| Comment Number: | EM-017503 |
| Received: | 3/10/2005 3:44:27 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 10, 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 deeply concerned with the rush to put NSPS in place. It makes no sense to put a system in place that has not even been fully designed. The only reason I can think of for not waiting until the entire system has been developed before implementing it is because they are trying to hide something. The details of the system have not been worked out or if they have been worked out they are hiding them. As the old saying goes, the Devil is in the details. How does leaving out the details meet their own Key Performance Parameter (KPP) of being Credible and Trusted? My second concern is with the system?s ?movement of personnel?. The plan expects the civilian workforce to be ? easily sized, shaped and deployed.? Civilians are not in the military and thus do not have access to the family support services provided to the military. Civilians must consider many things before they move that are not a concern for the military: who will be my new doctor, will my health insurance plan cover me appropriately in a new location, will the new location have quality schools for my children, how will the real estate markets affect me if I am suddenly forced to move. I am also concerned with the proposed pay banding and pay pools. I do not see how a system can be fair when different supervisors rate employees who are then grouped into pay pools and compared against each other for pay raises. In my 20 years with the Corps of Engineers, I have seen supervisors who never gave an exceptional rating and supervisors who only gave exceptional ratings. Training supervisors on the new system will not prevent this. It appears to me that the NSPS will destroy teamwork as each individual is competing against his or her coworkers for a portion of the pay raise. I also believe pay raises will be linked more closely to personality and whether your boss likes you than to your job performance. Sincerely,