| Comment Number: | OL-10509527 |
| Received: | 3/15/2005 4:02:14 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:
COMMENT #1: The FR should include a section on record keeping: "The Department will prescribe recordkeeping requirements in DoD implementing issuances." COMMENT #2: 9901.607(a)(2): The proposal states that a retention list will be established based on specific factors, including veterans' preference requirements in 5 CFR 351.504(c) and (d). Believe this is a typo as 5 CFR 504(c) and (d) are about credit for performance. Recommend deleting the reference to 5 CFR 351.504(c) and (d) or correct it to: 5 CFR 351.501(c) and (d). COMMENT #3: 9901.608(c): Placement in vacant positions: "At the Department's option, the Department may offer an employee released from a retention list a vacant position..." This implies a vacant position can only be offered to released employees. It is understood that vacancies may be used as RIF avoidance, however, once in a RIF, use of vacancies should not be held or used only for those released from the retention list as this would tend to cause more disruption. Vacancies should be able to be used in RIF to avoid displacement if possible. Recommend changing 9901.608(c) to read: "Placement in vacant positions. At the Department's option, the Department may offer an employee who is released from a retention list or is displaced because of position abolishment, or because of displacement resulting from the abolishment of the position of a higher-standing employee on the retention list, a vacant position."