| Comment Number: | OL-10509835 |
| Received: | 3/15/2005 7:07:56 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:
All comments are 5 CFR Ch XCIX Part 9901 - further referenced by paragraph heading. Note this is second submittal of comments, as my first set seemingly disappeared when I was typing in my address. Also note that all of my segregated comments run together, and end of quotation marks shows up as " in the database. Process While KPPS are listed in terms of "accountability, merit, flexibility to manage to budget, etc" the overall DoD metrics are still tied to one thing: the ability to obligate funds to the amounts appropriated each year. Any thought to updating those as well? Scope of Authority Essentially waives all statuatory protections afforded to present civil servants in favor of DoD-specified and selected administrative procedures. What good is asking the MSPB to act as an independent review board, and involving OPM as an honest broker if they have no independent authority? Classification With DoD-specific classifications and pay scales, how will employees be able to compare, share, and compete with those in other agencies? Table 1 - Most DoD employees above GS-12 operate in both professional and supervisory/managerial roles - how will they be banded? Compensation Comparability Since most DoD employees grades and pay average below comparable employees in other agencies, limiting the incentive pay to that available under the old system will seemingly lead to migration of our best employees to other agencies. Pay Pools Failed miserably under the "GM" concept in the 80s - what makes this one better? Agree with the idea that should have flexiblity to increase base and give incentive bonus. Initial Conversion Tends to empower the selecting official again - nice idea. Will the tendency toward central control in DA (CPOCs) be reversed? Premium Pay What will become of civilian pay in combat zones (haz duty)? Performance Mgmt Good idea to allow project-specific and ongoing changes to PS, but how will we align DoD goals with these? Performance and Behavior Good idea, but the entire body of personnel regs, including those governing our uniformed service peers, is based on the opposite premise. How will we reconcile this? Monitoring Performance Disagree with the premise regarding pay for longevity. In my agency (DA) the problem is pay for heirarchical position. Those at HQ and MSC are generally two grades higher than those at FOA for same work. How will NSPS correct this? Adverse Actions and Appeals What good is MSPB appeal if their 'legal" authority to adjudicate DoD cases is removed? Furthermore, the replacement 'administrative" procedures have yet to be promulgated, and will be as directed by DoD. This hardly seems independent or fair.