Dear Comrade,
Published hereunder is the reply to the questionnaire submitted by the Staff Side, JCM National Council, New Delhi to the 7th CPC.  Most of the organisations of the Central Government employees have adopted this reply and endorsed the same.  We have decided to do the same.  However, the NCCPA, to which we are affiliated have decided to elaborate the reply to question No. 10 pertaining to Pensioners issues.  We have endorsed their reply and submitted the same to the Commission.  You may read the full text hereunder.
With greetings,
Yours fraternally,
KKN Kutty.

INCOMETAX PENSIONERS FEDERATION

Manishinath  Bhawan,

A/2/95 Rajouri Garden

New Delhi. 110 027.

Phone: 25105324

Mobile: KKN. Kutty. 98110 48303

E mail: itpfchq@gmail.com

Website: itpfchq.blogspot.com

ITPF/01/2014

Dated: 10^th May, 2014.

Ms. Meena  Agarwal

Secretary,

7^th Central Pay Commission.

Post Box No. 4599

Hauz Khas

New Delhi.

Madam,

               Kindly refer to the questionnaire issued by the Commission eliciting response from various organisations of the serving employees and retired personnel.   We are in full agreement with the formulations made by the Staff Side JCM in their reply to the questionnaire.  We endorse the same and a copy thereof is sent.

               In respect of the matters concerning the retired personnel, we submit the reply to question No. 10 separately.

               Thanking  you,

Yours faithfully,

K.K.N. Kutty

For and on behalf of the Incometax Pensioners Federation.

REPLY TO ITEM NO. 10 OF VII-CPC QUESTIONNAIRE

VII-CPC vide her DO letter No. VII-CPC/15/questionnaire dated 9^th April, 2013 has sought considered views of all stake holders on the questionnaire of the VII-CPC.

tem 10 of the said questionnaire relates to Pension.  We submit the following in reply to questions raised by the Commission in item No. 10.

10-PENSION

Question No. 10.1: The retirement benefits of all Central Government Employees appointed on or after 1.1.2004 are covered by the New Pension Scheme (NPC).  What has been the experience of the NPS in the last decade?

Reply: The NPS envisaged one or more Central Record Keeping Agency (CRA) to maintain records, accounts and effect all instructions regarding subscription, switching of options and withdrawal by the subscriber.  It is also possible that subscribers may access CRA for any information.

It was therefore expected that the CRA would be set up right from the inception of the NPS scheme i.e. from 1.1.2004 and maintain records and accounts of all subscribers.  This was not done.  The CRA has been set up after a considerably delay of more than 3 years.  This has resulted in late opening of Subscribers account causing loss of interest on contributions.  The interest has been credited in the accounts from the date of opening of these accounts by the CRA.  It has also been learnt that Central/State Governments also took time in transferring these accounts to the CRA.  Some state Governments have transferred only the contributions recovered from the subscribers and not the matching contribution from the Government.  Due to these reasons there will be loss of interest to the subscribers during the period for which the accounts were not opened.

As per the an article in Economics Times dated 29.4.2014 more than 28lakhs Central & State Government Employees who joined service on or after Ist January 2004 have compulsorily invested in the NPS.  Their retirement savings account for 93% of total NPS corpus roughly 45000 crores.  This huge saving has not been invested right from the 2004-2009 as because the promoters have been appointed only in the year 2009-10 leading to this corpus lying idle. 

As per this article the following has been performance of these NPS funds which was obviously the worst ever performance by such funds.

Year                                     Central Govt. Workers                                  State Govt. Workers

2010-11                                             6.91%                                                                7.91%

2011-12                                             7.28%                                                                8.04%

2012-13                                             11.24%                                                              11.82%

2013-14                                             5.37%                                                                4.95%

Since launch                                      7.55%                                                                7.87%

It has also been learnt that some subscribers have already retired or died and they have been granted statutory benefit under CCS(Pension)Rules 1965 because of the fact that wealth accrued in their account is quite insufficient.

The NPS has created a class within the class among Central/State Government employees which is discriminatory and therefore, impermissible.  It is violative of the dictum pronounced by the Supreme Court in their landmark decision in Nakra vs. Union of India, as such this NPS deserves to be rescinded.

In the considered opinion of the Pensioners fraternity the NPS must be scapped and all those who are now covered by NPS should be brought back to be covered by statutory pension scheme.

VI_-CPC had asked the Centre for Economic Studies and Policies, Institute for Social & Ecnomic Change, Bangalore to conduct a study and to suggest various options by which the pension liability can be contained in future and device suitable and self-sustaining models for financing the pension of the Central Govt. Employees, the final objective being that the funds are so devised as are able to meet substantially the entire pension liability of the Government.  In other words Government wanted complete privatisation of pension by covering all Central Government employees including Defence personnel under suitable schemes on the pattern of NPS.  The concluding recommendation of the above study is as under:

“Mainly given the fact that the future liability for pension although may be large in terms of absolute size is not likely to last very long and does not constitute an alarmingly big share of GDP which is also on decline.  It appears that pursuing the existing  PAY AS YOU GO to meet the liability would be an ideal  solution”.

The PAY AS YOU GO system i.e. statutory pension is therefore also an ideal solution for those who have now been covered under NPS.

The Supreme Court has held that the right of a civil servant to receive pension is a property within the meaning of article 31(1) and articles 19(1)(g) of the Constitution of India.  Therefore, any order/scheme which denies the civil servant the right to receive the pension affects his fundamental rights.  In the light of the  above ruling the NPS is ultra-virus and has to be scrapped.

Question No. 10.2:  As far as pre 1.1.2004 appointee are concerned, what should be the structure of pension and other retirement benefits?

a)      The Scheme of one rank one pension in respect of defence personnel i.e. persons retired from same rank, same seniority and equal length of service should get equal pension irrespective of date of their retirement, having been ensured in respect of Defence Personnel (Army, Navy, Air force) , the principle of full parity in pension of civilians which had been enunciated by the V-CPC and implemented upto 4^th CPC has to be ensured by the VII-CPC.

b)      In order that pension is adequate, the minimum pension should 65% of minimum pay and not 50% thereof.

c)      Supreme Court had ruled that pension should be adequate to enable pensioners to live: free from want, with decency, independence and self-respect; and at a standard equivalent at the pre-retirement level.  Therefore, the pension should be 65% of basis pay + DA last drawn.

d)      Dearness Relief @ 100 neutralisation of increase in cost of living with its automatic merger whenever it cross 50% mark.

e)      Additional Pension.  Recognising that with advancing age anyone is gradually crippled and becomes more susceptible to decease etc.  Therefore, after superannuation on attaining the age of 60 years the pension should be enhanced after each five years as under:

65 years               @ 10% of the basic pension

70 7ears               @ 20% -do-

75 years               @ 30% -do-

80 years               @ 50% -do-

85 Years               @ 70 % -do

90 years               @ 100% -do

f)       Pension should be net of Income Tax.

g)      Restoration of commuted value of pension should be after 12 years and not  after 15 years applicable to commutation as per old Tables existing upto 2008.

h)      Full pension after 20 years of service has to be extended also to the Pensioners who retired before 1.1.2006.

i)       Grievance procedure should be on the lines as under:

a)      Resolution of Pensioners Grievances should be ensured within a specified time frame.

b)      SCOVA be upgraded to JCM level

c)      Benefits of judicial decisions should be extended to all similarly  circumstanced pensioners

J)   Medical Facilities:

The following land mark judgements of the Supreme Court have held that the enjoyment of highest attainable standard of health is recognised as a fundamental rightsof all workers/pensioners in terms of aAticles 21 read with Articles 39,41,43 and 48 of the constitution.

a)      Consumer education and Reserch Centre and others vs. Union of India (AIR 1995 Supreme Court 922)

b)      Laxman Thammappa Kotgiri Vs. General Manager, Central Railway & Ors (2005 (1) SCALE.

c)      Indian Medical Council vs. VP Shantha & ors. 1995 (6) SCC651.

A.     Therefore, smart card may be issued to all pensioners of all Departments and their dependents to avail cash less, hussle free health care both indoor as well as outdoor across the country in-

a)      All Govt. Hospitals and Dispensaries,

b)       All NABH accredited multi super speciality Hospitals which has been allotted land on concessional rates  or given any otheraid/ concession by Govt.

c)      And All CGHS, RELHS and ECHS empanelled Hospitals.

A.     All Pensioners irrespective of pre-retrial class or status be treated equally in all matters like ward entitlements etc.

B.     Fixed Medical allowance should 2500 p.m. plus dearness relief thereon.

C.     Hospital Regulatory Authority may be set up to bring all NABH hospitals or diagonistic centres under its constant monitoring of quality, rates etc. CGHS rates may also be revisd as per market trend.

D.     Extension of CSMA Rules 1944 to pensioners residing outside CGHS area.

E.      Extension of minimum pension to EPS 95 pensioners, SRPF/CPF pensioners.

F.      Revise pension from 1.1.2014 and thereafter every 5 years.

G.     Gratuity should be based on total length of service @ one month emoluments for every completed service year/part thereof.

H.     Family pension should be at the rate of 50% of the pay + DA last drawn.

7th CPC Questionnaire

1. Salaries

1.1 The considerations on which the minimum salary in case of the lowest Group ‘C’ functionary and the maximum salary in case of a Secretary level officer may be determined and what should be the reasonable ratio between the two.

           

Any Commission which considers the question of emoluments for employees/workers should first be inspired by the implication flowing from the amendment to the preamble of our Constitution where-by the words “socialist & secular” were prefixed to the word “Republic”, as also the Directive Principles of State Policy enshrined in Article 43 i.e. the state should endeavour to secure living wage for its employees/workers.

Group C is a skilled worker.  MTS is the lowest category of Group C. The 6^th CPC evolved the MTS by amalgamating some of the unskilled, semi-skilled and skilled functions without any scientific basis or logic.  From the standpoint of the stipulation in the recruitment rules, eligibility criteria etc, MTS deserves to be categorized as a skilled worker.  In practice, most of the departments have outsourced or contractorised the unskilled or semi skilled jobs leaving the MTS to cater to the requirements of the skilled functions.

Wage structure in civil service is to be determined on the basis of the computation of the minimum wage; fair comparison of wages elsewhere, growth in the economy etc. The living wage, which is a constitutional guarantee, has not been defined.  The 15^th Indian Labour Conference held in 1957 brought in the concept of “Need Based Minimum wage” on the basis of Dr. Aykhroid formula.  The need based minimum wage is required to be provided for an unskilled worker whenever one is employed.  The definition underwent minor changes, when the Supreme Court revised the norms later.  Presently there are no unskilled regular employees’ cadre in Government of India services.  The Commission is required to first determine the need based minimum wage as per the Dr. Aykhroid formula and make necessary adjustment to determine the wages of MTS which is the lowest category in Government of India services. The co-relation of the wages of the skilled and unskilled worker at the lowest grade had always been of the order of 130% for the skilled worker.  The minimum of the pay of the MTS/SS has therefore to be determined at 130% of the need based minimum wage.

The minimum maximum ratio obtaining in different countries as per information gathered by V CPC was as under:

                                               

                                                Malaysia         -           1:3

                                                Sweden                       1:4

                                                USA                 -           1:4

                                                Britain             -           1:6

                                                France             -           1:6.6

                                                Indonesia        -           1:6.9

            `                                   Australia         -           1:7.7

                                                Thailand         -           1:9

However, the earlier Pay Commissions had adopted a ratio of 1:10.  Since the minimum wage in the Central Government sector is no more related to an unskilled worker, this ratio must be proportionately changed to 1:8.  If one is to take into account the fact that the Pay of Cabinet secretary, being the topmost Civil Servant is excluded by the 6^th CPC, the ratio in reality between the minimum and maximum  will be  more than 1:9.

Therefore, so far as maximum salary in the case of a Secretary level officer is concerned the reasonable ratio between minimum and maximum salary may be taken as 1:8 and salary of Secretary level officer may be fixed by multiplying the minimum wage by a factor of 8.

1.2 What should be the considerations for determining salary for various levels of functions falling between the highest level and the lowest level functionaries?

Salary for various levels of functions falling between the highest and the lowest level functionaries should be determined by applying the existing vertical and horizontal relativities which have been evolved over a time through various Pay Commissions.

In respect of special functionaries like Professionals and technocrats who normally prefer to work in the Private Sector and therefore either do not offer themselves for Government service or tend to leave it and go over to the Private Sector, Instead of providing them the salary structure of Group A administrative post they  may be  granted a special Pay package.

Similarly semi-skilled workers engaged in hazardous activities like scavenging, maintenance of rail track, in Laboratories, Hospitals and handling chemicals, explosives etc.  may also be considered for a special treatment.

2. Comparisons

2.1 Should there be any comparison/parity between pay scales and perquisites between Government and the private sector? If so, why? If not, why not?

There should be no comparison/parity between pay scales and perquisites between Government and the private sector for their functions and objectives are incomparable.  While the private sector is motivated by the concept of maximization of profit, the requirement of quality  service to public without any favour is the cardinal principle of governance.  A civil servant is supposed to possess the qualities of being fearless, honest,  appreciative of inherent  difficulties, non- discriminatory between one citizen and the other; sense of equality; adherence to the rules and regulations etc.

However a “fair comparison with outside wages” is a principle which has been adopted world over for determination of wages of Civil (Government) servants and therefore at least at the bottom level,  wages must be on par with  the average minimum wage obtaining in selected Private/Public sector undertakings,  subject to the condition that it should not  in any case be less than the Need Based Minimum wage determined and quantified on the basis of norms adopted by the 15 ILC.

So far as perquisites are concerned no comparison with those obtaining in Private sector is possible except in the case of House Rent/Travelling Allowances. Other perquisites in the Private sector have been granted on altogether different considerations.

2.2 Should there at all be any comparison/parity between pay scales and perquisites between Government and the public sector? If so, why? If not, why not?

           

Yes. For the sake of a fair comparison of wages especially in the background that some of the Government employees are called upon to perform  in a hazardous situation as mentioned in reply to question No. 1.2.

2.3 The concept of variable pay has been introduced in Central Public Sector Enterprises by the Second Pay Revision Committee. In the case of the Government is there merit in introducing a variable component of pay? Can such variable pay be linked to performance?

The concept of performance related pay structure was actually imported by the 6^th CPC through the Pay Band and Grade Pay system.  In the absence of an objective measurement criterion to evaluate the performance of individual officials and groups, the innovation was flawed right at the outset.  The 6th CPC failed to recognize the fact that in Governmental set up, segmentalisation of functions into tiny units is next to impossible.  In order to make the concept workable, the organization must be capable of finalizing clear cut targets both at the individual and group levels. This being difficult in most of the Governmental organizations, it is not desirable either to continue with the existing system or import or replicate what is done in the Public Sector Undertakings. This apart, it is pertinent to point out that most the west European countries, which adopted the Performance pay related scheme in civil service in the hay-days of Thatcher-Reagan era subsequently discarded it as infeasible. 

 

3. Attracting Talent

3.1 Does the present compensation package attract suitable talent in the All India Services & Group A Services? What are your observations and suggestions in this regard?

Generally the pay package in Government service at all levels is at a low level compared to the exorbitant pay packets provided by some of the Transnational Corporation in the private Sector.  This has no doubt a deleterious impact on the quality of personnel recruited to Civil service, especially at lower levels.  Since the Group A Service officers in Civil Service enjoy enormous power, perks privileges and an incomparable job security it has continued to attract talents.  As mentioned elsewhere, while parity with the pay and perquisites with the private sector is neither desirable nor feasible, the Commission must ensure that the widening gap in this regard is taken into account as an important factor to be addressed. The element of statutory Pension is one very important and significant factor in attracting persons for Government service, which has been replaced with NPS.   Therefore, the NPS and PFRDA Act may be scrapped and statutory pension as a service condition may be restored.

3.2 To what extent should government compensation be structured to attract special talent?

           

Government may be required to requisition the service of personnel with special talents of professionals, Scientists, technicians  and technocrats for specific jobs.  The Commission may evolve a scheme for the recruitment and retention of such professionals ,  technocrats, technicians and Scientists with special pay packets and flexible service conditions.

4. Pay Scales

4.1 The 6th Central Pay Commission introduced the system of Pay Bands and Grade Pay as against the system of specific pay scales attached to various posts. What has been the impact of running pay bands post implementation of 6th CPC recommendations?

The Pay Band and Grade Pay system evolved by the 6^th CPC in implementation of the concept of performance related pay structure in civil service, in our opinion, brought about a chaotic Pay structure.   It did not serve the requisite purpose.

4.2 Is there any need to bring about any change?

            Yes.

4.3 Did the pay bands recommended by the Sixth CPC help in arresting exodus and attract talent towards the Government?

            No.

The Pay Band & Grade Pay structure has not prevented the highly qualified technocrats and professions to leave the Government in search of better career avenues in public and private sectors.

4.4 Successive Pay Commissions have reduced the number of pay scales by merging one or two pay scales together. Is there a case for the number of pay scales/ pay band to be rationalized and if so in what manner?

It must be noted that the successive Pay commissions had reduced the pay scales only at the Group C and D levels.  .  There is still scope to have further exercise in this direction where clear overlapping exists. 

            

4.5 Is the “grade pay” concept working? If not, what are your alternative suggestions?

It is not working. We shall make our alternate suggestion in the matter in our memorandum.

 5. Increment

5.1 Whether the present system of annual increment on 1^st July of every year uniformly in case of all employees has served its purpose or not? Whether any changes are required?

No. In fact the single date increment system has brought in anomalies, which were discussed at length at the National Anomaly Committee, without reaching an agreement.  In our Opinion, the commission must recommend, for administrative expediency, two specific dates as increment dates. Viz. Ist January and Ist July.  Those recruited/appointed/promoted during the period between 1^st Jan and 30^th June, will have their increment date on 1^st January and those recruited/appointed/promoted between Ist July and 31^st December will have it on Ist July next. This apart the Commission is required to specifically recommend that those who retire on 30^{th june}  or 31^st December are granted one increment on the last day of their service.

 

5.2 What should be the reasonable quantum of annual increment?

The reasonable quantum of increment should not  be less than 5% of the basic pay or the rate of increment agreed upon through bilateral discussion in the Banking industry, whichever is higher.  

5.3 Whether there should be a provision of variable increments at a rate higher than the normal annual increment in case of high achievers? If so, what should be transparent and objective parameters to assess high achievement, which could be uniformly applied across Central Government?

Without defining the term “high achiever” and prescribing transparent and objective parameters to assess high achievement the system of variable increments at a rate higher than normal annual increments will be misused on subjective assessment of high achievements. For these reasons and for what we have stated in reply to question No. 2.3  the scheme of   variable increment is not desirable.

5.4 Under the MACP scheme three financial up-gradations are allowed on completion of 10, 20, 30 years of regular service, counted from the direct entry grade. What are the strengths and weaknesses of the scheme? Is there a perception that a scheme of this nature, in some Departments, actually incentivizes people who do not wish to take the more arduous route of qualifying departmental examinations/ or those obtaining professional degrees?

           

There should be 5 financial upgradation in MACP based on  the departmental promotional hierarchy. The MACP scheme is required to be continued to motivate personnel at all levels and at all departments especially in those organizations, where normal promotional avenues are few and far between.  Normal promotions are dependent upon the availability of vacancies at higher levels.  The job requirement of certain organizations may not be capable of creating requisite number of higher level positions whereas it might need large number of personnel at lower levels.  MACP alone can take care of that specific situation.  The arduous route of career progression through examination and professional qualification, no doubt will be preferred if and if only such promotions are made available for the eligible candidates within a reasonable period of residency in the feeder cadre. Say  two to  three years. 

No financial benefit accrues to a person who is promoted through the arduous route of examination or acquisition of  professional qualification, when such promotion follows the financial upgradation under MACP  Scheme.  This has to be rectified by evolving a distinctly different financial benefit scheme on grant of actual regular promotion. 

6. Performance

What kind of incentives would you suggest to recognize and reward good performance?

We are against the system of incentives to reward good performance as this would only encourage favouritism and nepotism for the reasons stated to our reply to question No.2.3 an d 5.2

7. Impact on other organizations

Salary structures in the Central and State Governments are broadly similar. The recommendations of the Pay Commission are likely to lead to similar demands from employees of State Governments, municipal bodies, Panchayati raj institutions & autonomous institutions. To what extent should their paying capacity be considered in devising a reasonable remuneration package for Central Govt. employees?

Capacity of a Governmental organization to pay cannot be gauged only from the available resources but also its potential to raise resources.  Wages cannot be determined on the single factor of capacity of the Government to pay.  It must be noted that there are various State Governments in the country which pay better pay packets, perquisites and allowances to its employees than what is provided to the Central Government employees.  Panchayati Raj institution, Municipalities, normally follow the salary structure of the respective State Governments.  It is also to be noted that various State Governments do revise the wages of their employees once in five years.  In any case the incapacity of the government to pay cannot be a justification to deny the minimum wage to workers and the salary structure based upon that concept, especially in the background that the government is to function as a model employer. It also cannot be an excuse for denial of wages on a fair comparison of the wages existing in the society which is evolved as a product of collective bargaining of the workers. 

8. Defence Forces

8.1 What should be the considerations for fixing salary in case of Defence personnel and in what manner does the parity with civil services need to be evolved, keeping in view their respective job profiles?

 

            No comments

8.2 In what manner should the concessions and facilities, both in cash and kind, be taken into account for determining salary structure in case of Defence Forces personnel.

            No comments

8.3 As per the November 2008 orders of the Ministry of Defence, there are a total of 45 types of allowances for Personnel Below Officer Rank and 39 types of allowances for Officers. Does a case exist for rationalization/ streamlining of the current variety of allowances?

            No comments

8.4 What are the options available for addressing the increasing expenditure on defence pensions?

            No comments

8.5 As a measure of special recognition, is there a case to review the present benefits provided to war widows?

            No comments

8.6 As a measure of special recognition, is there a case to review the present benefits provided to disabled soldiers, commensurate to the nature of their disability?

            No comments.

9. Allowances

9.1 Whether the existing allowances need to be retained or rationalized in such a manner as to ensure that salary structure takes care not only of the job profile but the situational factors as well, so that the number of allowances could be at a realistic level?

The existing allowances need to be retained and enhanced. .  They are at a realistic level having been evolved by successive Pay Commission over detailed deliberations.

9.2 What should be the principles to determine payment of House Rent Allowance?

The IIIrd CPC    had recommended that Government should lay down appropriate HRA rates in different cities and town based not on population criteria, but on an actual assessment of prevailing level of rent in different cities and Towns. Alternatively, certain notional rents for different types of accommodation meant for officers and personnel of specified pay groups should be laid down for particular cities after studying the actual market rent in that city. The house rent allowance will have to be the actual rent payable by an employee in a particular location as reduced by 10% of basic pay being the amount factored in the computation of minimum wage.

10. Pension

10.1 The retirement benefits of all Central Government employees appointed on or after 1.1.2004 are covered by the New Pension Scheme (NPS). What has been the experience of the NPS in the last decade?

We are of the considered opinion that the new pension scheme which came into existence for the employees recruited after 1.1.2004 must be scrapped.  The old statutory pension scheme as was in vogue prior to 1.1.2004 must be made applicable to all Government employees irrespective of the date of their entry into Government service.   The New pension scheme has in fact created a class within class amongst the Central Government employees which is discriminatory and impermissible.  It is clearly in contravention of the dictum pronounced by the Constitution Bench of the Supreme Court in Nakara Vs Union of India and therefore deserves to be rescinded.

10.2 As far as pre-1.1.2004 appointees are concerned, what should be the principles that govern the structure of pension and other retirement benefits?

The concept of modified parity introduced by the 5^th CPC as a measure to reduce the financial implication must be replaced with the full parity concept as was made applicable for the personnel retired prior to 1.1.1986. In other words, the pay of every retired person must be re-determined notionally as if he is not retired and then his pension to be computed under the revised rules. This alone will protect the value of pension of a retired person.

5^th CPC in their Para 127.6 has observed, “It needs to be averred emphatically that pension is not in the nature of alms being doled out to beggars. Senior Citizens (Retired Government employees) need to be treated with dignity  and  courtesy befitting their age. Pension is their statutory, inalienable, enforceable right & it has been earned by the sweat of their brow” Hon’ble Supreme Court, in its landmark Constitutional Bench judgement dated 17.12.1982 in the case of D.S. Nakara Vs Union of India ruled –

“A Pension scheme consistent with available resources must provide (adequate pension) so that the Pensioner would be able to live

i)  free from want, with decency, independence and self respect and

ii)  At a standard equivalent at pre-retirement level.

iii) Pensioners from payment of pension form a homogenous class. Different formulae affording unequal treatment cannot be adopted to compute their pension solely on the ground that some retired earlier and some retired later.

A comprehensive scheme of retirement benefit has been suggested by the stake holders both as an agenda in the National Council meeting of JCM and the meetings of SCOVA. The Commission is requested to consider the well thought out scheme formulated in those agenda and make recommendations  to the Government, so that the pension and retirement benefits will really become meaningful for the retired employees. We shall elucidate the points in detail when we submit the memorandum to the Commission on retirement benefits.

11. Strengthening the public governance system

11.1 The 6th CPC recommended upgrading the skills of the Group D employees and placing them in Group C over a period of time. What has been the experience in this regard?

The then existing Group D employees, to the best of our understanding have all been trained, upgraded or promoted to function as skilled group C employees and they perform well  and efficiently.       

11.2 In what way can Central Government organizations functioning be improved to make them more efficient, accountable and responsible? Please give specific suggestions with respect to:

             

            a) Rationalization of staff strength and more productive deployment of available staff;  

            b) Rationalization of processes and reduction of paper work; and

c) Economy in expenditure.

           

Whatever rationalization effected so far by the Government had been through an unscientific and arbitrary executive fiat like the one issued in 2001 and which was kept operative till 2009. The said exercise only reduced the staff strength drastically.  We are not aware of any rationalization or reduction in Group A cadres through this exercise even though the executive instruction covered all grades and cadres in the Government service. In fact there had been no rationalization but only reduction of manpower overburdening the existing workers and making  most of the Departments difficult to perform perfectly.   In our considered opinion, the 7thCPC must recommend to the Government to  set up a Committee in each department with experts from outside the organization, the officials from within the organization and representative of the Unions of the respective department to study the functional changes taken place over the years, especially due to the induction of modern technology the new challenges and the best way to meet those challenges,  reduction in paper work, customer satisfaction and economy in expenditure and make suggestions to the Government for their acceptance and implementation.

12. Training/ building competence

           

To ensure that periodical professional training is imparted to all personnel to update the skills.

12.1 How would you interpret the concept of “competency based framework”?

No comments. This in fact is a matter which must be considered by an Administrative Reforms Commission rather than the Pay Commission. 

12.2 One of the terms of reference suggests that the Commission recommend appropriate training and capacity building through a competency based framework.

           

a) Is the present level of training at various stages of a person's career considered adequate? Are there gaps that need to be filled, and if so, where?

b) Should it be made compulsory that each civil service officer should in his career span acquire a professional qualification? If so, can the nature of the study, time intervals and the Institution(s) whose qualification are acceptable, all be stipulated?

c) What other indicators can best measure training and capacity building for personnel in your organization? Please suggest ways through which capacity building can be further strengthened?

            In our opinion in- service training is the best course for skill development.

           

13.1 What has been the experience of outsourcing at various levels of Government and is there a case for streamlining it?

            Outsourcing of Governmental functions per se is undesirable and must be stopped.

The experience has been sheer duplication of work by existing regular employees and deterioration of efficiency in public service. It encouraged rampant corruption and endangered the quality of service, safety and security of the organization.

13.2 Is there a clear identification of jobs that can be outsourced?

            No. for reasons stated in reply to question No. 13.

14. Regulatory Bodies

            No comments.

14.1 Kindly list out the Regulators set up under Acts of Parliament, related to your Ministry/ Department. The total number of personnel on rolls (Chairperson and members + support personnel) may be indicated.

            No comments. The reply has to be given Government Departments.

14.2 Regulators that may not qualify in terms of being set up under Acts of Parliament but perform regulatory functions may also be listed. The scale of pay for Chairperson /Members and other personnel of such bodies may be indicated.

            No comments. The reply has to be given Government Departments.

14.3 Across the Government there are a host of Regulatory bodies set up for various purposes. What are your suggestions regarding emoluments structure for Regulatory bodies?

            No comments.

15. Payment of Bonus

One of the terms of reference of the 7th Pay Commission is to examine the existing schemes of payment of bonus. What are your suggestions and observations in this regard.           

           

The present system of Productivity linked bonus is the product of bilateral agreements and cannot be changed through unilateral decisions.  What is needed is that the Government must issue necessary guidelines to enable all departments to enter into such bilateral agreements with their staff unions so that the adhoc bonus system presently in vogue in many departments could be abolished.  This apart, the Commission must recommend that PLB, being an incentive scheme in nature, must be computed on actual pay of an employee instead of the notional emoluments.

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