| Comment Number: | OL-10511823 |
| Received: | 3/16/2005 5:32:55 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:
Federal Register, 14 Feb 05, Part II, DoD, OPM 5 CFR Chapter XCIX and Part 9901, NSPS Proposed Rule Questions/Comments: The Case for Action, p 7553: ". . . the limitations imposed by the current personnel system often prevent managers from using civilian employees effectively. The Department sometimes uses military personnel or contractors when civilian employees could have and should have been the right answer. . ." Question: Does this mean NSPS will reduce the need for A-76 contracting? Performance and Behavior Accountability, p 7562: " . . . DoD mission and goals . . . Standards of Ethical Conduct for Employees in the Executive Branch and the DoD Joint Ethics Regulations . . ." Question: Are these going to be the standards to measure performance and behavior accountability? Comment: Performance and Behavioral Standards are needed to ensure expectations and evaluations are more objective than subjective. Setting and Communicating Performance Expectations, p 7562: " . . . Supervisors will involve employees in the planning process to the maximum extent practicable. . . . Final determinations in setting expectations, however, are within the authority of the supervisor . . ." Comment: NSPS allows the supervisor to have too much authority in determining expectations and pay raises. Final determinations should not be based on supervisors being allowed to make unilateral decisions. This leads to the more subjective determinations versus objective determinations. Question: Who are the supervisors and managers accountable to? Workforce Shaping--Subpart F, p 7564: " . . . The proposed regulations eliminate that tenure group and place all employees in one of two tenure groups: 1) career employees (includes employees serving an initial probationary period) and 2) employees on term and comparable non-permanent appointments in a separate, lower tenure group. . . ." Question: Tenure Group is limited to the above definition and does not take into account years of service? Workforce Shaping--Subpart F, p 7564: " . . . Under the proposed regulations, employees are placed on a competitive group's retention list in the following order: 1) Tenure group, 2) veterans' preference, 3) individual performance rating, and 4) length of service. . . ." Question: If NSPS is based on performance, then why is performance third instead of first? Question: Is length of service fourth because there no consideration for experience? Question: Does this order permit the reduction of an aging workforce, thereby reducing benefits the Government would have to pay based on retirement age requirements and length of service? Comment: Define competitive groups in more detailed. NSPS Fact Sheet, 10 Feb 05, p 2: " . . . Lengthy detailed job descriptions no longer need . . . " Comment: Performance and Behavioral Standards are needed to ensure expectations and evaluations are more objective than subjective.