| Comment Number: | EM-017591 |
| Received: | 3/11/2005 7:50:40 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 11, 2005 DoD NSPS Comments , DoD NSPS Comments: IMY COMMENTS GENERAL: I believe the proposed NSPS will hurt both DoD people and the DoD mission. Such a significant decrease in employee rights is the wrong way to encourage by incentives a more productive, more loyal workforce. Implementation of changes without prior collective bargaining weakens the partnership between management and the workforce which has developed under the current collective bargaining scheme. SUBPART C PAY, SECTIONS 9901.301 TO 9901.373 Changes in the system used to determine annual pay increases should be subject to collective bargaining before implementation. The changes should be tied to the General Service pay schedule. It would be wrong to stop current employees' pay increases, and put all increases to new and recent hires, but where is that prohibited in the regulation or where is the collective bargaining procedure to make sure that doesn't happen. The individual pay increases for performance should include be scheduled in the regulation or subject to collective bargaining before implementation. As it stands employees with outstanding performance may get no increase or the criteria outside the normal performance review process would be used to preclude outstanding employees from getting any increase at all. These changes should not go into effect unless there is prior collective bargaining. SUBPART D PERFORMANCE MANAGEMENT - 9901.401 TO 9901.409 Performance evaluations that can be appealed only within the organization are unfair. There are existing management abuses that are only checked by the current appeal process that include independent third parties. Any changes should be subject to prior collective bargaining. SUBPART F WORKFORCE SHAPING - 9901.6012 TO 9901.611 The DoD workforce should not be mercenary; loyalty should be encouraged. The changes to the layoff and RIF rules that lower the value of longevity are cynical, misguided, and wrong. Any changes should be subject to collective bargaining before implementation. SUBPART G ADVERSE ACTIONS - 9901.701 TO 9901.810 Suspension without pay and termination is a financial death penalty. Without continuing employees knowing that a suspension or termination has been subjected to outside review, a increase in distrust between workers and management may develop. The current rules have come about because of court opinion of abuses that did occur. Removing these barriers will allow abuses to return. Any changes to existing procedures should be subject to collective bargaining. SUBPART I LABOR-MANAGEMENT RELATIONS - 9901.901 TO 9901.929 There is no compelling reason to take away most of the collective bargaining rights or grievance rights. Changes in dispute rules should be subject to prior collective bargaining. The myth is wrong: decreasing employee bargaining rights and increasing the right of management to make unimpeachable decisions will not improve the effectives and productivity and loyalty of the workforce. Collective bargaining may be a nuisance to management, but it is also a check on abuses that keep the workplace from degenerating into an ineffective organization dominated by groupthink and resentment. Sincerely,