| Comment Number: | OL-10502860 |
| Received: | 3/3/2005 9:24:37 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 believe the proposed NSPS will undermine the Civil Service and hurt the mission of the DoD employees. Subpart C Pay, Sections 9901.301 to 9901.373 The employee’s in DoD should continue to receive the same annual across the board pay adjustments that other GS/FWS workers receive. The individual pay increases for performance should include guaranteed percentages in the regulations so that employees will understand the pay system and what their pay increase will be depending on their performance. Subpart D Performance Management – 9901.401 to 9901.409 To insure fairness and accuracy, DoD employees should be able to appeal any performance rating to an independent grievance and arbitration process, as we are able to do currently. Subpart F Workforce Shaping – 9901.6012 to 9901.611 DoD should not change the current layoff/RIF rules which give balanced credit to performance as well as the employee’s dedicated years of service. Subpart G Adverse Actions – 9901.701 to 9901.611 Due process and fairness demand that the independent body reviewing a major suspension as termination be allowed to alter the proposed penalty if they deem it to be unreasonable. The current standards approved by the courts to guide such bodies should continue to be used. Subpart I Labor-Management Relations – 9901.901 to 9901.929 The labor management law that has governed the employees’ right to organize and engage in collective bargaining has worked well over the past 25 years or so. I see no reason to take away any of the collective bargaining rights or grievance rights. DoD should not create a “company dominated dispute board.” Any dispute board should be “jointly selected” by management and the union.