Comment Number: OL-10511949
Received: 3/16/2005 6:45:58 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:

9901.103 Reassignment. This definition is very vague. Does this mean an employee can be put in another job series? Who determines minimum qualifications? Will the type or series an employee can be assigned to be known to the employee so it's clear that as a condition of employment the employee can be assigned to a series other than the one he/she was hired for? I realize that the groundwork for doing this is addressed in 9901.221 Classification Requirements, however this is also vague. What's the timeline? Shouldn't this already be accomplished prior to any implementation? Subpart C - Pay and Pay Administration. I served 29 years on active duty in the comptroller career field. I am very knowledgable on the budget process and civilian pay funding. One of the cornerstones of NSPS is full funding of civilian pay, an event that rarely occurs. Reward for performance is already built into the current system, it's called a QSI. Problem is funding. If you give someone a QSI generally that wipes out funding for other personnel to receive yearly a bonus. What's going to make NSPS any different? I see it as worse because you won't even have longevity to look forward to. 9901.342 Performance Payouts. Largest concern here is cronyism. The government work, unfortunately, is "good ole boy system." More who you know than what you know. Pay pools will only sharpen the saw for rampant politics. I would like to believe that professional and personal could be separated but then I come back to the real world and realize it's just not possible. Jockeying for funds is going to become extremely competitive and I think many women more so than men will end up on the losing end. I accept that changes will occur. In fact, I think they're necessary. The government performs a unique mission and while some business practices can and should be adopted there are others that just won't work. Team work may fall by the wayside in an effort to outshine fellow workers in order to achieve more money. Is that what we really want? Take a look at private industry -- it happens all the time. Do you really believe this will help recruit and retain folks? Thanks for the opportunity to provide feedback.