| Comment Number: | OL-10506621 |
| Received: | 3/12/2005 12:45:50 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:
9901.101(b), In regards to respect of the individual and protecting rights guaranteed by law there in an overt omission of laws concerning age discrimination and, I believe, a covert implication that the current performance rating of record for one individual could obliterate the accomplishments of a long and fruitful carrer. I've seen this happen as unwitting, inexperienced, young supervisors have a tendency of awarding younger employees with good prospects and a will to please the supervisor but little experience. These same supervisors will have a tendency to view older employees as dinosaurs because of a time proven, worn-in resistance to change for the sake of change. The older employees tend to be less interested in impressing a new supervisor but usually have extensive corporate knowledge and years of professional experience that is invaluable to the mission. I would like to see more emphasis on experience versus change. 9901.212, Although the article in the Federal Register refers to sample classification structure, ie: entry/developmental, full performance and senior/expert, nowhere in Subpart B is there any mention of such a structure. How can an employee comment on something that affects them so profoundly but is so vague? 9901.212(d), refers to qualification standards in Section 9901.514, but 9901.514 is entitled "Non-citizen hiring". 9901.513 entitled "Qualification standards" provides no information on said standards. 9901.311(a), Again a structure of rate ranges is stated to be described in subpart B, but I can't locate said description anywhere. 9901.361(b), In the current structure of the DoD civilian workforce we have operated with less staff than is required as evidenced by the urgent need to recruit and retain employees as noted in these NSPS proposed rules. The only answer to these worker shortages has been for current workers to work overtime to make up for management failures. The current administration has supported abolishment of all types of overtime, preferring to label some non-supervisory employees as mangement. How will we know if an employee who is at a full performance level is considered management or not? What comments can be made regarding pending DoD implementing issuances? This Section is useless. 9901.607(a)(3) & (4), Putting the current rating of record above creditable civilian service without due consideration of past performance for purposes of retention standing is the stupidest management decision I have ever heard in my 26 years as a civilian DoD employee. This would put the government at risk of losing a brain trust with invaluable experience and corporate knowledge and is by far the worst way to conduct a reduction in force. As an employee gains tenure in an organization the tendancy is to be less engaged in their own personal gain than in the continuance and consistency of the mission. The result of such an action values motivation for the individual's personal gain above time tested experience and cheapens the core value of service to one's country. In summary, I agree with the overall need to re-align the classifications process to the need for greater flexibilty. I view the failure of the classification process to be a systematic management failure to respond to current needs. The ability or inability to hire and fire employees is in direct correlation to implementation of existing rules and the current problem is caused by a failure in effective management. This does not require revamping of pay schedules. After having worked for the federal government for 26 years I can assure you that I've not gotten the best possible pay for my services, but that is not the reason why I'm committed to my job. I'm committed to my job because I have "grown-up" in the federal workforce from a limited mechanic to a senior planner and as I end my career as "the average worker" I don't intend to be discarded like an old shoe.