| Comment Number: | OL-10506321 |
| Received: | 3/11/2005 1:42:05 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:
Comments on NSPS. As a federal civil servant of more than three decades and a manager of more than a decade and one who is currently working under a personnel demonstration project, I feel obliged to offer some comments on the proposed NSPS. First and foremost, I concur that the existing GS system is in dire need of overall and the proposed system is far better and clearly represents an incredible effort by a large number of talented individuals. Second, I think it would benefit from some minor adjustments and I therefore offer some suggestions as follows: Paradoxically, the extraordinary degree of freedom offered by these federal regulations, I believe, will, in the long run, be counter productive, cause delays or abuse that will undermine the intended goals and that the DoD and nation would be better served by more restrictive language. For example, -I would limit extraordinary pay increases to no more than, say, 20% per annum (perhaps less; there is too much opportunity for abuse here particularly, during times of change of administrations when some employees seek to “burrow” into career civil service positions.) -I would struggle to cut the size of this regulation in half by deleting “fluff” that is not needed. -I would eliminate wasting DoD resources in duplicating Dept of Labor wage surveys or limit DoD to only deviating to say =/- 20 % from DoL labor statistics for locality pay -I would change the implementation due date from “prior to November 2009” to “prior to October 2008” or even “prior to October 2007”. -I would mandate a 5 level performance system (not: “at least 3”) -I would mandate that the larger of at least 1 person or 5 percent of the pay pool workforce be rated in one of the bottom 3 of 5 ratings. -I would limit the percentage of individuals in the top rated level to less than half” -I would change table 1 title from “Sample Classification Structure” to “NSPS Classification Structure” and I would call the three levels Apprentice, Pay Band (PB) 11, Journey Level, Pay Band (PB) 13, and finally Expert, Pay Band (PB) 15; thereby reducing confusion when dealing with agencies on the GS salary scale. I would explicitly make the middle level have more overlap visually with the Apprentice and Expert (thereby allowing the Journey level salary to have maximum flexibility for the employee and the organization. -I would change table 2 title from “Sample Rating Methodology” to “NSPS Rating Table.” There is very little to be gained by DoD employees all over the country agonizing over this; clearly, some of the best practices in the country have been considered. Just pick one and tell us what it is so we can get on with getting what the warfighter needs. -To allay fears of change, I would clearly state that: no (acceptable performance) employee will have his or her salary reduced. -I would make the second level (as opposed to a higher level) supervisor the pay pool manager and dictate that each first level supervisors be allocated at least 90% of their “fair” share with the balance held at the second level and I would make a separate pool fund available for higher lever contingencies. -I support the proposed regulation regarding personnelists and lawyers regarding bargaining units. -While I think it is obvious to all the DoD including Navy, Air Force, and Army, I would explicitly say so under definitions.