| Comment Number: | EM-001274 |
| Received: | 2/23/2005 8:16:16 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: "-Hiring is too slow; adversely affects our ability to attract and retain high quality talent" How exactly is NSPS going to address these problems? I don't currently see any problem getting new talent at the Detroit Arsenal in Michigan, where new employees are being brought on board weekly. The problem with attracting and retaining high quality talent in the government is related to pay and widespread knowledge. Pay in the government is significantly less than the private sector, and jobs available in the federal government are not widely publicized. My interpretation of proposed NSPS regulations allows for some pay flexibility, but only allows for current overall budget allowance for the overall pay pool...no increase in overall budget allowance for federal worker salary is provisioned for, and therefore will not occur. ?- Current pay system results in outstanding performers being paid the same as poor performers? The current GS pay system also results in employees understanding how much they can and will make currently and in the future. For many people, the simple and stable GS pay system was an incentive to come to the government from the private sector. The federal government, overall, pays its employees significantly less than the private sector?one of the only ways of enticing people to make the switch is the stability of a federal government job under the GS pay system and current regulations. ?Rigid, inflexible rules hinder DoD?s ability to act without delay to meet mission needs and manage from ?total force? perspective? What current rules specifically are being referred to by this statement? I find that stability of pay, and simplified performance reviews have led to groups of workers interacting and functioning as a team with the ?soldier in the field? as a primary focus for getting the job done. ?DoD has over twenty years of successful experience with testing personnel flexibilities ? it is now time to expand those flexibilities to the rest of the Department? I am unaware of any success stories associated with DoD messing around with human resources over the past two decades, please share with me some examples of the positive effects that these ?flexibilities? have had on the ?soldier in the field?. ?DoD needs a flexible, agile HR system to meet the demands of a dynamic national security mission, while preserving the core, enduring values of the civil service? Over the past twenty years, DoD has decreased the amount of human resources personnel and consolidated their locations. For example, at the Detroit Arsenal our CPOC is located all the way over in Rock Island, Illinois. HR was agile and flexible when it was properly staffed and located twenty years ago, how will NSPS recreate this situation? The core of the civil service is, ?to support and defend the Constitution of the United States against all enemies, foreign and domestic; that I will bear true faith and allegiance to the same; and that I will obey the orders of the President of the United States and the orders of the officers appointed over me, according to regulations and the Uniform Code of Military Justice. So help me God." And this job can better be accomplished without people dedicating and focusing a good portion of their abilities into pay concerns rather than doing their core jobs. ?3. Value talent, performance, leadership and commitment to public service? How will this be accomplished if someone feels they have been wronged, but have lost the ability to use their union to help their voice be heard? ?4. Ensure accountability at all levels? This comment sounds like a line from a Lean Manufacturing textbook; however Lean Manufacturing principles also refer to personal empowerment at all levels. I haven?t read anything in the NSPS regulations that calls for personal empowerment at all levels. ?7. Be competitive and cost effective? How are these two phrases both possible at the same time with a change compared to current standards? To be more competitive, the government would have to increase pay to that of the private sector which would be a great overall increase in government spending?which NSPS does not allow for. To be more cost effective, the government would have to make a simpler pay system that required less oversight and overhead?which NSPS is definitely the opposite of! ?- Ability to offer more competitive, market-sensitive compensation? So NSPS would trade the stability of government jobs, which in itself is a recruitment tool, for the same compensation environment of the private sector? Current turnover rates in the private sector are less than five years, is this what we desire for the interest of National Security? ?Annual performance pay increases? Longevity will not play a factor in NSPS! Longevity is what provides the experience and expertise to ?get the job done right?. How can longevity not be part of how a person is reviewed for a pay increase? How will the government keep track of what the current market adjusted minimum and maximum should exist for each pay ?band?? ?Proposed system retains negotiated grievance procedures with arbitration; but excludes matters relating to pay, MRO actions, and ratings of record? Aren?t those the top 3 subjects that a union functions to protect individuals? rights for? Or, put differently, those are the top 3 areas in which personal rights are abused and neglected; so, without a union grievance, how will individual rights be protected during those matters under NSPS? My final comments: I am a Mechanical Engineer with approximately 4 years of experience. I am the very "high quality talent" that NSPS proposes to attract and retain. What will my pay band minimum and maximum be for Warren, Michigan? If I have to go through the same performance based reviews as the private sector, then this pay offered through NSPS better be HIGHER than what I am worth locally (according to Salary.com is a median salary of $80,942 + benefits). Working for the government has increased difficulties and responsibilities when compare to the private sector. If the stability of job pay and classification is to be striped away from government jobs, then the pay of governent jobs will have to EXCEED private sector salaries in order to RETAIN talent like myself. Many technically talented individuals switch to the federal governement based on job stability. Currently a Mechanical Engineer like myself is offered a GS-13 position under an 830 classification which currently equates to an annual salary of $64,886. How will NSPS compensate in this gross difference in pay? Also, if NSPS compensation will be competitive with the private sector, then who will take care of the 10,000% (yes 100x current) increase in the number of applicants for current job openings?! 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 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. 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. Salaries and bonuses are funded by DoD. 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? "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. 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,