| Comment Number: | OL-10506747 |
| Received: | 3/12/2005 8:00:44 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:
Subpart C Pay, Sectiom 9901.301 to 9901.373 The proposed NSPS states that an employee will not lose pay upon conversiom to NSPS but it does not Identify the cases when an employee will not receive a salary increase equal to the amount they have earned towards their next within-grade increase. Who will set the Local Market Supplement? The proposed Regulation does not specify what happens when or if market conditions are rated poorly or are below average. How will the local market supplement be affected? Employees need to be aware of what to expect to guarentee their wages. Subpart E Staffing and Employment - 9901.501 to 9901.516 The proposed regulations would replace longstanding provisions on hiring found in 5 U.S.C. Chapters 31 and 33 with unpublished procedures that will be prescribed at some future date through implementing issuances. Using this approach will allow the Defense Department to arbitrarily develop and administer new rules on staffing and employment that have not been available for public comment. This is especially troubling given the proposal to engage in non-citizen hiring to positions within NSPS. Our national security would surely be put at risk if Defense Department managers were able to exercise such hiring flexibilities. How long after the inception of NSPS will it take for managers to convert military positions to civilian ones? Subpart F Workforce Shaping - 9901.6012 to 9901.611 The Defense Department should not change the current layoff/RIF rules, which give balanced credit to performance and the employees' valuable years of committed service. Moreover, under the proposed regulations employment disputes over such matters would be unfairly limited to the Merit Systems Protection Board. NSPS is a proposed performance based system, employees competing for retention under RIF who have the same performance rating will be retained based on length of service. What happens to the VETERANS?