| Comment Number: | EM-017671 |
| Received: | 3/14/2005 9:51:38 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 14, 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 have worked for DoD for 30 years. I would not have believed on September 11 that I had more freedom to lose at the hands of my own government than from the terrorists. I am angry that these proposals seem to treat the employees who help our military defend our country as the enemy. Most DoD employees work hard and are committed to our mission of support. I am very upset by NSPS. This system will change the way workers are paid, evaluated, promoted, fired, scheduled, and treated by subjecting workers to the whims of federal managers who have already proven to be more interested in favoritism than quality. In the thirty years I have worked for the navy I have seen every fad of good management sweep over these managers. Unfortunately, they buy into the name but never the substance of reform or quality. Under the General Schedule and FWS, employee pay was clear. It was funded by Congress and could not be taken away. However, NSPS will take away this certainty. Instead of wages adjusted for cost of living, we will be at the mercy of subjective reviews that will set whether we get salary increases. We are asking a group of supervisors, who fought for pass/fail ratings because they were too lazy to take the time to properly evaluate their employees to become fair reviewers of the workforce. These supervisors will be expected to communicate and evaluate their employees. The normal methodology for today?s review process is to scribble the least required on the annual evaluation, give it to the employee, and ask them to sign it. No discussion has been the rule of thumb for this activity. It is the rare exception to find a supervisor who took his job seriously enough to discuss the evaluation as required by regulation. These same managers will now be deciding who will be getting raises and who will not. What will happen will be a new patronage pay system, the opposite of what the civil service system should represent. ?Pay for performance? will force workers to compete with one another for pay raises, destroy teamwork, increase conflict among employees, and reward short-term outcomes. There is no guarantee that even the best workers will receive a pay raise or that the pay offered will be fair or competitive. This system will create a situation in which workers are in conflict with one another and afraid to speak out about harassment, violations of the law, and workplace safety problems. Furthermore, there will be no impartial appeal system to assure that everyone is treated fairly. That?s because the appeal system will place the fox in charge of the henhouse. Without an independent appeal system, the DoD will devolve into a miserable place to work. There is a reason we are now being called human resources, DoD, and all of government is trying to take the person out of personnel. We are not objects to be moved around like pawns, but people with families, communities, and lives that need a compassionate and flexible workplace. Working for the government has never been without its stresses and strains, but workers could trust their employer to be fair and job security was protected by Reduction in Force rules that balanced veteran protections and senority and performance. You knew that you would be protected from manipulating managers who wished to remove older and better paid workers to save costs. The new RIF rules will compromise all fairness in this procedure. Manipulative managers will be able to remove the most experienced and take the fairness out of the whole process. NSPS will allow managers to schedule employees to work without sufficient advance notice of schedule changes. This will make it extremely difficult for working parents to care for their children and family. It will also mean that abusive managers could harass employees with bad schedules or short notice. Overtime rotations can be canceled, which means that employees may not be able to plan adequately for childcare and other important responsibilities. Federal employees could be assigned anywhere in the world, even into a war zone, with little or no notice. I am proud to serve my country but I am also responsible for caring for my family and my personal obligations at home. We signed up for a civilian job. We did not enlist in the military. I am a civil servant and proud to work for my government. My government used to pride itself at being a model employer which partnered with employees to get the most out of the best. This hasn?t been how we are looked at lately. Even before this assault on our basic rights, our employer has developed a mean streak that is unworthy of our country. America is at war. We are fighting for democracy abroad. But the regulations are an attack on workers? basic rights. Furthermore, NSPS will divert the attention of defense workers from the soldiers? welfare to protecting themselves from abuse on the job. I urge you to force DoD to rethink this proposal. We need work rules that preserve fairness, serve the American people, and respect the rights of Defense Department workers. Stop advertising this as a successful implementation. Most of the regulations and rules that will implement this new system has not even been delineated. This, in itself, is a demeaning and wholely dishonest way of approaching reform. Without the respect and cooperation of the workforce, which is now entirely lacking, this system will be a disaster of major proportions. Stop lying to us, it is unbecoming of the Department of Defense and this government. You can jam this down our throats but that will not make it a success, and it is certainly not worthy of the land of the free. Sincerely,