| Comment Number: | OL-10511607 |
| Received: | 3/16/2005 4:18:57 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:
3) Adverse actions & Appeals: The Constitution protects our rights to petition for redress of grievances. It is generally agreed that the current employee appeals system is too cumbersome, confrontational and time-consuming. However, merely shortening the allowable response time does NOT address the problem. It simply takes a great deal of time for an employee to get all the requisite information together for an appeal. Shortening the timeline and removing experienced employee advocacy from the process serves only to trivialize and marginalize the constitutional provision under which employees are empowered to petition for redress of grievances. Appeals should be based entirely on OBJECTIVE FACTS. A supervisor's opinion, or subjective documentation generated by the supervisor, should NEVER be the only basis of personnel decisions. The appeals process should routinely (!) require that MANAGEMENT support its documentation and decisions with independantly confirmable facts, instead of excusing management failures at every opportunity. Thus the current practice of addressing appeals in a highly subjective manner will NOT be improved by NSPS, and as such I wholly support any litigation aimed at compelling DoD personnel management to tell the truth!