Comment Number: OL-10510044
Received: 3/16/2005 12:40:36 AM
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:

I wanted to give a brief comment on the proposed NSPS regulations. I realize that the fix is already in, and if every GS employee wrote you and said this is a terrible idea, that it is still going to happen your way. However, here are some comments after reading your web page that describes the purpose. Let us not use the events of September 11th 2001, and the war on terrorism as an excuse to dismantle the GS system. From the summary page of the NSPS it states the purpose of the NSPS. Hiring is to slow affecting ability to attact and retain high quality talent. Is two weeks advertising (assuring that every highly qualified person gets notified and has the ability to respond to the vacancy) too long? If you wanted to shorten the time any, one could let the person start work the day after being hired. At present one must wait until the next pay period. You could shortend the two week advertising period to one hour but you might end up hiring the only person on the list that just happen by the advertising (not extremely qualified, however qualified for the job) where the next day, the most qualified person in the United States, just happen across the advertising the following day, and did not get hired. Current pay system results in outstanding performers being paid the same as poor performers. Why are these poor performers still working for the Government. One could change this with some rule changes in the present GS system. There is presently a system to give a step increase for substained superior performance. Also there is a present system for Cash Bonus for outstanding performance by an employee. Either one under the present GS rating makes it possible to reward those that are Outstanding Perfomers under the present GS system. Rigid inflexable rule hinder DOD's ability to act without delay to manage force perspectives. Under the present GS system you already (according to your Myths and Facts web page) have the capability to assign GS employees anywhere. Under the GS system I see job openings all over the world. I can apply for any of them that I am qualified for. However, if I was needed in Iraq, I am sure that the DOD could transfer me or offer me the opportunity to resign from the Civilian GS Workforce. I work in an Army Hospital, so I will just address some thoughts that are going through my mind in relation to that workforce. Working in a hospital requires several specialities. When looking at the pay bands, let us look at these cases. Not every Nurse is the same. There are specialities and licenses. There are Nurse Aids (GS-04) LPN's (GS-05) RN's (GS-06 & 07's) Nurse Practioners (GS-08-09's) One that works in an ICU or ER would be paid more than above by raising the RN from GS06 to 07. Clerks are Receptions (GS-03) Med Clerks (GS-04) Chief Secretary (GS-05) Medical Records Technicians (GS-05). One that is a called a "NURSE" can not work as a Nurses Aid (GS-04) and be expected to work as an LPN (GS-05) because of job knowledge/training and most importantly the State/Federal license is different. (Scope of Practice). You can not take a person that is called a "Clerk" GS-03 Receptionist and put them in GS-05 Medical Records Technicians job. Again the knowledge and medical training is different. This would be similar to taking a person that is called a "Mechanic" who is a small engine repair person and saying well you are a "Mechanic" so you will be a UH-60 helicopter repair person. I am not sure what their GS ratings are, but I assume the first would be GS-04 and the second would be GS-07 - 08. To summerize my thought of your NSPS proposal. As you can clearly see, the present GS system has its merits. If there are jobs that are needed in the defense of our country for force protection and mission, then even under the present GS system you can hire them. You could make certain jobs that are needed overseas, a higher pay grade and give combat pay incentives.