| Comment Number: | OL-10509710 |
| Received: | 3/15/2005 5:14:20 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:
As a 24+ year federal employee with DOD I am opposed to the radical changes proposed in NSPS. I reccomend the following changes: PERFORMANCE MANAGEMENT – SUBPART D. · Proposed regulation states that adequate training on the new performance management system will be provided by DoD for employees and supervisors. o Recommend that the training provided by DoD include more than just performance management, suggest including adverse actions, recruitment, career program manager etc. Training should be for employees as well as supervisors. To that end, the training should be moved to subpart A. STAFFING AND EMPLOYMENT – SUBPART E · PROBATIONARY PERIODS. The explanatory notice states that DoD may prescribe in-service probationary periods for current Federal career employees who move into certain categories of positions. o Recommend that a clause be added stating that current Federal career employees will not have to serve an additional probationary period if one was already completed. For example – If a current Federal career employee has already served a supervisory probationary period, they should not have to serve an additional probationary period even if they move to another supervisory position. ADVERSE ACTIONS – SUBPART G MANDATORY REMOVAL OFFENSES (MRO). · Proposed regulation states that the proposed MRO procedures include a requirement that a proposed notice of mandatory removal be issued only after approval by the Secretary. Also stated is that only the Secretary may mitigate the penalty for committing a MRO. (9901.712) o Recommend that the Secretary not be involved in the approval process to issue the MRO. The Secretary already establishes the list of offenses that require MRO, so there would be no need to be the final approver. Since the Secretary is the only person that may mitigate the penalty for committing a MRO, it appears contradictory if the Secretary approves the MRO but then can mitigate the penalty. ADVERSE ACTION PROCEDURES. · Proposed regulation states that the Department will provide a minimum of 5 days to reply orally/in writing if the employee has committed a crime for which a sentence of imprisonment may be imposed. It is unclear if this is 5 additional days. (9901.715a) o Recommend the wording be changed to reflect the intent, i.e. 5 additional days. nges proposed in NSPS.