| Comment Number: | OL-10505932 |
| Received: | 3/11/2005 9:45:54 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:
Comments: The DOD OPM NSPS proposed rule in more than one instance liberally uses the terminology ‘attract skilled, talented and motivated people’. This statement is not substantiated. The current propensity of the DOD to hire retired military into civilian positions with no impact on military pension’s locks out civilians from a career path that would attract the above mentioned ‘people’. In addition hiring reemployed annuitants with no impact on their pensions also precludes talented, motivated individuals from moving into positions of greater responsibility. Retention of veteran’s preference also blocks civilians with no previous military experience so the aforementioned intent to attract talented and motivated people is tremendously overstated and unsubstantiated. Until DOD provides civilian training on a par with military training civilians will not compete well with former military. Pay banding will not solve this problem, nor will it provide equity in competition for civilian positions. Funding will also be a constraint. DOD is not fully funding civilian pay currently, despite statements to the contrary, the system will be less than effective due to funding constraints. The current system if used effectively by managers provides the flexibility to adjust performance expectations during the rating period. The proposal alleges (Performance Management Subpart D page 7561) that it does not. This appears to be a trumped up argument to support NSPS, also unsubstantiated. While the current system could use improvement, the proposed system, which purports to make improvements, lacks evidence that the recommended improvements are going to make the system better. There are many details missing from the proposal. Funding concerns, coupled with the potential for favoritism in distributing raises should be addressed in more detail prior to implementing this system. The NSPS will open the floodgates for complaints. The workload will be significant. Current pay banding systems i.e. those in NAF and Acquisition should be reviewed. Those systems can provide numerous examples of system abuses. Pay raise by personality is rampant in some sectors. Supporting documentation that would substantiate the need for the recommended changes would significantly improve the proposal. The assumptions in the proposal are just that, assumptions. Where is the evidence that supports the assumptions? Certainly OPM and DOD should be able to produce statistics that support the proposal. How can either organization be certain that the changes will provide more flexibility? Attract better people? Etc., without that information.