| Comment Number: | OL-10502711 |
| Received: | 3/2/2005 4:37:20 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:
After review of the proposed NSPS regulation it became clear that while this attempts to address many issues of the current system it really has nothing to do with National Security as it relates to where the current problems reside in the DOD workforce. It should become clear to all that read the proposal that this new system regardless of the intent will still be administered by those that currently administer the system now in place. As such and as human nature does not change this system if implemented as proposed will do nothing but create another legal system backlog with the only winners the attorneys who will benefit from the increase in court challenges and endless litigation over civil rights, labor laws and such. The current system was also designed to streamline government administration and make for a more productive workforce. However the reality is that while the intent was there the implementation has been hampered at every step by various other government rules and laws that conflict or outright overshadow the current system. One example of this is the Federal Employees Compensation Program or”FECA” for short. This program is designed solely for the benefit of the employee with little or no input allowed at the agency level. The “FECA” program or as it is known in DOD “The Third Retirement System” is the third largest entitlement program in the government and grows in costs each yr at around 4% * overall with no end in sight. (* Source, DOD/CPMS/ ICUC report) After a search of the NSPS proposed regulation was conducted not one reference was found in any section where this issue was addressed in the regulation. While that in itself is not unusual given the direction that this regulation takes, one can not help but wonder exactly what will occur once the NSPS comes into play. Employees looking at termination or other adverse actions will avail themselves of this option for continued pay and full medical benefits for life with no fear of any action that could be taken without a drastic change in the FECA law which as a benefit program, congress is not going to touch. Unless and until the FECA program is changed the costs associated with the NSPS for DOD will skyrocket costs and do nothing towards improving national security other than give many current DOD employees a real “National Security” check each and every month for life. Contact: Inv. Gene (Skip) Billings GS-11 Dept of the Army FECA Investigations Fort Carson, CO 80913