| Comment Number: | OL-10511784 |
| Received: | 3/16/2005 5:20:11 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:
1. New NSPS system must fence funding for all performance pay and incentives as well as the training funds that are mentioned as an integral part of the new NSPS system. The reason is that folks that work under say Navy Working Capitol Fund (NWCF) type organizations will lose out due to budget marks, Cost of War (COW), Annual Operating Result (AOR), Net operating Result (NOR), etc. (nowadays it seems there is a new type of mark every FY). In FY04 for example, all training funds were held back and used to offset an FY04 budget mark. I can already see the performance pay being used to offset budget marks just like training funds are used today, because there is nothing stating management can't use those funds for that purpose. NWCF type organizations are more accountable to the budget and their staff will be disadvantaged when compared to others. 2. Training and communication appears to be the only security for staff members that management will be fair with the new NSPS system. Why will this be any different than the system we have in place today? There is nothing indicated to ensure the NSPS system is administerred fairly to all. If training and communication are the answers, why does that not work for the system in place today?