| Comment Number: | EM-017417 |
| Received: | 3/13/2005 10:51:53 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 13, 2005 DoD NSPS Comments , DoD NSPS Comments: This proposal is often referred to as "Pay for Performance" - a boon for the high achiever; though the NSPS proposal seems ideal, the 53 page account in the Federal Register is quite vague. A few of the many concerns are: Page 7 of 53; employ the 30/30/30 method of review. "Collaborative" review with employee representation (union) is further discussed. On page 23 it is written the Federal Mediation and Conciliation Service may provide assistance. However, 9901.106 allows the Secretary to implement the proposals if he determines further mediation is unlikely to produce agreement. This implies any alternatives offered by DoD employees or members of Congress may be rejected out of hand. Subpart B Classification: 9901.211 Career group classification is not specified; it is possible chemists may be classified with machinists with accountants; no groupings are specified. 9901.212 Career group pay bands are likewise not specified. 9901.221-222 the secretary"will develop" a methodology for [career groups etc]; methodology not specified Subpart C Pay and Pay Administration 9901.332 What is presently known as locality pay will become local market supplements. These supplements [for a single locale]may vary among occupations or within a pay band. While it may be worthy to reward the best workers with the best pay, locality pay is fixed regardless of your occupation and performance - I believe this should be consistant for all in a given locale. 9901.342 share distributions for performance is not clearly defined; there is a concern competitive ranking within a group will be implemented, regardless of individual performance. This will foster inappropriate competition and eliminate teamwork. Pay pools are not defined; it is not said at which organizational level a pay pool (and a pay pool manager) will exist. The managers will be able to override supervisory ratings and assign performance payouts in some unspecified manner. Subpart D Performance Management 9901.407-408 and 409 : monitoring/feedback and rating are all vague. Finally, I should mention that roughly the last 15 or 20 pages (of 53 pages) address labor relations. Though I have not scrutinized these sections, this brings to mind a degree of inference that the NSPS may be out to conduct some "union busting". Please do not implement this (potentially) good proposal until the actual details are made public. Sincerely,