| Comment Number: | OL-10501567 |
| Received: | 2/26/2005 10:45:10 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:
I believe the proposed NSPS will undermine the Federal Civil Service and hurt DoD employees, their mission and careers. The following specific sections apply: Subpart C Pay, Sections 9901.301 to 9901.373 -- DoD employees should continue to receive the same annual pay accross-the-board adjustment that other GS/FWS workers receive. Subpart D Performance Management, Sections 9901.401 to 9901.409 -- To ensure fairness and accuracy, DoD employees should be able to appeal any performance rating through an INDEPENDENT grievance and arbitration process the same as or similar to the current system. Subpart F Workforce Shaping, Sections 9901.6012 to 9901.611 -- Did should not change the current layoff and Reduction-in-Force (RIF) rules and procedures that provide a balanced credit to performance and longevity of Federal Civil Service/DoD employees. Subpart G Adverse Actions, Sections 9901.701 to 9901.810 -- There should be an independent body that reviews any major suspension such as termination, and it must be allowed to alter the proposed penalty if they deem it to be unrasonsable. The current standards approved by the courts to guide such bodies should be maintained and continue to be used. Subpart I Labor-Management Relations, Section 9901-901 to 9901.929 -- There is no compelling reason to change or take away collective bargaining and grievance rights. Therefore, the current labor-management law that governs employees' rights to organize and engage in collective bargaining should be maintained and continue to be used. DoD should not create a "company dominated dispute board". Any dispute board must be "jointly selected" by management and the Union.