| Comment Number: | OL-10508871 |
| Received: | 3/15/2005 11:14:48 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:
SUBPART A - GENERAL PROVISIONS: 9901.105 - Coordination with OPM Paragraphs (3) and (4) Recommendations: 1) Abolish ALL Classification Standards. The following standards are not current and the majority have not been updated in over 30 years: GS-403, Microbiology (42 yrs); GS-414, Entomology (40 yrs); GS-645, Medical Tech (37 yrs); GS-646, Pathology Tech (37 yrs); GS-688, Sanitarian (35 yrs); GS-698, Environmental Health Tech (35 yrs); GS-683, Dental Lab Aid/Tech (33 yrs), etc. 2) The Class Standards do no ensure equity of pay. Managers in the Department of Army have received delegated classification authority in Oct 89. This authority allows managers to classify and/or override classification decisions rendered by the human resources staff. There is little or absolutely no classification consistency. 3) Since there is no real accountability or check and balances for classification accuracy, Class Standards serve no useful purpose. 4) Job descriptions can be limited to a maximum of two (2) pages and include: (a) General Description (maximum of four (4) broad statements. (b) Brief examples of tasks to be performed. (c) Describe only the key and essential knowledges, skills and abilities. (d) Describe the essential qualification requirements. Subpart D - PERFORMANCE MANAGEMENT: 9901.406 - Setting and communicating performance expectations: MILITARY MANAGERS AND SUPERVISORS: There should be a "specific" performance element on the military OER/EER that holds military personnel accountable and responsible for supervising and managing civilian employees, the same as it does for federal civilian supervisors/managers SUBPART E- STAFFING AND EMPLOYMENT: 9901.513 - Qualification Standards - Recommendations: 1) Allow DoD or agencies to develop their own qualification standards based on industry standards. 2) Agencies use Qualification Review Boards to approve requests for pay increases based on additional credentials, certifications, licenses, assumption of assigned managerial, supervisory or leadership responsibilities, and professional activities that significantly impact the organization, or agency.