| Comment Number: | OL-10511122 |
| Received: | 3/16/2005 2:06:15 PM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| Attachment: | Dear Sir.doc Download Adobe Reader |
Comments:
Dear Sir, I believe the proposed NSPS regulations could undermine the civil service and undermine our ability to accomplish our mission. The following comments wrt specific sections are provided. Please read my attachment to review my complete list of comments. Subpart B Classification - Section 9901.201 to 99901.231 NSPS will replace the current government job classifications by grouping them into a few occupational categories with pay being set in "bands" with the new categories. Individual employees will be unable to appeal these newly classified positions or the broad range of duties under the revised categories to a neutral arbitrator. Subpart C, sections 9901.301 to 9901.373: How are people in development jobs 5/7/9, 7/9/11, etc. affected? There are no words to address personnel in these positions. Will promoting these people, as promised them during the hiring process, take money away from acceptable performers? Subpart C, 9901.322: This paragraph contradicts paragraph 9901.313. After addressing the expected compensation comparability in 9901.313 which leads one to believe that we will not lose money as a result of NSPS, 9901.322 makes it clear that an employee may have their rate of pay reduced due to availability of funds and mission requirements. This will allow the DOD to reduce our Congressionally approved pay raises to a lower amount. While NSPS purports to be for the purpose of rewarding performance in the workplace, the reality is that a high-performing and acceptably performing employees can have their pay cut simply because the DOD has decided to use the money for mission requirements. Subpart C, Section 9901.352: Under Reassignment - Involuntary moves should NEVER result in a reduction in pay under any circumstances. Sincerely, Vincent Christinziano 853 Littlefield Road Wells, ME 04090