| Comment Number: | OL-10510533 |
| Received: | 3/16/2005 10:21:03 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:
Subpart A General Provisions It seems that despite saying that only specific chapters of Tilte V USC may be waived, NSPS seems to waive a lot more than its authority. But does it? If NSPS is not limited by just this. And in 9901.102, the Secretary may with sole and exclusive discretion make any group eligible or ineligible for any or all of these new reforms. So this means that there could be different sets of standards for managers versus employees. If employees have to get the highest performance rating for two years to go beyond a control point in the payband, the Secretary could have separate directions that managers in a certain payband only need to have one exceptional rating. This is truly an opportunity for disparate treatment. The rules are going to have to be the same for both employees and supervisors/managers. Managers are paid at a higher rate already, supposedly due to their additional and more responsible duties, and making a lot of separate rules for them will only increase the likelihood of a two class system, where one preys upon the other. .