| Comment Number: | OL-10504815 |
| Received: | 3/10/2005 11:08:04 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:
SubPart F Workforce Shaping, Retention Ranking. Retention Standing. Change section 9901.607of proposal to read: DoD will establish a retention standing based on the following order---Tenure, Performance, Length of Service, Veteran's Preference". NSPS is supposed to be a performance based system that also considers veterans preference. The law says in reducing staff, "...performance, veteran's preference, tenure of employment, length of service..." must be considered. If you are focusing on performance, the scale should not rank veteran's preference above performance, and furthermore, if performance has been high over 10 years, that fact needs to be factored in ahead of veterans preference, otherwise the performance is inappropriately diminshed in favor of a "select" group, and having nothing at all to do with performance. The ranking for retention needs to be tenure, performance, length of service, and veteran's preference. It is proper and appropriate to rank tenure, performance, and length of service, ahead of veteran's preference and fully comply with the statute.