| Comment Number: | OL-10501380 |
| Received: | 2/24/2005 8:51:25 PM |
| 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:
COST-BENEFIT ANALYSIS: NSPS rules are complex and difficult for the average individual who does not have a background in these programs to understand. An easy to follow -- old vs new -- chart would have been helpful. While the current GS system is not perfect, it is impossible to say that the proposed changes under NSPS will be any better. Different is not necessarily better and the proposal does not make a solid business case for implementing a wholesale revision of a complex set of rules in a relatively short timeframe. I see no cost-benefit analysis. There is no discussion of the cost to deploy this major reform and no discussion of quantifiable benefits to the taxpayer. JUSTIFICATION NOT SUPPORTED: The justification that this reform is needed to improve national security is not supported by hard facts of any kind. There are any number of ways to boost/augment national security through excepted appointments or other flexible hiring authorities that would appear to be less costly than this major rehaul of civil service rules. DEPLOY IN STAGES: In place of a total revamp of civil service rules as we know them and phasing in by location (spiral bases), recommend a phased implementation of the various NSPS authorities. Phasing in the NSPS authorities would allow DOD and OPM to assess the impact of the various programs. Deploying all of the authorities (albeit to phased locations) at once, will be more difficult to baseline and assess results. In fact, different aspects of NSPS could counter other provisions. For example implementing wholesale pay banding & pay-for-performance could have a positive impact while the new appeals and grievance rules could negatively impact an organizaiton's overall performance. An alternative to consider would be to implement portions of NSPS, compare results to a baseline, adjust if needed, and proceed to the next NSPS proposal.