| Comment Number: | EM-001397 |
| Received: | 2/28/2005 3:10:23 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:
February 28, 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 almost 15 years. The NSPS system will change the way workers are paid, evaluated, promoted, fired, scheduled, and treated. These rules would create a system in which federal managers may determine who gets raises based on favoritism rather than on fairness. This does not serve the best interests of the American people. Annual Pay Raises Would you like your annual raise to be based on your public approval rating - whatever its percentage is the percent of your salary that you receive? Likewise, I do not want to trust my compensation to the whims of any supervisor, although I have great supervisors now. 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 relative 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 will reward short-term outcomes and "brown-nosing." There is no guarantee that even the best workers will receive a pay raise nor that the pay offered will be fair or competitive. A victim of base closure, I have finally managed to return to Government service. During part of my hiatus, I was employed by private industry and by a Government contractor, where I witnessed first-hand how demotivating lack of security and stability was. The (supposedly cheaper) temporary contract personnel often openly demonstrated the "contractor attitude," doing the minimum necessary. You might think the hope of permanent employment would motivate temporary employees to perform their best, but that is not what I witnessed. That did not overcome the awareness that their employment was at the pleasure and whim of their supervisors. The permanent employees exhibited much better attitudes and produced more. On two occasions about 1 1/2 years apart, a temporary contract worker had to be fired for viewing Internet pornography on company time. No permanent employee was caught doing this. This is what you risk if you allow these changes in the Civil Service employment system. Secondly, this system will create a situation in which workers are afraid to speak out about harassment, violations of the law, and workplace safety problems. Furthermore, there will be no impartial appeals 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. Furthermore, NSPS will divert the attention of defense workers from the soldiers? welfare to protecting themselves and their best interests on the job. I urge you to require 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,