| Comment Number: | OL-10509007 |
| Received: | 3/15/2005 12:00:23 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:
Examples are 9901.231 (b) or 9901.342 (d) (1), but are not limited to them. In many instances the procedures on how implementing will take place is left to DoD with the Department being the ultimate authority. There seems to be an inadequate system of checks and balances (read that procedures, protocols, and divisions of responsibility) to ensure fairness of aplication. The system speaks of converting contract positions to civil service with no mention of how the present requirements/authorizations/FTE's or other artificial Department limitations will be lifted. This problem is not addressed by this Personnel System but appears to be indicative of sales rhetoric present through much of the preamble to 5 CFR 9901. Will the present overtime practices be addressed and/or changed by the implementation of this new Personnel System? It is not apparent in any of the the subparts.