| Comment Number: | OL-10508197 |
| Received: | 3/14/2005 8:41:32 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:
Apply to all sections, i.e., the entire system as proposed: To avoid both the appearance and the reality of age discrimination, the new system should not be applied to older workers with significant years of service. The inherent subjectivity of this system coupled with the reduction of workers' rights and protections potentially makes it a tool for budget cutting at the expense of older, more experienced, and highly paid workers. Proposed changes in calculating locality pay alone threaten to reduce the pensions of many older employees. Will years of experience and advancement be factored into locality pay determinations made by job categories? Or will all be lumped together? Workers with higher levels of expertise and experience within the same job category should be paid more--and they are in the private sector. Also, will the reduced rights of employees under this new system allow loyal federal employees to be replaced with low-bid contractor personnel over time to achieve budget reductions? To evaluate and compensate workers based upon performance is an excellent idea, but to remove the rights and protections that have been put into place over the years in response to abuses is to ensure that those and worse abuses will occur, probably under the guise of achieving efficiency, cost reductions, and budget goals.