| Comment Number: | EM-001224 |
| Received: | 2/23/2005 9:23:05 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:
February 23, 2005 DoD NSPS Comments , DoD NSPS Comments: I write to express my concerns about changes to work rules in the Department of Defense (DoD). The proposed regulations, known as the National Security Personnel System (NSPS), were printed in the Federal Register on February 14, 2005. This message will be sent to both DoD and my representatives in Congress. I have worked for DoD for 21 years. I am angry that these proposals seem to treat the employees who help defend our country as the enemy. Most DoD employees work hard and are committed. I believe that mistreating the employees will hurt the agency's mission. I am very upset by NSPS. This system will change the way workers are paid, evaluated, promoted, fired, scheduled, and treated. These rules would create a system in which federal managers are influenced by favoritism rather than serving the civil concerns of the American people. In many cases the managers or supervisors do not have a basic understanding of what functions their assigned personnel accomplish and how they accomplish these duties. There can be no true "pay for performance" criteria applied to these individuals' evaluations. Needless to say without an appreciation and understanding of what and how these duties are accomplished, a supervisor cannot provide a true (good or bad) performance rating. Annual Pay Raises Under the General Schedule and FWS, employee pay was clear. It was funded by Congress and could not be taken away. However, NSPS will take away this certainty. DoD funds salaries and bonuses. In the past - as recently as just last year - DoD did not fund its awards program. Given the agency's miserable record on this issue, how can employees feel confident that our salaries and bonuses will be funded in the future? There is a definite negative precedent being set by DoD that will ripple throughout the entire national workforce. Basic securities are such as coast of living, within grade increases, and financial awards are subjectively proposed and possibly scheduled for elimination. These actions are a basic betrayal of guidelines established by the Department of Labor in the late 1950s. These guidelines lead to the creation of the Office of Personnel Management (OPM). OPM has been very successful in insuring fair treatment of the entire (both government and private sectors) US work force. OPM has ensured employees are treated in a fair, non-discriminatory manner; buy hearing grievances, petitions and legal cases where employee and employers cannot reach a reasonable settlement. The NSPS proposals will empower DoD to initiate these negative actions, against their federal employees, without the same non-discriminatory actions affecting the all other civilian and non-government employees our of the sphere of DoD' influence. If this is not discriminatory, I do not know what is. The government (OPM) has always set the standards for fairness and equal treatment. Why should DoD be allowed an exception, without a true "Operational Plan?" "Friend of the Supervisor" Pay System With the new patronage pay system, which DoD calls "pay for performance," the amount of a worker's salary will depend almost completely on the personal judgment of his or her manager. This system will force workers to compete with one another for pay raises, which will destroy teamwork, increase conflict among employees, and reward short-term outcomes. There is no guarantee that even the best workers will receive a pay raise or that the pay offered will be fair or competitive. This system will create a situation in which workers are in conflict with one another and afraid to speak out about harassment, violations of the law, and workplace safety problems. Furthermore, there will be no impartial appeal system to assure that everyone is treated fairly. Again these DoD proposals lack sustenance, as there is no true mechanism, other than Supervisor Opinion providing the final input into these issues. There are no clearly defined provisions delineating what a supervisor must do in order to take action against an employee. Schedules and Overtime NSPS will allow managers to schedule employees to work without sufficient advance notice of schedule changes. This will make it extremely difficult for working parents to care for their children and family. It will also mean that abusive managers could harass employees with bad schedules or short notice. Overtime rotations can be canceled, which means that employees may not be able to plan adequately for childcare and other important responsibilities. Civilian Deployment Federal employees could be assigned anywhere in the world, even into a war zone, with little or no notice. I am proud to serve my country but I am also responsible for caring for my family and my personal obligations at home. We signed up for a civilian job. We did not enlist in the military. Today's volunteer system works well. America is at war. We are fighting for democracy abroad. But the regulations are an attack on workers' basic rights. Furthermore, NSPS will divert the attention of defense workers from the soldiers' welfare to protecting themselves from abuse on the job. I urge you to force DoD to rethink this proposal. We need work rules that preserve fairness, serve the American people, and respect the rights of Defense Department workers. Sincerely,