| Comment Number: | OL-10511865 |
| Received: | 3/16/2005 5:54:49 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:
In subpart D, pg 7561--The "static standards make it difficult to make adjustments." The standards are written to reflect the job description. The standards were to be a living document. Management could make adjustments if they so chose. "The proposed system builds in the flexibility to modify, amend, and change performance and behavioral expectations, etc--the means include standard operating procedures, organizational directives, manuals, etc." Need to ensure these items do not conflict. The work environment is a dynamically changing environment and personnel are changing working directions daily. Measuring from various "standards" will be a big challenge. To include training the personnel to be in a broader position, expanding the work experience, and across the whole organization. Personnel will be "judged" based on conduct. Need ways to measure such an item as well as "train" personnel on the performance parameter. Subpart C Pay, Sections 9901.301 to 9901.373: The employees in DoD should continue to receive the same annual pay across-the-board adjustment that other GS/FWS workers receive. -- The individual pay increases for performance should include guaranteed percentages in the regulations so that employees will understand the pay system and what their pay increase will be depending on their performance. Subpart F workforce Shaping - 9901.6012 to 9901.611: DoD should not change the current layoff/RIF rules which give balanced credit to performance and the employees valuable years of committed service to DoD. Pg. 7570-- Item 9. The "FLRA is required to apply the regulations consistent with the Department's mission" --Has FLRA been aligned with the Departmen? If not, there is a potential for conflicting information/rules being applied. Pg 7571--Item 11, "the union has no institutional right to represent the employee". Need to define who has the "institutional right". Would that be a lawyer the employee hires? Section 9901.211, pg 7579, Career groups: DoD establishes the career groups-- Need to understand how the career groups relate across Agencies or Commands within the same general area to a broader area. Throughout the document "the Secretary" is mentioned. What is the identifying factor to keep employees from being fired when the "Secretary" changes? Stability is good. Firing or relieving poor performers from their position is good. Changing the workforce too often is not good. Need to keep some intellectual capital.