| Comment Number: | OL-10506604 |
| Received: | 3/12/2005 10:25:03 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:
General: Many of the most significant issues are relegated to the catchall phrase "subject to DoD implementing issuances". The most significant issues concerning employees are what they will be paid under what rules. This notice does not contain enough detail to discern those. As such, as a DoD employee, I am very uncomfortable with this proposed rule. I have 21 years as a Federal employee, 15 of those as a DoD (Army) employee. I have worked very hard, made many sacrifices, and accepted many responsibilities for what I felt were the good of the Army and the nation. I am very concerned about a philosophy that seems, to be driving these regulations. That philosophy seems to dictate that most people who have advanced in there career and are near the top of their GS grade and step range are dead wood, while a vast reservoir of enthusiasm and skill are available outside the government and at the lower grades, if only management could reach them. This philosophy is false, and I hope I am misreading DoD's intentions in this regard. Most of the people at the top of the fields are there for good reasons. The reasons are the tenent, skill, knowledge and devotion they have shown over long years of service. Accordingly, I respectfully offer the following comments..... Sec. 9901.352. I presume that the system is being designed contemplating employees will rarely transfer geographically within the same pay band. If not, I am confused about the inducement to employees to volunteer for geographic transfers. I cannot tell from these regulations how I would be compensated if I accepted a position in the same pay band in a new geographic area. This section concerns me greatly because the Army Senior Workforce initiative seems to contemplate a requirement for mobility. Will I negotiate pay with the new office during an interview? Will I be transferred and then find out? What does DoD really have in mind here? Sec. 9901.353. Will I negotiate pay with the new supervisor during the interview? Will I be transferred and then find out? What does DoD really have in mind here? Sec. 9901.406 Setting and Communicating Performance. Training and compensation for Team Leaders is conspicuous by its absence. The National Performance Review arbitrarily reduced the ratio of supervisors to employees. In many cases, "Team Leaders" are performing the work that supervisors previously performed. Because of the archaic legacy systems in place, Team Leaders do not receive the training that Supervisors receive, even though it is obvious that the Team Leader's role in managing performance is more important that the Supervisor's. The new regulations do not correct this situation, but may make it worse. Sec. 9901406(e). The word "practicable" in this context is virtually meaningless. To me, the section reads that management has sole discretion. If this is what DoD intends, just say so. 9907.606: This section gives the agency such broad discretion in determining competitive groups that employees and the public have no assurance management will not "game" the system for no-merit purposes when proposing RIFs. 9901:607 (3): The last three ratings of record should be used as the basis for retention, not just the last rating of record. This should be included in the regulation, not implementing issuances. Basing retention on only one performance appraisal would allow the possibility a supervisor to selectively RIF for non-merit reasons. Besides, isn’t long-term good performance more important than a one-time event?