Comment Number: EM-008405
Received: 3/5/2005 9:17:04 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:

March 5, 2005 DoD NSPS Comments , DoD NSPS Comments: For the past nine months, I have been a Department of Defense employee at Fort Leonard Wood in Missouri. The majority of my working life, some thirty years, has been with civilian entities. My husband is also an employee at Fort Leonard Wood, and a Navy veteran. I am telling you this so that you will understand that I know what I?m talking about. I have lived in both worlds, have seen both sides and am writing to tell you that the NSPS plan will severely harm the Civil Service, and will ultimately undermine the mission of DOD employees. One of the few things I like about the new system is that it will allow the offering of jobs to all civilians at once. For example, we if are in need of another Librarian at the Clarke Library where I am employed, the way things are now set up, the Library can only allow Veterans or current government employees, through the RESUMIX system, access to this job. This is particularly frustrating when a local librarian might be perfect for this job but cannot apply. It?s ridiculous that the (potentially) best person for the job cannot even apply for it. Please don?t mistake me here; I do believe that Veterans and current employees should have preferential points on these jobs, particularly Veterans. But make it a point system where all aspects of the application are given points : ten points for Veterans; five points for other government service; five points for education; five points for experience; five points special knowledge, skills and abilities. This would not only be much more equitable, but would give Commands a much larger pool of people from which to draw. One of the problems I do see with the NSPS is in pay. While I do understand that under the current system there may be cases where a lazy or underachieving person gets the same raise as a innovative, overachieving person, I also understand that under the new system there is a danger inherent in giving supervisory discretion over pay. Supervisors can ?tweek? a person?s review to give them more or less money than they deserve based solely on how the supervisor feels about that person. In the new system, an overachiever, or someone who finds new way to do things, or someone who works harder and longer, but who is also a bit of a pain in the neck, might actually find themselves getting a smaller raise than those who do little or nothing, but are friends with the boss. Pay raises should not be funded at the discretion of the Department of Defense, but should be mandated by Congress as is the case now. While we are direct employees of the Department of Defense, since it is headed by a member of the President?s cabinet, is ultimately responsible to the President alone. That means that our pay could conceivably fluctuate greatly as new Presidents are sworn in or out. As Congress is responsible to all the people, they should be the ones to decide if money is available to the employees of the people. Another problem I see is that the NSPS would take away our rights to appeal performance ratings to an independent grievance or arbitration group. As stated above, it is too easy to manipulate reviews and without the ability to appeal to an impartial group, cronyism would run rampant. This extends, also, to due process and fairness in reviewing suspensions and terminations which are perceived by the employee as unfair. There are standards in force at this time which have been approved by the courts to make sure that each case is treated equitably; they should be maintained. One of the most heinous of the new NSPS ideas is the change in layoff/RIF rules. By changing the layoff/RIF rules, you leave honest and hardworking employees who have put their time and energy into supporting the mission of the Department of Defense at risk. Again, while there may be a few people who do the minimum and mark time, there are thousands of us who understand the importance of the work we do, and who should not have to worry every day whether our long years of service will be thrown away. This is one of the most morale-breaking things I?ve ever witnessed. It is impossible to give everything you have to a job when you are waiting for the axe to fall. This situation leads to extreme toadying in some and inexorable despair in others. In either case, the job is not getting done. The mission is not being supported and the layoff becomes a self-fulfilling prophesy. Time served with a company, and especially the government, should be rewarded not punished. And we must now consider ourselves deployable assets. While I realize that a little part-time library tech might not have much to worry in this area, the possibility does exist. As I said, my husband served in the Navy, and I served as a Navy wife. We are serving the government now in our positions as DOD employees. We are both too old to be considered for the regular Navy, but now we must face the possibility of being drafted into service again. Ah, I do know what you are thinking. Well, if you can?t or won?t deploy, you can always leave your job. So tell me how this differs from your changing the layoff/RIF rules? It is a way to serve one of two purposes : to increase your man-power abroad without using the people who have signed up for direct military service, AND to get rid of people you want to get rid of. With this system I can be an exemplary employee but may be making waves that my supervisor, her supervisor, his supervisor, or even the president doesn?t like. All of a sudden I?m faced with a terrible decision : at 47, deploy or lose my job. Another terrible decision is the one in the NSPS which supports a company dominated board. Any EFFECTIVE board must be selected by both the company and union, and should represent not only the company, but the workers as well. Or maybe I should say the people as well. Because it is people who will suffer under the National Security Personnel System. The NSPS has one or two good points, the most noticeable being that DoD jobs would be offered to a larger pool of people. Otherwise it seems to be a way of corporatizing the civil service. It will offer us the chance to be refused raises based on time of service to our country; it will offer us a chance to lose our jobs if we decide we do not want to, or are unable to deploy; it will offer us a chance to have years of loyal service be rewarded with layoffs, while those who have served a shorter time, making less money, will be kept. It will offer us the chance to be fired if our idea of a career path does not mesh with the ideas of someone else?s career path. Instead of receiving our pay raises from the elected Congress, it will leave us at the mercy of a member of the Presidential Cabinet for our pay raises. It will offer us a chance to accept disparity and disputed pay raises with a company-based board where we are not represented ? in those instances where it will allow appeal decisions at all. In the end, I feel that the changes supported by the National Security Personnel System will lead to the break down of an effective Civil Service, and will severely undermine the mission of Department of Defense employees. I also feel it flies in the face of all principles of equality, justice and humanity upon which our Constitution is based. Sincerely,