| Comment Number: | EM-008392 |
| Received: | 3/6/2005 1:53:35 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 6, 2005 DoD NSPS Comments , DoD NSPS Comments: 9901, Subpart C - Pay and Pay Administration, Subpart D - Performance Management and Subpart F How are we as Blue Collar Laborers to believe the Department of Defense will be effective at administrating such expansive, time consuming, programs? May I relate an excerpt of Mr. Tim Kauffman?s article, concerning Sen. George Voinonich in a hearing before the Senate Homeland Security and Government Affairs subcommittee: ?Voinovich, R-Ohio, railed against the Pentagon?s long history of management inefficiencies?, ?Defense is unable to properly manage its finances, contracts, buildings, supplies, personnel and business systems, according to the Government Accountability Office, which issues a biennial report identifying areas rife with mismanagement and vulnerable to waste, fraud and abuse. Eight of the items on the most recent report, called the High-Risk Series, focus specifically on the Pentagon.? So, how will they do this given their track record? You know, I?d be all for this if I believed it had a snowballs chance in Hell of working. However, let me elude as to my background; I?m a 20-year veteran of the USAF. I spent twenty years in an effective ?Pay for Performance? system. It doesn?t work! Although I?m not privy, I?m sure the sister services employ some similar system. I?d challenge you to find one veteran that would tell you; in all honesty, they found the system to be fair and equitable. A Performance for Pay system is always ripe for abuse, favoritism, or over inflation. So, what?s the sense? Any instance dilutes the system. When I began my Air Force career we were under a performance scale from 1 ? 9. Around about mid career they switched to a 1 ? 5. You see the system had become over inflated and the Department of the Air Force was going to fix it. Anyone want to guess were the system was upon my retirement, and still remains? I?ve long pondered this matter from both sides of the sword. The revelation I came to is, that performance has no place in association with pay decisions. Rather, in my opinion, performance is very well suited in determinations of retention. However, a credible appeal system for contested ratings is a must to negate any possibility of unfairness. This appeal system must be an impartial 3rd party. It will have no credibility if appointed by the administration, or management. Basically you are paid to do a job; how well you do a job dictates whether you are maintained. One thing that continues to bother me though is how you expect any more effective personnel management. You see reading through 9901 and Title 5 most everything to effect positive personnel management you?ve asked for, or stated as principles, already exist in the US Code. However, they are balanced for fair and equitable administration via the right to appeal, negotiate and arbitrate. I don?t believe the restriction of employee rights will serve to enhance your/our goal of the most effective security and defense of the nation. Rather it speaks toward a more autocratic agency. Autocratic administrations have failed more and more, in our lifetime. Correct me if I?m wrong, however I thought that autocracy is what we are fight against and have fought against since our great nation?s inception. I?ve heard and read the statement about the current system being old. I?d reiterate back to the quotation above and ask again how is this massive undertaking going to be effectively undertaken? If management hasn?t effectively learned to use, what read to me as, straightforward directions in fifty years, exactly how are they going to effectively execute new, what appear to be yet vague, skeletal, directions? This seems like a most inopportune time to throw the whole department in to ciaos. I mean the whole point here is to enhance National Security and the War on Terrorism; right? It?s just one person?s opinion, however I think we?ve done pretty fair so far under current guidance. I?d urge you to reconsider the majority of your purposed directive. This is just not the time to distract attention from exactly what you state is the purpose. I know employee bargaining representatives were supposed to have been involved in this process, however I hear tell several bargaining units have filed suit for injunction due to the fact you did not meet your obligation as defined in HR 1588-230. Is this true? Sincerely,