| Comment Number: | OL-10501200 |
| Received: | 2/24/2005 9:19:18 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:
My comment addresses Subpart F-Workforce Shaping,paragraph 9901.607 (Retention Standing). As described in the proposed regulations, during a Reduction in Force (RIF), an employee with 2 years of service with an Outstanding performance rating can bump an employee with 20 years of service and an Excellent performance rating. This devalues the worth, and significance, represented by the experience derived from the length of service. My suggestion to remedy this defect is to develop a formula for equating length of service with each level in the performance rating. For example, 5 years of service might be equivalent to one level of performance rating, so that an employee with 20 years of service and an Excellent performance rating could only be bumped by an employee with an Outstanding rating if that employee has 15 years or more of service. One way to implement this might be to award an increasing number of effective service years for each level of performance rating achieved. Thus, for example, an Outstanding rating might be equivalent to 20 years of service, an Excellent rating might be equivalent to 15 years of service, etc. These effective years of service might be added to the actual years of service in formulating the retention register. Thus, in the example considered above, the employee with 20 years of service and an Excellent rating would get a total of 35 service years (20+15), while the employee with 15 years of service and an Outstanding performance rating would also get a total of 35 service years (15+20), effectively treating these two employees equivalently. This would eliminate the ludicrous circumstance of a very junior employee bumping a very senior employee during a RIF, even though the junior employee has only a performance rating only one level better than the senior employee.