| Comment Number: | OL-10502848 |
| Received: | 3/3/2005 8:53:57 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:
General Questions: 1. What is DoDs "national security mission?" 2. What functions/jobs are critical to the "national security mission?" Performance Management-Subpart D (pg 7562): It is stated "... the behavioral expectations must be set by the supervisor at the beginning of an appraisal period ..." Is the outcome being controlled whether right or wrong? What happened to empower the employee to get the job done? Appeals-Subpart H: How can you have conflicting legal standards between 5 U.S.C., Chapter 77 (MSPB) and Section 9901.107? Section 9901.107 should totally conform to 5 U.S.C., Chapter 77. Otherwise, 5 U.S.C., Chapter 77 needs to be modified. Labor Management Relations-Subpart I (#18 on pg 7573): Why aren't the same rules and remedies being used for grievences that occurred prior to implementation of NSPS? E.O. 12886, Regulatory Review: It is stated "Among the NSPS design requirements is to build a system that is ... flexible, credible, and trusted." How will these requirements be implemented? Also, 5 U.S.C. 2301(b) should be used for additional requirements in building the system. Other key requirements should be "fair and equitable." Subpart D-Performance Management (9901.401): Performance appraisal systems should be developed that are objective and can be quantified in some manner. Past practices have been slanted heavily towards being subjective and haphazardly justified. Also, ratings have been based on who you know and not what you know. Hopefully the new system will correct these past bad practices. Note: 5 U.S.C. 2301 should be used in developing the performance appraisal system. Mike