| Comment Number: | OL-10508065 |
| Received: | 3/14/2005 5:25:05 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:
In your Myths and Facts document, you state, 'Veterans’ preference eligibles are still retained over employees without veterans’ preference in RIF. Also, seniority continues to be a factor in RIF. However, because NSPS is a performance-based system, the proposed regulations give greater weight to performance in RIF retention by placing performance ahead of length of service. Employees competing for retention under RIF who have the same performance ratings will be retained based on length of service.' It is true that in developing a RIF retention list, that Veterans Preference is still a consideration. However, with the proposed changes to how competitive areas are defined, veterans preference can be severely, if not totally, wiped out. With the new NSPS, traditional bump and retreat rights can be limited to a specific organization, funding line, etc… Even with veteran preference, you cannot displace someone outside of this narrowly defined group, even though they may be in your same series/function and have no vets preference at all. DoD is not being completely honest in this matter.