| Comment Number: | OL-10502005 |
| Received: | 2/28/2005 4:47:25 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:
I have read the proposed NSPS Rules and I have several questions/concerns: 1. 9901.322 - DOD, within its sole and exclusive discretion, may adjust the pay bands' rate ranges. There is no mention of how often this must be done, so I assume there is no requirement for this to be done. This can certainly be used to hold everyone's pay down based on political reasons instead of fair play without any say from Congress. There are no checks and balances, and it puts way too much power into the hands of the Secretary of Defense. 2. 9901.342 - DOD may provide control points within a band that limit increases in the rate of pay. DOD may require that certain criteria be met for increases above a control point. This is basically the same as having grades within a pay band! Also, it seems it can be very subjective as to who meets the criteria and who doesn't. Also, it does not say whether these control points will change based on a change in the pay band's rate change. 3. 9901.405 and .406 - supervisors/managers must clearly communicate performance expectations. This should be required to be in writing. I have had many a supervisor advise me that "a phone call can be denied, but something in writing (including email) can not!". 4. 9901.407 - performance feedback should be required to be in writing. 5. 9901.607 - retention standing. I am not a veteran, but I do agree that they should have a preference in new hiring for their service to their country. However, if this is supposed to be a performance-based system, I do not think it is right to have veteran's preference be rated higher than the rating of record. It seems to me DOD would rather keep an excellant non-vet than an average or below vet. Overall, I believe that this is setting up a system based on favoritism and brwon-nosing, that too much power and control are in the SECDEF's hands, that politics and not performance will determine pay increases, that it is too easy to prevent increases in base pay (thus reducing pensions and making it very difficult to plan a retirement), and that an appeal of an adverse action is drastically against the employee.