| Comment Number: | OL-10505165 |
| Received: | 3/10/2005 3:48:47 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:
Section 9901.513: Recommend requiring the DoD to obtain OPM approval for all qualification standards for positions covered by NSPS. The move to generic job descriptions will hinder our efforts to hire the best - because many, many more people will qualify as priority placement if the positions descriptions are generic. Section 9901.605(a): Recommend changing the basis for competitive area to mandate that geographic location (for overseas locations - Alaska, Hawaii, foreign countries) be a mandatory factor in workforce shaping actions. Do not give managers the ability to decide to conduct a nationwide RIF - that is not taking care of people. Section 9901.607(a): Recommend the retention list critera/factors be changed to consider the following (in order of precedence): 1. Tenure 2. Average of the last three ratings of record 3. Veteran's Preference 4. Creditable civilian and/or uniformed service.... My recommendation involves including three employee ratings to determine "performance". Also, if we are truly going to focus on a system that attracts/keeps the highest performers, then we must move Veteran's Preference to a lower priority during workforce shaping actions. What you're saying is you must keep a non-performing veteran over a high-performing non-veteran. The proposed rule does not go far enough to give our managers the ability to keep the best. General Comment: The proposed rule assumes that managers in the Department of Defense have the available skills and capacity to manage such a new system of pay banding. While many of the constructs are not new, the proposed performance awards system will drastically affect management-employee relations throughout the DoD. Unless we eliminate the four separate services, I fear that there will be inconsistent application of the proposed rule that may adversed affect civilian employees in one (or more) branches of service. This is an issue for the DoD to address through their implementing guidance. Thank you for the opportunity to comment.