| Comment Number: | OL-10506796 |
| Received: | 3/13/2005 9:51:34 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:
My specific comment is in reference to APPEALS-SUBPART H, I believe that the Department needs to meet the HIGHEST standards. Management needs to make every effort to find out all the facts before an action is taken. Hiding behind the old excuse, I didn't know, indicates to me that it is management that is being capricious and arbitrary. The proposed changes encourage management to act in this manner. The current standard, that the Department may be required to pay attorney fees based on facts that were not known when the action was taken must be maintained. This in NOT an unreasonable standard.