| Comment Number: | OL-10503063 |
| Received: | 3/3/2005 9:34:30 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:
1. In the case of a reduction in force, a one-year employee with an “outstanding” rating would be retained over a 20-year employee with an “excellent” rating. What is next get rid of the Veteran’s Preferences when they get in the way of hiring “Talented Younger Employees” like a son or daughter of a manager. Or just go after the old CSRS employees because they have a better but more costly retirement that the FERS 2.When disciplinary actions are appealed to either the Merit Systems Protection Board or an arbitrator, neither would be able to substitute a lesser penalty unless the penalty was “wholly unjustifiable” – a standard some consider impossible to overcome. I also object to the system’s inclusion of mandatory removal offenses, which require the termination of the alleged offender’s employment for most offenses. 3.NSPS never collaborated with any of the union affected by the new system. It was the DoD telling the unions “This Is What Will Happen and That Is It”. To say any different is a bold face lie. Meetings held with the affected unions, does not constitute collaboration. Well may-be in a dictatorship it does and this has all the ear marks of one. 4.Pay banding will destroy any cohesiveness that an agency will have. No extra money will put into this system, so someone has to lose wages so another can gain. How can I guest it will be the lower level worker and not the senior leadership. 5.Training of managers will also deplete already over-stretched budgets with no help from DoD. What if any safe guards built into prevent misuse by a manager who are trained but don’t follow the training and goes off on their own. 6.People who work in lower cost of living areas will be penalized to pay for people who work in the high cost of living areas within the same localities within the same agency. If that is the case then more thought should be given to move the Head-Quarters of agencies into low cost of living areas first. Then pay band employees later. Budgets would go farther, if you move out of D.C. metropolitan areas and to southern West Virginia or Louisiana where the cost of office space is low to keep the overhead low, then budgets would go farther. 7.NSPS was to give agencies flexibility moving people as needed. Yet no clear guaranties on how long of deployments to needy areas, security of your job site if in a War Zone, or the amount of travel that will be incurred by employees, special needs of employees and their families are not addressed anywhere I have seen published about NSPS. 8.I have read over the information but for a system that says it will be transparent. I can’t make heads or tails of how it is supposed to be implemented and who determines what other than management is always right. Very unclear for being transparent. 9. NSPS says it does away with long job descriptions but yet says there must be clear defined and measurable goal to determine pay and performance awards. How can I make a high standard if I don’t know what the standard is? Also it says that managers and employees set the clear goals for performance standards. What if two different supervisor set different standards for the same job series at similar locations. How can that be fair to either employee?