Comment Number: OL-10502122
Received: 3/1/2005 8:30:29 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:

Subpart C Affect on Acquisition Personnel: Contracting Officers and Quality Assurance Reps are ultimately held responsible for what we sign. Stating that we were directed by higher authority to do something has rightly never been accepted as an excuse. Contracting Officers regulalry tell military commanders and senior managers that they will not take a certain action because it violates law, regulation, or good business sense. Under the new system managers and commanding officers will be able to penalize us for fulfilling our fiduciary duty. At the same time we will still be liable for our actions. Since military commanders are only at one assignement for 2 - 3 years, they are most likely gone when things go bad. The new system will put contracting officers and quality assurance personnel in unacceptable positions. The trend of senior officers to go to work for major defense contractors after they retire is another reason why they should not be able to control the pay of acquisition personnel.