| Comment Number: | OL-10507723 |
| Received: | 3/14/2005 2:25:24 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:
- General Comment: The NSPS seems to revamp the method of assigning, reassigning, detailing, transferring, and promoting employees but it leaves out the fact that it also provides for a speedier process to dismiss an employee as well (i.e. reassign low performer to Iraq, transfer a disgruntled employee to the most distant parts of Alaska, etc.) - General Comment: There are many government employees currently under the NSPS. A survey should have been done to assess the "kinks and knots" already experienced by those employees and shared with the general population of government employees. - Guiding Principles: Since emphasis is placed on talent, performance, etc., the initial documents should have been expounded more on the administrative process to handle matters relating to pay,mandatory removal actions, and ratings of record. Employees view the NSPS as a way to minimize their pay by rating their performance low. Safeguards to prevent this should have been presented. - Pay and Pay Administration- Subpart C: Local market supplements in lieu of locality pay seems to put government employees at the mercy of a system that still needs to be more specific. If employees are guaranteed not to have a reduction in pay for the Initial Conversion, is this excluding the locality pay? In many instances, the locality pay is substantial. Are the local supplements equal to the locality pay? - Table 2 - Sample Rating Methodology is unclear since it doesn't lay out all the relevant conditions. Explain...is the rating level the "grade" the supervisor has given the employee? Is "share range" given a monetary value? Is the supervisor's performance rating based on that of his/her employees? It's reasonable to expect the supervisor be given a low rating level if his employees are performing at a low rating level. Will NSPS ensure this? - Adverse Action Procedures: It seems insensible, unrealistic, and horrifying that a supervisor may not afford an employee an opportunity to improve their performance. As all employees can and will be affected by unexpected life-events that may result in low performance for a short period of time, to give a supervisor the hammer to take adverse action is cold and inconsiderable. It puts supervisors in the position of a "god" able to axe an employee at vulnerable time. This will encourage what is now call the "postal" employee behavior. - Appeals-Subpart H: All adverse actions taken under DoD placement programs must be appealable to MSPB to ensure the actions taken are fair and just.