| Comment Number: | OL-10508787 |
| Received: | 3/15/2005 10:45:48 AM |
| 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:
9901.805-808: By taking away the right of appeal fpr RIFs & DOD placement program actions, these would be handled by managers who may well know the managers whose rulings they would be overturning. Typically now little good happens in terms of fairness to the employee until the case goes to arbitration. Until then, cronies support cronies. As long as there is the threat of MSPB review, there is some semblance of fairness. Under the new system even this will be taken away. Filing times are shortened. Most employees need more time than 20 days just to learn that they can appeal. Discovery can be limited. How can an employee prepare his case without knowing the evidence against him?