| Comment Number: | OL-10509393 |
| Received: | 3/15/2005 3:02:57 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:
Topic: Reduction In Force Applicable References: Pay and Administration- subpart c 9901.409; 9901.603; 9901.604; 9901.605; 9910.607; 9901.609; 9901.610; 9901.611; 9901.704; 9901.805 Workforce shaping –subpart F references the reduction, realignment, reorganization and retainment of personnel utilizing existing veterans protection criteria in a Reduction In Force (RIF). Additionally, RIF criteria changes the basis of the competition area from primarily geographic location, to one or more factors including geographic location, lines of business, product lines, organizational units and funding lines. Existing Personnel regulations for RIF will continue with the exception of placing performance ahead of length of service, and under current law compensable veteran service of 30% or more disability ahead of all other preference eligibles and will list all other veteran preference eligibles ahead of non-preference eligibles. Comment/Recommendation: using the existing veterans, preference eligibility system is not considered to be fair and reasonable, nor is it considered to be in keeping with the intent and creation of this new NSPS key operational characteristics and requirements to provide high performing workforce and management, and employees and supervisors being compensated and retained based on their performance and contribution to the mission providing for an Agile and Responsive workforce, shapeable to meet changing workforce requirements. Although protection of our veterans is a highly laudable and commendable, consider how much more useable work life does a Vietnam era veteran have? At most maybe seven years, then the only veterans preference that will remain are those who have claimed a disability, or possibly have campaign badges. There are many veterans who have fought in the line of duty and deserve a preference rating, but there is also a large percentage of those veterans who deliberately claimed some concocted disability that was not related to the line of duty. (these are the veterans who deceived the government and who will remain in government service to carry out the mission). There are those of us who are veterans, but under the current system, cannot claim any preference because we were not Vietnam era veterans, nor did we leave the service with any related disability. (These individuals will be unfairly treated in the ranking of RIF criteria remaining as currently prescribed under existing OPM regulations) Secondly, in the past several years, we have hired into DOD Federal service thousands of young college students, who have never served in the military, and have no claim to veterans preference. Where will these bright, up and coming young minds stand after the government has trained them and mentored them for several years in this proposed RIF ranking system? They have no veterans preference claims, and today’s young workforce is not formally educated to work in this bureaucratic performance system being proposed. Today’s young workforce is trained in the New Workforce mindset,, of autonomy, creativity, self governing, horizontal structuring (Performance assessment and tenure absent form our future workforce). Somehow, we need to rewrite the law for this proposed RIF ranking criteria and give thought to the intended purpose of the new NSPS and what our workforce of the year 2010 will look like. We would most desire to have the Agile and Responsive workforce proposed. What statistics can we derive from a workforce year 2010, how many workers would remain who would have veterans preference, and within that preference, how many are disabled?