| Comment Number: | OL-10510619 |
| Received: | 3/16/2005 10:48:06 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:
Sample Comment SUBPART F - Workforce Shaping Pages 7588-7590 Section 9901.601-611 Under this subpart of the proposed NSPS regulations, the DoD will have total flexibility to layoff employees in any organizational unit, line of business, product line, funding line, and several categories of jobs and pay structures. Through the use of surgical RIFs, transfers, furloughs, and other actions, management will have new powers to reassign or remove employees for almost any reason. In contrast to existing government-wide regulations, DoD will have the ability to create new competitive areas and groups using a variety of criteria when conducting targeted RIFs. It for example, it would allow people over 50 (or maybe people earning over a certain salary) to be placed in the same organizational unit and then layed off by a RIF targeting that organizational unit. The new process is not a “performance-based” system claimed by the DoD. Non-performance factors, such as organizational unit, product and funding lines, and other considerations will affect RIFs more directly than employee performance ratings, which contradicts the purpose and intent of NSPS, as claimed by the DoD. The current RIF rules that apply to DoD employees should be retained until a truly fair and appropriate set of rules is proposed.