| Comment Number: | EM-008354 |
| Received: | 3/2/2005 3:05:34 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:
March 2, 2005 I understand that shortly, new personnel rules for the Defense and Homeland Security departments will come under scrutiny by both the legislative and judicial branches. According to this week's FED WEEK NEWSLETTER, hearings are forthcoming in Congress on the new National Security Personnel System (NSPS), which restricts union rights, revamps employee appeal rights and moves the agencies toward a pay-for-performance system incorporating pay banding. I also understand that at a Senate hearing focusing on DHS, some members expressed reservations about how fairly unions and individual employees would be treated under the new system, although members stopped short of indicating they might change the underlying law. I am concerned and disappointed in the DoD proposal for the NSPS, and hope you will examine what it could potentially do to the civilian workforce, the quality of their performance, and the dedication to mission here at Fort Knox as well as throughout our U.S. Government. I feel the name DoD has chosen for the program is deceiving. National Security Personnel System would lead you to believe this proposal--to revamp the civilian workforce guidelines--is for the security of our country. One item in the proposal is of particular concern to me. It seems to be designed to allow managers of DoD civilians to determine what these employees should be paid based on performance, and also determine if where they work and what they do is important enough to remain as part of the mission of the organization. Employees' positions could be in jeopardy if the managers arbitrarily deem the position is not needed within the organization. This gives the low and mid-level managers too much authority, and according to the proposal, the employee will no longer have the current appeal rights. I agree that DoD civilians should perform their duties on their job descriptions with dedication and loyalty, but allowing the managers to determine if the performance is of "expected" quality is too objective. Managers and supervisors are often transient military or newly hired civilians, and therefore unfamiliar with the duties of positions which some civilians may have held and mastered for years. Managers often do not possess the institutional knowledge required to accurately base comments on performance appraisals of their DoD civilian employees. In addition, human nature can get in the way of objectivity. Unfortunately, favoritism for a variety of reasons could bias the manager's opinion of an employee. Therefore appraisals for job performance may be biased and have nothing at all to do with the actual job performance, but rather the employee's personality or even employee refusal to cater to personal whims of the manager. This proposed NSPS system could also create animosity and dissention in the workplace among employees and hinder the teamwork necessary to get the mission accomplished. Productivity is an offspring of teamwork, and if employees are pushed into trying to outdo their peers for a potential pay raise or a positive performance appraisal, they may not work as a team to enhance the productivity of the organization. Unfortunately, employees may subtly evolve into selfish, backstabbing, paranoid workers. I fear employees will fulfill the proverbial "stomping on co-workers on their way up the corporate ladder." This NSPS proposal could destroy the camaraderie, dedication, and loyalty of our civilian workforce by creating an unfair and unbalanced environment within which to work and accomplish the government's mission. It doesn't seem to promise a more productive and secure workforce. It may even create a "straw breaking the camel's back" situation in mentally unstable employees and force them to resort to violence in the workplace as happened here at Knox several years ago. This NSPS proposal may create a "Pandora's Box" of problems and cause EEO complaints to go through the roof! I assure you that I have no problem in my current position, nor with my supervisors. I am happy with my position, and my supervisors are happy with my performance. I am happy with the current system, and feel the NSPS proposal would be detrimental to the current system. Thank you for considering my opinion.