| Comment Number: | OL-10507690 |
| Received: | 3/14/2005 2:00:48 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 A--Sec. 9901.106 of the NSPS, “Continuing collaboration”, there is to be a Continuing collaboration with employee representatives; this has not happened and has forced the Unions to file a lawsuit in federal district court; the Unions have not been allowed to give constructive input. DOD has unilaterally made these changes without any input from the Unions; for those reasons the NSPS should not be allowed to be implemented at all and status quo should be maintained....Subpart B--The DOD through the “Town Hall” meeting and other correspondences has indicated that it plans to use Pay Banding. The proposed regulations do not actually provide details for the specifics on Pay Bands; they merely say that DOD will issue internal policies covering the classification system at some future date. The DOD published its regulations on the federal register on 14 Feb 2005 for public responses, this portion cannot be responded to since DOD omitted details on how this will be implemented and what and how exactly the Pay Band system will work. A vague and unplanned Pay Band system is wrong and should not be implemented. There should be no changes to the pay system until DOD has a proper plan that can be published on the federal register and allow the American public an opportunity to comment....Subpart C--"Pay and Pay Administration”, DOD has not got an exact plan for the conversion published, it says that it will try to ensure that, for fiscal years 2004 through 2008, the overall amount allocated for compensation of NSPS employees will not be less than the amount they would have had if they had not been converted to the NSPS. DOD gives itself the right to lower overall payroll amounts to less than other federal agencies, which is wrong. Federal employees throughout the government under the GS system might be getting 3.5% that year, but DOD will not have to give that amount to NSPS employees. There should be no changes until DOD has a proper plan that can be published on the federal register and allow the American public an opportunity to comment....Subpart D – “Performance Management”, DOD has published very few details on how it will be setting and communicating performance expectations; there are very few actual details. DOD says it wants the flexibility to change and modify expectations throughout the year; this is wrong and is only proposed for setting employees up for failure. While NSPS will make the rating far more important than it is now, it will take away the right that bargaining unit employees currently have to appeal that rating to an outside arbitrator. And, although supervisors will impact employees’ pay both by the rating they assign and the number of shares they choose to give, there will be no accountability and no redress for those decisions....Subpart E – Staffing and Employment, The Secretary may establish probationary periods "as deemed appropriate" for employees in the competitive and excepted service covered by NSPS. No outside limits are set in the proposed regulations. There is nothing that states the time of a probationary period or the limits if any. There should be no changes until DOD has a proper plan that can be published on the federal register and allow the American public an opportunity to comment....The is not emough space for my complete comments.