| Comment Number: | OL-10505780 |
| Received: | 3/11/2005 8:16:36 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:
I am writing to express concern that the new NSPS system may lead to subtle age discrimination during any period of downsizing. Given that it establishes that future RIF actions would rank performance scores first and length of service second, it sets the stage where higher paid older employees could be eased out the door in favor of lower paid younger employees by just grading the older employees one score lower. An example would be grading the older employee as “Exceeding Performance Criteria”, while grading a younger employee as “Exceptional” when in reality there might be little difference between 2 good employees. Personality differences, physical appearance or even politics, could be the only difference between the 2 good employees and it would be hard to challenge a basically good rating such as “Exceeds” and prove that it should have been “Exceptional”. When the RIF arrives, the higher scored 6-year employee stays and the lower scored 26-year employee is out the door, with a net salary cost savings for the agency. This potential age discrimination problem does not appear to exist under the current Civil Service System.