| Comment Number: | OL-10507861 |
| Received: | 3/14/2005 3:35:40 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:
Docket number (NSPS 2005-001) or RIN 3206-AK76/0790-AH82 9901.103 Definitions: Reassignment – definition supports management reassignment/movement of employees to respond to mission requirements. There is a need for clear and concise standards and regulations under which this would occur. The majority of DoD employees, both civilian and military are dual income. There is spouse preference for active military spouses…but if it is DoD’s intent to make the civilian workforce mobile, then spouse preference of civilian employees must be addressed. 9901.105. Coordination with OPM, © (2): here is an opportunity for DoD to take bold action. Since this document contains language talking to a competency-based system, be bold and eliminate occupational series. A competency-based system, with appropriate tools to identify functional, supervisory and leadership competency requirements of a position will enable management greater flexibility each time the position is vacated, eliminating continual rewrites of position descriptions. © (4) establishing alternative classification standards for a particular group or occupation is a great idea – just make it competency-based versus occ series. This would also enable DoD and components to establish an inventory of competencies resident in the current workforce. This will provide the basis for workforce planning and forecasting and also enable the agency to meet critical position requirements at first glance. 9901.107. Relationship to other provisions. (1) (iii) recruitment, relocation and retention payments should have the same consideration of a fenced civilian pay account, as is recommend for salary, awards and bonuses. 9001.201 Classification. Take time to do this right. DoD is on the cutting edge with NSPS and has the flexibility of stepping out with a competency based system that does away with stove piped occupational series that restrict flexibility of managers as well as employees. 9901.211 Career Groups: Yes, yes and yes. Look to Army, Navy and Air Forces’s work on competencies as an example of creating a competency-based workforce. Take the time and do this right. 9901.221 Classification Requirements. (b) – no, no, no. Eliminate occupational series – the concept jars with a competency-based system. 9901.332 Local market supplements: (a) “DoD may provide different local market supplements for different career groups or for different occupations and/or bands.” This could easily be viewed as an effort on the agency's part to create a vehicle by which the ceiling of a pay band could be exceeded without due process or validation. Engineers, for example, could ensure engineers in the San Francisco area are protected, while other critical positions are not. 9901.345. Treatment of developmental positions. a.This may be an excellent tool for components to use to reward employees who pursue further education or certification to improve job performance. The dilemma is when employees pursue certifications or personal enhancement on their own versus the component paying the bill. This paragraph (and concept) needs to be married to mobility and PCS of employees to benefit the agency (mission-related). b.Creating a formal training/development program to build a skill base is an excellent concept. Look to creating a separate TDA for those risk-takers willing to trust the agency/components to develop and place employees to respond to strategic needs. c.Look to assessment tools to determine level of competency of supervisors and leaders. Assessments could determine training needs of the workforce, but also assist in recruitment and placement/assignment of the best suited employee.