Comment Number: OL-10510384
Received: 3/16/2005 9:18:02 AM
Subject: Notice of Proposed Rulemaking, Request for Comment
Title: National Security Personnel System
CFR Citation: 5 CFR Chapter XCIX and Part 9901
Attachment: NSPS COMMENTS.doc Download Adobe Reader

Comments:

The attached file, which is Word for Windows XP Professional, has more details. I have over 22 years as a civil servant. The personnel system does need revamping. I was looking forward to NSPS, but not so sure now. Page 7564 and 7565, Adverse Actions, Subpart G, 2 Mandatory Removal Offenses - My concern here is the following "DoD has not yet identified a proposed list of such offenses. However, . . . over time." UNTIL THE LIST IS CREATED AND NEGOTIATED BETWEEN MANAGEMENT AND UNION, THIS CANNOT HAPPEN. Page 7579, 9901.211, DoD will document in implementing issuances the criteria and rationale for grouping occupations or positions into career groups. I’m concerned that these groups will not be identified prior to implementation. I believe the employee should now in advance what career group they will fall into. I’m currently a GS-11 343, most of my duties are financial analysis; however I have no budget skill codes, they are all manpower. I cannot get into the budget career program without budget skill codes and with my experience being all budget, no one is likely to hire me as a GS-12 manpower person. Page 7579, 9901.212, (d) DoD will designate qualification standards and requirements for each career group, occupational series, pay schedule, and/or pay band, as provided in 9901.514. 9901.514 references the hiring of non-citizens. How does this relate to pay schedules and pay bands?? Page 7579, 9901.221, and 9901.222, The employee needs this information prior to implementation to lessen the number of mistakes made, reference my current situation annotated two paragraphs previous. Page 7581, 901.311, 9901.321, 9901.322, 9901.323, 9901.331l, The amount of the cost of living raise in the NSPS system should never be different from the amount of cost of living raise for other federal employees, ESPECIALLY the raise received by member of congress. Page 7581, 9901.313, Again, the amount of raise received by NSPS employees should never be different from other federal employees, ESPECIALLY members of congress. Page 7582, 9901.332, 9901.333, 9901.334, Pay should never be reduced unless ALL federal employees receive the same reduction, ESPECIALLY members of congress. Page 7584, 9901.373, (e) The Secretary has discretion to make one-time pay adjustments for GS and prevailing rate employees . . . the timing of any such pay adjustmnet. Does this allow the Secretary to reduce pay or increase pay, or both? Page 7591, 9901.712, (d) Nothing in this section limits the discretion of the Department to remove employees for offenses other than those identified by the Secretary as an MRO. If the offense is not on the list of MROs, how can the employee be removed? If the offense is not listed, the employee cannot know that removal will happen. THIS IS UNJUST!!!! Do we the people need to fear our government now? Page 7591, 9901.714, and 9901.715, How can the reply period expire prior to the notice period? Page 7597, 9901.910 Management Rights, If civilians become deployable assets, some issues need to consideration. Will we receive the same training as the military, i.e., weapons firing, chemical training, etc.? Will our pay become comparable to our military counter parts? A GS-11 makes about the same amount has a high year E-5 or a low year E-6, with none of the tax benefits. GS-11s also have more management responsibilities than do E-5s or E-6s. We are expected to comport ourselves at a higher level of professionalism. Personally, I think this is a great idea, but it should be on a voluntary basis. If the civilian work force had wanted to be deployed on a consistent basis, we would have joined the military. As I took several hours of my personal time to review this information, I sincerely hope that the concerns addressed will receive the consideration they deserve. Some of us have a hard time adjusting to new ideas, especially when we feel we have no say in the matter.