| Comment Number: | OL-10512190 |
| Received: | 3/16/2005 11:24:26 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:
SUBPART H: APPEALS. I object to all of the sections contained in Subpart H with the exception of section 9901.806 and recommend that they be deleted. I recommend that any appeals system include a process which will be perceived as credible and will allow the MSPB to perform its functions independently. As proposed, this system allows DOD/OPM to opt out of the appeals system or override MSPB decision makers and substitute their own judgment during much of the appellate process outlined in this section. DOD/OPM note they will be conducting ongoing evaluations of the DOD HR System, paying special attention to the adverse action and appeals process’. I recommend that if this process is included in the final regulations that DOD provide the information it gathers to employee representatives and allow the Unions to have a role in the review process.