| Comment Number: | EM-017427 |
| Received: | 3/15/2005 7:39:30 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:
The average individual employee can expect less effective compensation over time and greater demands to be made. These regulations take away a known compensation quantity and replace it with a highly subjective system. Tight budgets and management biases will result in curtailment of even merited increases for all but the favored few. The employee who performs his/her job in quiet anonymity will suffer financial stagnation. Everything appears to hinge on the opinion of the immediate supervisor without regard to past performance, ability, context, or any other factors. Relocation and reassignment, or resignation, is possible. These rules invite management neglect and abuse. Supervisors do not all "grade" equivalently; some are more lenient and expect less than others resulting in what can be severe skewing. Grading inequity is common and these regulations will not change it, but will magnify its impact. They presume across the board fairness, impartiality, and honest evaluation will reign, and that is unlikely. Checks and balances are lacking. A lot of the managers and supervisors are top notch. But the Peter Principle is alive and well. Management level competency can and is lacking just as it is at the lower worker level. Managers and supervisors include entrenched old timers who are subjective and do not have the same targets as the organization. While such instances may represent a minority, they do exist and are not that hard to find. These rules will allow injury to good employees working under less than the best management. They are of great benefit to the government as an entity, but many individual employees will experience them as harmful. These new rules are meant to encourage individual striving and performance, but they will be selectively used to achieve just about any outcome that management desires. The goal, flexibility, will be achieved by removing the few protections available to the individual. The objective is to make DoD more like private industry. The above concerns exist in private industry. But Federal government culture is different from private industry in one critical aspect: private industry can offer the ability to acquire a financial stake in the success and benefit from improvement and growth that is not subject to the immediate whim of management, but rather to market forces. The government cannot. My first impression is that these proposal rules are attempting to construct a strong building on an unstable substrate. 9901.221 An employee who has performed jobs other than his/her current one, and has other skills to offer to the organization as a result, will not have those abilities documented and included in the new classification that becomes effective. Under the current tight budgets, there are a lot of employees performing jobs that are not their preferred or strongest areas. It would be improper to trap them in the current or any single classification niche. 9901.222 (a) states that an employee may request DoD or OPM to reconsider a classification at any time. However, (c) says that if an employee does not request OPM to review DoD's classification determination, then DoD's classification determination is final and not subject to further review or appeal. No time frame or deadline is identified. These contradict. 9901.332 (a) states that... "DoD may provide different local market supplements for different career groups or for different occupations and/or pay bands within the same career group in the same local market area." Are local market supplements percentages? Who figures them? How? Such differences cannot be justified. If an employee lives and works in a particular local market area, he/she is subject to the same costs of living as the next employee in that location, irrespective of the job he/she does, the classification he/she holds, or any other irrelevant factors to how much things cost. What does it have to do with the job being performed?