| Comment Number: | OL-10504499 |
| Received: | 3/9/2005 3:00:17 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:
Regarding pay: 1. Page 7560 - I believe the NSPS system would work much better if the employees were allowed to keep their annual cost of living increase in conjunction with the new pay system. Under the NSPS system as it currently is written DFAS employees will not only be loosing the step increase, but also the annual cost of living increase. The new system allows the individual bands to be adjusted at the will of the organization. They can adjust bands annually (but don't have to do so); they can adjust only a few bands, they can adjust the upper end of a band and not the lower end (causing no cost of living increase). The organization could take years to adjust a band under this system. The other reason I believe we should keep the annual raise is the situation where a person is sitting at the top end of their band. If they receive a pay adjustment the pay is not allowed to be higher then the band top. The payout would be in the form of a bonus. If this happens in consecutive years (very likely) then that person's high three for retirement purposes doesn't increase. If the annual raise were retained, their high three would at least increase as it does under the current system when they are sitting at the highest step of their grade. The current design of the NSPS gives the appearance of DOD saving money off our paychecks. 2. I believe the shares should be more uniform. The number of shares should be decided ahead of time and the share should be the same for all employees at a rating level. I believe that if there are 20 outstanding employees then all 20 employees should receive the same share percentage. One of the very nice things about the general schedule system is that men are not paid more than women, as has been very common in private industry. This new system opens the door wide to this type of abuse. At the very least, I would expect certain safeguards and documentation requirements to be written into the regulations to monitor and prevent these types of abuses. 3. I think there is little belief among government employees that evaluations will consistently be written in a fair manner. Anyone who has worked for the government for a number of years has had to deal with a poor evaluator for any number of reasons. Now, our pay, and our jobs will be reliant on these evaluations. I would expect that the regulations be rewritten to require evaluators to confer with the employees a predetermined number of times during the rating period. This way no employee will be taken by surprise when they receive their evaluation. I also expect that the quota system will no longer be used to determine how many employees receive each rating. 4. The regulations are very unclear and vague about many functions that should be documented. I don't see that procedures for moving from one band to another band, either within the same cluster or into a different cluster, have been documented. I think there should be clear regulations and guidelines for these procedures. Regarding Reduction in Force 1. Page 7564 - The NSPS regulations change the order of RIF retention priority by placing evaluations above length of service. Since evaluations are subjective and easily manipulated, there is much room for abuse here. Newly hired friends could be kept over life long civil servants. I think that length of service should remain higher on the priority ranking than evaluations. At the very least they should be equal in importance. Regarding the Mandatory Removal Offenses 1. Page 7565 - With something as serious as MRO's there should be an initial list sent to all employees for their review and comments. These offenses should be very well documented and quantifiable. The offending employee must be given a credible hearing with an impartial audience.