| Comment Number: | OL-10502467 |
| Received: | 3/2/2005 9:17:58 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 have worked as a federal personnel specialist for 20 years. I have worked both inside and outside DOD. When I first heard about NSPS, I felt it was a good idea; however after reading the federal register, I believe we are making a serious mistake with this system. It is a pie in the sky system and ignores some real world issues. The personnel system we currently have is not perfect, but has come about because of real problems and issues over the years. The new system does not address that there is a need for position descriptions that describe what employees do and not just a general statement of work that does not allow announcements to be developed and performance standards to be developed as well as explain to the employee what they should be doing. A good example of this is the Lab Demo project where addition duties must be sent in to develop a job announcement because the job description does not describe specific duties. In general, I am in favor of a pay banding system, however it appears that this system will take away from the idea of equal pay for equal work concept. The federal register is so general on the new staffing rules it is hard to know what it will be like. The current system since regionalization has made great strides in service and timely filling of positions. To completely throw it out does not make sense. The performance system will not work. The budget constraints will not allow true pay for performance. It will be much more work intensive and appears not to allow equal compensation to highly performing work groups. Employee moral will be damaged by this type of system. Finally, I recommend not going into NSPS, but continuing to work to improve the system that we now have.