| Comment Number: | OL-10511215 |
| Received: | 3/16/2005 2:34:00 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:
This is a very complex change. I hope once you have considered all of the comments and made revisions that it will be published once more for comments. That is the best way to ensure a procedure that works and federal workforce unforced participation. Subpart C, Section 9901.313, National security compensation comparability, (a): Why should we believe that sufficient funding will be allocated after 2008 if you must mandate the allocation now for 2004 through 2008? At worst this appears to be another Government bailout using federal workers to supply the funding by changing mandatory increases to discretionary increases. At best we have to believe that providing discretionary funds for pay increases and local market supplements to existing workers will fall higher than everything else that needs to be funded out of the discretionary pot of funds. At a minimum the local market supplements should be a mandatory pot of funding that can be allocated as specified in 9901.334. The best approach would be to set aside mandatory funding for disbursement in accordance with the NSPS if the compensation had not converted to NSPS for the next 10 to 20 years. This would guarantee that no federal employee would go without a cost of living or pay increase because we were not high enough on the allocation list. Subpart F, Section 9901.607, Retention Standing, (3) and (4): Placing performance rating before length of service could result in stagnating the workforce, and reluctance to train new personnel. Why would an outstanding performer take a chance on a new position that could result in a satisfactory rating until they master the new job? Why would anyone in the new area be willing to help train someone that might be better than them in the long run? I have over 20 years Federal service and have received a Performance Award all but one year of that service. I changed jobs right before an appraisal period and my new boss did not receive or consider my performance at my old job. Since the appraisal was based on 1 month it was Satisfactory. By the time they gave me the appraisal in writing I was competing for Non-Supervisory Civilian Employee on the Base level. Under NSPS and performance before service I would have been gone in a RIF situation. If you are going to place performance before length of service the performance should be at least the average of the last 3 years.