| Comment Number: | EM-010816 |
| Received: | 3/2/2005 12:02:22 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 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 am angry that these proposals seem to treat the employees who help defend our country as the enemy. Most DoD 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. This is already in evidence at the military bases, etc who are currently under the precursor, Acquisition Demonstration/CCAS. 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 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 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 has already been widely seen throughout the organizations currently under the precursor (Acquisition Demonstration/CCAS) to this proposed system. Morale is at an all-time low and teamwork and collaboration have been erroded. Workers under the Acq Demo/CCAS project now have an incentive to keep information--such as tricks of the trade, advice, or informal mentoring to themselves. Workers have even developed incentives to make co-workers look bad compared to themselves. Admittedly these problems can exist to some degree in any workplace, but pay for peroformance exacerbates them. In short, these Demo-driven incentives that are geared toward individual rather than organizational achievement (as is the case in the Acq Demo/CCAS System) have resulted in backstabbing and vicious competition among employees. Additionally, employees under the current Acq Demo/CCAS system have universally discovered that the supervisors in charge of judging the employee performance have had a natural tendency to favor people like themselves. There have been numerous instances of biases based on gender, minority status and age. This demonstration project has, at a minumum, increased incentives for employees to play office politics which are a very unconstructive waste of time and resources. The pay-for-performance as seen in Acq Demo/CCAS has singlehandedly done more to demotivate the majority off average performing employees and done little to enhance the motivation of the top 5 percent who are likely to perform well in any case. How motivating can it be if you have a paypool of 400 employees and only 50 can receive a decent raise?? And even the winners of these coveted few raises don't necessarily become better employees. True motivation must come internally from pride in one's own work. 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. 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. Public employees are proud to serve our country, but they are also responsible for caring for their families and personal obligations. America is at war. We are fighting for democracy abroad. But these 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. I urge you to force 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,