Comment Number: OL-10506428
Received: 3/11/2005 3:11:15 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:

The highly praised new personnel system will simply give poor managers/supervisors an even greater ability to abuse/mistreat or even discriminate against employees. Subpart G Adverse Actions - 9901.701 to 9901.810 The current standards approved by the courts to guide such bodies should continue to be used. Asking for permission to over turn MSPB decisions is clearly against the mandate granted by the Congress. 6. National Security Labor Relations Board (page 7569) The Secretary wants to pick a three member board. Currently this Board is picked by the President with consultation and approval of the Senate. What is the rationale behind thischange from the current system to the new MSPS? Subpart F Workforce Shaping - 9901.6012 to 9901.611 DoD should not change the current layoff/RIF rules which give credit to performance and employees' valuable years of committed service to DoD. The proposed regulations indicate that when an employee is reduced in pay due to a reduction in force, the employee may get some sort of pay retention but no details are provided. The proposed regulations provide that each employee’s pay will depend on his pay schedule and pay band, his rate range, his local market supplement and his performance payout (based on his performance rating). This will be set by DOD, not Congress. How will DOD make these determinations ? Will there be wage surveys in which unions can participate? How will DOD determine what jobs in the local labor market are comparable to DOD jobs? Which local markets qualify for a supplement and which don’t? How often will DOD conduct wage surveys and adjust basic pay? I cannot see how this proposed system will impact national security. There are still a lot of unanswered questions