| Comment Number: | OL-10506870 |
| Received: | 3/13/2005 6:22:57 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 F Workforce Shaping; 9901.607 Retention Standing -- In keeping Veterans' preference in accordance with 5CFR 351.504(c) and (d) when conducting a Reduction in Force (RIF), the NSPS completely defeated the purpose of a pay for performance system. Although performance may be a factor within the veterans' preference group, these regulations still allow a Low performer to be retained above a High performing individual as long as the Low performer has veterans' preference in Reduction in Force (RIF). The NSPS is not a well balanced pay for performance system. The hiring practices under OPM are not based on quality of performance or merit but based on Veterans' preference. The NSPS rules for RIF'ing are based on Veterans' preference regardless of performance. The NSPS will not be a whole and true pay for performance system as long as we continue to hire and run RIFs based on veterans' preference. Employees will find it hard to trust a pay for performance system that will begin already with favoritism towards a single group (Veterans). Thank you for the opportunity to comment.