| Comment Number: | EM-010795 |
| Received: | 3/4/2005 4:09:09 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 4, 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 Customs, INS, & DHS for years. I am angry that these proposals seem to treat the employees who help defend our country as the enemy. Most DoD & DHS 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 & DHS calls “pay for performance,” the amount of a worker's salary will depend almost completely on the personal judgment of his or her manager. IN THE CURRENT GS SCHEDULE A SUPERVISOR CAN BLOCK A RAISE IF HE/SHE JUSTIFIES THAT THE EMPLOYYE IS NOT DOING THIER JOB. IF SUPERVISORS HAVE NOT BEEN USING THIS TOOL THAT IS A MANAGEMENT PROBLEM NOT A SYSTEM PROBLEM. THE GS SCHEDULE RAISES ARE FAIR AND ARE TIED TO PERFORMANCE. This NSPS 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. An INTERNAL review board for DOD & DHS is not fair in any way to the employee. There is no way they will be impartial. 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 of the people serving my country but they are also responsible for caring for my family and my personal obligations at home and DESERVE better treatment than this. They signed up for a civilian job. They 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. II URGE YOU TO FORCE DoD and DHS TORETHINK THEIR PROPOSALS AND TO WORK WITH THE UNIONS AND NOT JUST FORCE THEIR WAY FORWARD WITH THEIR PLANS. We need work rules that preserve fairness, serve the American people, and respect the rights of Defense Department and homeland security workers. DHS's program should be halted immediately. After the DoD program has been revised and agreed upon with the unions, there should be a five year wait until the program has bben phased in and there is time and evidence to evaluate the success. The government should not put all government employees on the system until a five year trial program has been evaluated. DoD and DHS ARE IMPLEMENTING PLANS THAT ARE NOT GOOD FOR THEIR EMPLOYEES AND FOR OUR NATION. THEY ARE FORCING PLANS THAT ARE NOT WELL THOUGHT OUT AS FAR AS BEING FAIR OR GOOD FOR THE EMPLOYEE. LABOR RELATIONS ARE BEING SET BACK IN A MAJOR WAY AND THE EMPLOYEES WILL BECOME SLAVES WITHOUT MANY RIGHTS. Sincerely,