Comment Number: 05-02582-EREG-95-d7391-c32114
Received: 3/2/2005 8:00:00 AM
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:

The proposed personnel regulations, published in the Federal Register on Monday February 14, 2005, could devastate morale in the civilian defense employee ranks around the globe with more than 20 year or more in service time. In the case of a reduction in force, a one-year employee with an outstanding rating would be retained over a 20-year employee with an excellent rating, according to the American Federation of Government Employees. When an employer has the power to mess with people's pay, and work schedules arbitrarily, workforce morale will suffer.

The National Security Personnel System is intended to link pay more closely to employee performance. Faintly, it may even give performance priority over seniority in hiring and firing decisions. However, the proposed Defense Department civil service reform raises a number of concerns. This is because it contains a number of changes that could, if not monitored, lead to the greater hidden favoritism and discrimination. The whole process is extremely complex with few details about how performance will actually be measured. It is clear in my opinion that performance measures in the new system will increase favoritism and discrimination found in the current system even more. Without more clarity and extensive controls for managers, it would take very little for favoritism and discrimination to creep in.

The Federal Register states that DoD and OPM has involved and collaborated with the elected representative of DoD's workers over the planning, development, and implementation of labor relations changes. However, when representatives are asked about the their involvement they say " DoD and OPM failed to engage in meaningful collaboration with the elected representative of DoD's workers over the planning, development, and implementation of labor relations changes. " In addition, there is a planned lawsuit that state DoD and OPM ignored and violated the law when they decided to completely shut out labor leaders by creating the labor relations sections of the proposed regulations without union involvement. As usual new system sounds terrific on paper but with a little investigation the wholes in the system start to appear.