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An Incomplete Report Card: A new Congressional Budget Office report on DOD's National Security Personnel System cites the difficulty of evaluating the program this early in the game, saying, "Sufficient time has not yet elapsed since the first employees were converted to accumulate an adequate amount of useful data." CBO noted that Congressional legislation enacted last year has limited DOD's conversion of its civilian workforce to NSPS to non-union employees, leaving the department with about 472,000 employees out of some 680,000 eligible for conversion. By this month, DOD expected to have shifted some 188,000 to NSPS under various spirals begun in 2006. CBO noted that at least one federal agency has experienced payroll cost increases under a plan that, like NSPS, employs pay banding. Under NSPS, DOD has reduced 15 pay grades under the old General Schedule system to just four pay bands, ostensibly providing it with greater flexibility in rewarding superior performers. Still, CBO says DOD must expend "greater effort … to monitor and control payroll costs" lest they "increase considerably over time." Another potential concern, cited by CBO, is the potential to create "equal-pay-for-equal-work concerns in the workforce," since it will be possible for different units to assign pay raises differently to employees performing the same work at the same level. And, of particular concern for Congress, CBO says there is still some question that DOD may be underestimating the cost to convert to NSPS.