| Comment Number: | OL-10504002 |
| Received: | 3/8/2005 10:18:13 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:
In accessing said document, there were difficulties. The web site we were directed to, lead us to a web page with a “condition code of 404 page not found”. After some “clicking” around, the information desired was finally located. The format was difficult to read on-line. So, the document has to be printed. Leaving an interested party feeling suspicious of the writers and their intentions to really make an effort to give the people concerned an opportunity to review it; or if they were more concerned in meeting a dead line. The information was not disseminated to this area until Feb 22, 2005. While the proposed review time is stated in the e-mail was 30days to review and recommend, and the document clearly states “Comments must be received on or before March 16, 2005”. Later it states “comments filed late will be considered only if it is possible to do so without incurring expense or delay”. Again, leaving the reader feeling suspicious. Also, the e-mail we received stated “Should you desire to review and/or comment on the proposed regulations by computer at your activity, you are responsible to seek approval from your supervisor who will ensure that factors such as mission priorities, employee workload, access capabilities, etc., are taken into account.” To top things off, people who reviewed this document prior to us, were allotted 3 weeks to review all of this documents complexities. There is not even an index for this document so, the reader can easily located information that truly concerns them. On page 7559 it states that employees are and will be able to request reconsideration of their classification, Where and when will that information and procedure be made available to the employee? What would the reproductions be? Under “Setting Rate Ranges and Local Market Supplements”, is that stating that there will still be the cost of living adjustments in addition to the pay band raise? If you are going to have a “pool manager” what system of checks and balanced will be in-place? The reason I ask is because some evaluations are due in Oct thru Dec. And there never seems to be any funds available during those months. What would happen to the remaining funds, should there be any left? Under “Promotion”, pg 7561- Need clarification on how and who does reassignments. I feel that if you are going to move someone for what ever reason an up to 10% decrease in pay is a bit much. Health insurance increases more than that almost every year. How long would the pay reduction last for? Who Regulates? Page 7562 states that supervisors will ensure employees will understand what is going to be expected of them to receive higher ratings and increased pay. Earlier, it stated that pay increases will be determined by a pool manager, taking away that decision from the manager. Page 7563 goes into great detail about improvements with the hiring practice. We were told that the application process will not change. If we are not getting great selections now, and we are going to continue using the same system then I don’t look to see better candidates either. Page 7565- There is no outline for what is considered to be misconduct. Are we talking about the UCMJ? For the government to abolish the union, it would set precedence for other labor groups. Then you are creating more jobs by establishing the NSLRB, making the need for more funding necessary. Why would a new group be created when the union services are provided to the government at no additional charges to the government. These proposed changes would set the stage for other employers to change their employment practices. I would think that setting up the NSLRB would be a conflict of interest. How could the government defend itself against itself? I do foresee that the pay ban system leaves plenty of room for the “good ol’ boy” system to settle itself back into our lives. There is already a lot of competition in the system. It is difficult at best to get promoted now. I would suggest that the committee consider allowing current employees to remain under the system that they are and assign new employees under the new system. That way, current employees are using a system that they are familiar with. It also allows for time to adjust to the new system gradually. Current employees may consider these actions as a breach of contract. People who start working for the government, start because of the way the system is. What does the word “Deployed” refer to on page 7555 and 7575? Need information on how the pay bands are going to be set-up by job series to further analyze.