Comment Number: OL-10505724
Received: 3/11/2005 7:12:31 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:

1. Table 1 - Sample Classification Structure - The draft reg needs more than a sample classification structure. The actual proposed pay bands should be included. How can employees truly evaluate a personnel system that doesn’t truly explain the expected pay. 2. Setting and Adjusting Rate Ranges - There needs to be a statement that the geographical factors will never be below the locality rate established for non-NSPS personnel. 3. Pay Pools - Need to establish minimum qualifications and composition of the pay pool. Need proper composition of mgt and non-mgt personnel to remove the stigma of preferential treatment. 4. RIF Retention List Priority - if this is a performance based system, shouldn't performance not tenure group be the number one criteria. 5. Mandatory Removal Offenses - These must be very clearly defined infractions that aren't subjective in nature. They must be in compliance with the law not some idiosyncrasy of a power monger. 6. MSPB Appellate Procedure Improvements - AJ's should be able to grant interim relief, etc... 7. The MSPB should be the final authority and the Sec of Defense should not be able to overrule. 8. This system will do nothing but propagate the Good Ole Boy/Girl network. If you're in with the right people, it's clear sailing. If you rub the wrong person the wrong way, your career is effectively over. NSPS has Mr. Rumsfeld's fingerprints all over this thing. I don't disagree that there needs to be improvements in the system, but don't throw the baby out with the bath water. Also are there plans to provide extra funding to support this pay system. Most organizations struggle to provide awards due to funding constraints. Most organizations are limited to a certain percentage (5% usually) of their entire payroll for awards.