| Comment Number: | OL-10511240 |
| Received: | 3/16/2005 2:41:46 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:
Many statements about the code under NSPS are vague and nonspecific. I am concerned about the following: 1. Paragraph 9901.332, Local Market Supplements, states DOD may provide different local market supplements for different career groups or for different occupations. This should be deleted. Federal employees need to have guranteed expectations concerning pay benefits. Do not penalize most occupations because of their skills. A substitute policy would be premium pay for high-to-fill or those careers who need considerable academic backgrounds. 2. Paragaraph 9901.516 states: Internal placement actions may be made on a permanent or temporary basis using competitive and noncompetitive procedures. This should be changed to read: Internal placement actions may be filled with permanent or nonpermanent employees under competitive procedures. The reason fo this change is that favoritism will prevail on filling vacancies if merit-based factors are not used. All positions should be filled on a competitive status.