Comment Number: OL-10506098
Received: 3/11/2005 11:32:34 AM
Subject: Notice of Proposed Rulemaking, Request for Comment
Title: National Security Personnel System
CFR Citation: 5 CFR Chapter XCIX and Part 9901
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Comments:

5 CFR 330 subpart b covers the Reemployment Priority List (RPL) regulations and procedures. NSPS does not revise RPL procedures so the current regulations stay in effect. Summarized the RPL provides priority for displaced DoD employees based on Vet Preference and tenure who qualify for positions based on OPM minmum qualification standards. Subpart F of the NSPS address the procedures for Workforce Shaping and provide greater consideration for current performance than for seniority. If DoD is to become a truly performance oriented Agency, it seems prudent to reflect performance in all intake programs such as the RPL. The Priority Placement Program (PPP) and the RPL are in some ways duplicative. However, since the PPP is an internal placement program, the program requirements can be shaped more easily. For example, the PPP standard for placement mandates that a candidate be well qualified a much more stringent criteria than the RPL's basically qualified requirement. The PPP permits more categories of candidates to be given consideration. But because the RPL was a government wide program, it stayed in effect. NSPS provides the opportunity to shape workforce to advance DoD's ability to be more performance oriented. I recommend the DoD eliminate the RPL for NSPS as being duplicative and to provide that the PPP is the only Placement Program for priority for DoD positions. PPP current priorities can be revisited and redefined to reflect performance within the priorities.