band." This appears to create the same dilemma that exists in the GS schedule when an employee reaches the 10th step - it is not unusual to have several very experienced and talented individuals that reach this "ceiling" in regards to "step increases". In these days of flattening organizations, this is becoming more the norm than the exception, with fewer higher graded positions to aspire to. I see no difference in the current pay band structure proposed, especially with statements like those above. Talented individuals will reach the top of their pay band, have no place to advance to, and will leave DOD!!! There is not enough information in this document to understand what flexibility will be allowed in terms of the ability to move employees from one pay band to another. Will this be provided in follow on "Implementing Issuances"?? If so, will we be given an opportunity to comment on them?? If not, why not?? 2. Page 7559, National Security Compensation Comparability. I am involved with recruiting activities for engineers and scientists. On the surface, there is a lot of "talk" in this document about recruiting the brightest and the best, and retaining the brightest and the best, yet, the document also discusses the reality of "availability of funds" and "pay pools". When I recruit, I don't recruit on a bell curve - I recruit the best and brightest. The proposed system as I read it has the same constraints as the existing system in terms of the funds that will be available for paying employees and rewarding excellent performance - just "packaged" in a different manner. This proposed system does absolutely nothing in terms of "retaining" the best and brightest, and in fact, will require me to "penalize" excellent workers in order to "reward" other excellent workers resulting in a net loss of talent to DOD. Please explain to me, if I have all high performing personnel (which is the goal of NSPS), how I am supposed to be able to reward them all, and retain them all, based on "fixed" pay pools? Please explain. This new system insinuates that all DOD organizations exist in some sort of bell curve with some high perfomers, lots of steady performers and some poor performers. The proposed system does provide for methods to reduce the number of poor performers, but it does not appear to address the preferred "end state" organization that has lots of high performers and some steady performers. The bottom line, if there isn't enough funding to reward excellent performers based on budget constraints, you will not be able to retain the best and brightest. How is this dilemma dealt with in NSPS?? 3. Page 7561, Performance Management, Subpart D discusses "behavioral expectations" yet there is no definition of what this means. Provide a detailed explanation of what this term means, how this element is supposed to be described in terms of performance and how it is to be measured.