| Comment Number: | OL-10502377 |
| Received: | 3/1/2005 7:38:31 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:
Section 9901.345 Treatment of developmental positions The statement 'DoD may issue implementing issuances regarding pay increases for developmental positions' is insufficient - specifically the word 'may'. Without such implementing issuances, the transition of developmental positions is vague at best. The draft rules provide little specific guidance. This will likely cause inconsistent treatment of career-ladder individuals during the transition to NSPS. DoD should be required to develop and publish implementing issuances before developmental positions can be converted to NSPS. Without such guidance, individuals in developmental positions are likely to experience delays (possibly significant delays) in reaching the equivalent of the full performance level. Example: Suppose an individual is a GS-12 and is currently in a developmental position. Suppose that the full performance level under the existing system is a GS-13. Further suppose that the relevant pay-bands under NSPS for this individual happen to be divided between the GS-12 and GS-13 grades. Under the proposed NSPS rules, as a GS-12 this individual would be assigned to the lower pay-band (page 7561, career-ladder positions). Suppose that the individual would have been eligible to be promoted to a GS-13 two weeks after being converted to NSPS. How will personnel and managers respond to this situation with no specific guidance from DoD? Will this individual be promoted in a timely manner to the higher pay-band, will the individual experience a significant delay in such a promotion, or will the individual's eligibility to be promoted to the full performance level without further competition (as intended under the current system) be lost in the transition to NSPS? Here's my suggested guidance: Not only should the career-ladder individual's current grade level be converted to NSPS, but the full-performance level of the career-ladder position should also be converted to the equivalent band in NSPS. The full performance level should be designated on the employee's SF-50. The employee should then be allowed to move to the full performance level without further competition (as intended under the current system), subject to acquiring the necessary skills and knowledge of course.