Comment Number: OL-10507815
Received: 3/14/2005 3:24:16 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:

Comments on Federal Registry dated Feb 14, 2005 regarding the National Security Personnel System (NSPS) (Docket # NSPS-2005-001 and RIN 3206-AK76/0790-AH82) 1. Workforce Shaping – Subpart F p. 7564 and Subpart F – Workforce Shaping-9901.607 Retention standing.-(a) Retention list. p. 7589: When establishing a retention list, the factors of tenure, veterans’ preference, rating of record and creditable service are considered. Even though the document makes statements like “greater emphasis to performance … ahead of length of service”, it is not clear how these factors will be weighed. 2. E. O. 12866, Regulatory Review p. 7573 and Subpart D-Performance Management–9901.401 Purpose (5) p. 7584: The document is vague on how NSPS initial training and retraining will be implemented (e.g., on-line, classroom, manuals). 3. E. O. 12866, Regulatory Review pgs.7573-4 and Performance Management-Subpart D-Performance & Behavior p. 7562: It is not clear how the initial costs for NSPS were determined (i.e., $158M through FY2008). The significance of some costs seems to be understated. Examples include the following: a. Training for hundreds of thousands of people on such a widespread system, which will significantly affect their lives, will be quite extensive (as stated on p. 7562). This contradicts the statement that in the area of training, “costs associated with implementing NSPS will not be extensive” (p. 7573). The costs should include employee and supervisor training as well as training and reference materials. b. The document also states that in the area of HR automated systems, “costs associated with implementing NSPS will not be extensive” (p. 7573). Information Technology (IT) changes required to transform to NSPS should be a major undertaking requiring significant resources. For example, changing all the records from GS to NSPS pay bands will require significant IT changes. This compares to the major effort required to make systems Y2K compatible (i.e., changing a two-digit field to a four-digit field). c. Analyzing the mapping of employees to their respective career groups, calculating local market supplements, etc. will be a manpower-intensive undertaking. 4. Performance-Based Pay-9901.342 Performance pay-outs.-(f) and (g) p. 7583: The document addresses payout adjustments for employees who return from honorable uniformed service or from worker’s compensation status. It does not directly address those employees returning from extended leave (e.g., maternity leave). With the significant number of employees invoking their long-term leave rights under the Family Friendly Leave Act, their associated payout adjustment (if any) should be addressed directly. 5. Pay Administration (9901.351 through 9901.354) pp. 7583: It is not clear who will determine pay for newly-hired employees (e.g., HR or employee’s new organization) as well as for reassignments, promotions, and reduction in band. The document only states “DoD”, which is a vague reference in this case. 6. Subpart D–Performance Management -9901.401 Purpose (7) p. 7585: The document states there will be safeguards in the performance management system that “ensure that the management of the system is fair and equitable and based on employee performance”. No details or examples are provided to solidify this statement. 7. External Recruitment and Internal Placement- 9901.513 Qualification standards. p. 7587: Several federal organizations are currently restricted to hiring new interns (e.g., college graduates) at the GS-7 Step 1 level. This means a college graduate needs a Grade Point Average (GPA) of 3.0 or higher. Under NSPS, new hires should be hired on the basis of more than just their GPAs.