Comment Number: OL-10507099
Received: 3/14/2005 8:44:54 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:

Since 9/11, the 180 day waiting period for retired/retiring military members to be eligible for civil service employment has been in a moratorium. This policy was waived as a result of the national emergency immediately after the attacks on the World Trade Center and the Pentagon. Now, three and a half years later, the moratorium is still in effect and the "revolving door" for retiring military has returned. As a result, many military retire on Friday and return as civilian employees on Monday, frequently at senior grade levels. I have personally known individuals to retire as O-5 or O-6 and come back as GS-15s immediately. This practice removes promotion opportunities for civilian employees who have toiled for years and done an excellent job. Not only at the grade level filled, but for lower grades as well because the "domino" effect of promotions can effect several layers of exceptional performers being locked out. Congress understood the cronyism that exists in the military and imposed the 180 day period to preclude "feater-bedding" or "boring in." This practice raises a major credibility question on NSPS before it is even implemented. Will the moratorium on the 180 day waiting period for employment in DoD agencies for retiring military be lifted under the NSPS? If not, what rationale is there for keeping it and limiting advancement opportunities for high performing civilians who have spent a career, in some cases 20-30 years, preparing themselves for those opportunities?