![]() | National Treasury Employees Union Comptroller of the Currency Chapters 298, 299, 300, 301, 302 |
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Compensation – What’s behind the Curtain at the OCC Analysis as of 9-30-2007 |
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Since inception, OCCNTEU has consistently pressed for greater transparency from management when it comes to items affecting compensation. We have made progress, but the results are mixed. For example, while management attempted to clarify how they calculate GeoPay, they have not disclosed the underlying assumptions for the geographic locations. However, we have made progress on the disclosure of merit pay, merit bonuses, special increases, and award distributions on an aggregate basis. Last year via a Freedom of Information request, OCCNTEU was able to obtain information relative to special increases. After compiling that data, we presented the information to OCC management and asked that they disclose supporting data to ensure its accuracy. Subsequently, management did disclose supporting data, but not to the level of unit specificity that OCCNTEU had proposed (i.e., field office, division, large bank). While we had information compiled to that level, management expressed a discomfort disclosing that level of detail. Since we were making progress and as a matter of good faith, OCCNTEU elected to abide by management’s desires, and we did not further disclose. Earlier this year, we requested that management take the next logical step and disclose information on merit pay increases and merit bonuses in a similar format. We provided management with a recommended format that would show by major organizational unit, the number of employees, number of 4 ratings, average 4 ratings, number of 3 ratings and average three ratings, and the average merit increase for the unit as a whole. After meeting with the Human Capital Subcommittee, management was not comfortable with disclosing this data to the degree of detail suggested by the OCCNTEU. However, they did provide greater transparency relative to the average size of 4 and 3 ratings, merit bonuses, and awards. Therefore, we have continued to make progress. OCCNTEU has performed additional analysis on the information that we did have. As we did with the special increase data, we have presented management with a copy of our analysis and requested that they provide the disclosure to ensure factual accuracy. This time management has declined our request. Management indicated a concern that such disclosure “could create unnecessary dissension across organizational units.” It noted that while the agency endeavors to maintain the high standards set for level 4 performance, “it does not force specific percentages or set absolute targets.” Consequently, there “will always be differences among organizational units. The great ‘equalizer’ among organizational units is the same merit pay budget with which managers have to work.” While OCCNTEU also does not advocate percentages or targets, we do have a concern as to whether a “4” in one unit is really a “3” in another unit. Our concern goes beyond just the size of a merit increase as the rating may have implications when it comes to consideration of merit promotions in a competitive situation with all other things being equal. We also disagree with management’s concern over unnecessary dissension across organizational units. OCC employees are professionals who recognize the importance of teamwork. It is somewhat disconcerting to suggest that dissension would occur. Discussion certainly, but dissension…we disagree. Consequently, we have now put together our analysis and have developed a spreadsheet for employees to review. We used simple algebra in our analysis, employing two non-linear equations to produce the results. In providing this analysis to management, we have disclosed a few caveats about the information, but based on the mathematics we feel the numbers provide a reasonable ballpark estimate. Check this analysis out at: Merit and Special Increase Analysis Management has responded that some of our projections are not what they would consider “in the ball park.” They have asked if we publish our data that we should note that fact. Management further believes, based upon the data they provided, employees can certainly generalize from the data without the need for exact numbers. While we are willingly complying with that request, the whole purpose of asking management to validate the analysis was to ensure accuracy. Again, we believe that employees have a right to know this type of information and that greater transparency will lead to greater or lesser employee confidence in the fairness of the agency’s performance management system. We have provided the data…now you provide your assessment. OCCNTEU has begun pressing management for even greater analyses of this information on an EEO basis to ensure that the pay system does not discriminate unintentionally against any protected classes of employees. OCCNTEU is surprised that such analyses have not been routinely performed at the agency. We welcome any questions, comments, or concern to this website. | |