Comment Number: OL-10511870
Received: 3/16/2005 5:58:19 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. Overall comments: a. How will converting to NSPS affect retirement calculations for CSRS employees? b. There seems to be no specific provisions for the expectations of supervisory employees - the amount of subjectivity in the document does not offer any comfort to those of us that have seen supervisors take advantage of their positions. 2. Classification, Subpart B: How do you propose to consider private sector pay rates, if they are substantially greater than current pay rates for the same positions, such as engineers? 3. Pay and Pay administrations, Subpart C: a. Who are the pay pool managers? b. Will unused pay (unfilled positions) become part of a pay pool, and if so, how will itbe distributed? c. What checks and balances wil be put in place to monitor pay pool managers? 4. Performance Management, Subpart D: Attitude can often be subjective; how do you intend to ensure quiet, reserved individuals aren't labeled with poor attitudes? Under setting communication and performance expectations -- you say expectations MAY include goals and objectives and MAY include observable and verifiable of manner, quality...etc. This language could make expectations completely subjective as to whether an employee met them or not. 5. Staffing and Employment, Subpart E: How will this new sytem affect the hiring within programs such as Copper Cap and Palace Acquire? These programs currently provide for almost automatic promotions to a certain level. 6. Workforce Shaping, Subpart F: Reference your discussion on employee lists for reduction in force. Will each list be separate according to pay band, career group, etc., and will employees be allowed to jump lists or are they relegated to one list only, and therefore in line for separation only according to their list? 7. Adverse Actions, Subpart G: When will the mandatory removal offenses be determined? How do you ensure expectations are not misinterpreted?