| Comment Number: | OL-10510939 |
| Received: | 3/16/2005 1:09:00 PM |
| 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:
First: - The proposed regulations do not define the details of the system's implementation, including such issues as adequate safeguards to help ensure fairness and guard against abuse; - The proposed regulations do not require, as GAO believes they should, the use of core competencies to communicate to employees what is expected of them on the job; - And, the proposed regulations do not identify a process for the continuing involvement of employees in the planning, development, and implementation of NSPS. Source: GAO Comptroller General David Walker; Second: - Since CSRS employees were given the option of switching to FERS, why shouldn’t current Federal career employees be given the option of the current personnel system vs the NSPS? Concerns: - Under NSPS, the Defense Department will be able to deploy civilian employees within 72 hours with no recourse. - In RIFs or Public/Private Competitions, no preference for seniority will be given. This is age-ism. -For historical guidance, merit pay for supervisors and managers on the basis of demonstrated performance was mandated by the Civil Service Reform Act of 1978. It was widely acknowledged to have failed within a few years and was abandoned in the early 1990’s. The post-mortems generally pointed to inadequate funding to recognize significant performance distinctions and the inability or unwillingness of performance appraisers to document differences in performance. - Adequate funding of pay for performance remains questionable. An Administration committed to expensive entitlement reforms, a robust world role, and halving the federal deficit in five years is unlikely to pump up agency budgets with generous allocations for performance pay.