| Comment Number: | OL-10510556 |
| Received: | 3/16/2005 10:26:24 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 believe that paragraph 9901.605 of Subpart F Workforce Shaping compromises some of the statutorily protected civil service rights of DoD employees and will not always result in retaining the best performing employees. Specifically, paragraph 9901.605(a) allows for competitive areas to be defined in FIVE different ways: geographical location(s), line(s) of business, product line(s), organization unit(s), and funding line(s). This seems excessive, even to meet the needs of flexibility. Confining reduction in force actions only to those positions funded by ‘XYZ’ funding line of a Command’s budget for example could mean a better performing employee is released and a lower performing employee is retained. In other words, an individual in released based on nonmerit factors. Defining a competitive area in terms of the agency’s organizational unit(s) and geographical location would allow Command’s to keep their best performers. Agencies should retain employees based on their performance.