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B-164072 1 (1978-02-17)

handle is hein.gao/gaobachki0001 and id is 1 raw text is: COMPTROLLER GENERAL OF THE UNITED STATES WASHINGTON, D.C. 20548 B-164072 The Honorable James M. Frey Assistant Director for Legislative Reference Office of Management and Budget Executive Office of the President Dear Mr. Frey: This responds to your request by Legislative Referral Memorandum dated February S. 1978, for our views on the Civil Service Commission's draft bill Comprehensive Civil Service Reform Act. The limited time available has precluded us from thoroughly analyzing and reaching a final position at this point on the many areas involved. Consequently, the views we express here are somewhat general and tentative in nature and subject to modification upon a more comprehensive review of the material you submitted. We expect to offer more detailed comments in subsequent stages of the legislative process. We can, however, state at this time that, while we have reservations concerning their implementation, we favor in principle many of the concepts embodied in the proposed reor- ganization plan and bill. These include provisions covering the separation of the personnel management functions from the applate and merit enforcement functions, changes in the aerse action and appeal procedures, a revised performance appris4 system* more flexible selection procedres and the greater delegation of authority to the agencies. modification of veterans preference, the Senior Executive Service, and pay for performance. In connection with the separation of functions we note that considerable effort has been made to ensure the independence of the members of the Merit Systems Protection Board (Board) and the Special Counsel by establishing terms of office and limited grounds for removal of these officers. We support the principle of an independent Special Counsel and Board, but we have some doubts as to the achievement of this independence as between the Board and the Office of Personnel Management (OPM) in light of S. . ~. .. .

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