| Comment Number: | EM-017442 |
| Received: | 3/14/2005 9:56:14 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:
GENERAL COMMENTS NSPS is nothing more than the legal means for the current regime to attempt to break the Labor Unions that represent the current workforce. It provides for a corrupt system that will promote favoritism and backstabbing to appease management at any cost rather than to work as a team to conduct business for the good of the taxpayer and care of the soldier and the DOD mission. SUBPART B: CLASSIFICATION, 9901.201 - 9901.231 DOD employees and the public are denied a fair and reasonable opportunity to comment on DOD's expanded authority to evaluate and classify jobs because Subpart B relies on "implementing issuances" and does not provide information on what policies and procedures will be used by DOD. DOD must clarify the mechanics of their system and not hide their true intent behind vague language and policies and procedures that have not yet been held to the light of public scrutiny. SUBPART C: PAY AND PAY ADMINISTRATION, 9901.301 - 9901.373 Successful pay-for-performance systems already in DOD are joint efforts between labor and management. DOD has designed a system that will not achieve the goals of a pay-for-performance system and will not enhance national security. Excellent employees that are in a pay pool with less money allocated by the pay pool manager will get lower raises than average employees in a pay pool with more money. Furthermore, the supervisor has almost total authority over their employees' pay and will make decisions based on favoritism and not on performance as the system intends. There are not adequate checks and balances in the system to stop bad supervisors from unfairly punishing good performers. That alone is bad enough, but managers above the supervisor may also make decisions that will unfairly cost top performers money with very little or no first-hand knowledge of the performance of the employee. DOD's authority to establish limitations on maximum pay in pay bands will cause well-qualified people to leave DOD for better paying positions with no caps on salary. In the future DOD could eliminate or reduce payroll increases. The funding available for payroll increases may not be fairly distributed across DOD. Expenses in a specific locality are the same for all employees but under NSPS all employees in a specific location will not benefit equally from locality pay. DOD's broad latitude in setting the ranges of basic pay for the pay bands sets up a system in which the funds will be distributed solely at the discretion of DOD and may be subject to misuse and re-appropriation and not used to reward employees' performance. There is no guarantee of an annual increase. If the local market conditions do not warrant an increase at the minimum rate of the band, the entire band will not be increased even though an increase may be warranted at the upper end of the band. This creates a situation where higher level employees will leave their jobs for better paying jobs in the local area. Also, the local market DOD selects may not be representative of the local area.