| Comment Number: | EM-017674 |
| Received: | 3/13/2005 7:46:44 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:
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 as a civilian employee for over 10 years. I have heard that the intent of this new system was to make the various agencies of the govement more efficent and cost effective. I agree that there is room for a lot of impovement and change across the board in the structure of the govement workforce. However, for that to occur, starting with the pay structure of the lowest paid employees within the goverment seems to be a backward and ineffective method of bringing this change about. Goverment agencies are not designed to function in an efficient manner; there are no incentives to lower the cost of doing business or to look for more effecient means of performing as in the competitive world of private industry. There should be a system that rewards the agencies for performing effieciently and productively, that will encourage the management and employees to work toward these goals; or at least some type of procedure for using the funds saved during one fiscal year for work in the next. Effieciency and productivity start with upper management working toward these goals; however, the upper mangament in federal agencies are personnel who have spent there entire career working under a beauracratic system that offers no rewards and encourages agencies to spend all the funds recieved each year in order to recieve funding for the next year. Although the details have not yet been determined for the new pay system, it is intended to change the way workers are paid, evaluated, promoted, fired, scheduled, and treated. These rules described in the Federal Register would reverte back to the old feudal system in which federal managers are influenced by favoritism rather than serving the best interest of their agencies mission and the American people. Moreover, and most importantly, the management in place today in the civil service has spent their entire careers working under the old system which was admistering a set of rules and regulations and have no experience with any type of performance based system. In the 10 years I have worked for the federal govement, I have seen professional, hard working personnel hired from private industry leave the govement service because they were penalized for their knowledge and work ethic. Sometimes "working to hard" and trying to save the govement money by questioning expenditures for services results in retailation by those who do not share the same work habits. How will this system protect the personnel from these situations? With the new pay system, which DoD calls ?pay for performance?, the amount of a worker's salary will depend almost completely on the personal judgment of his or her manager, whether they are qualified or objective enough to make these decisions. 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. The biggest fault of this new system is that it will force workers to compete with one another for pay raises, which will destroy teamwork, increase conflict among employees, and reward short-term outcomes. All these things will be conterproductive and wiil acutually serve to work against the intent of this new system. Under the General Schedule and FWS, employee pay was clear. It was funded by Congress and could not be taken away. NSPS will take away this certainty and the lack of security that goes with it. This uncertainity will do nothing but contribute to poor performance as workers will less likely to concentrate on their jobs when worried about salary funding issues. It will also mean that abusive managers could harass employees with bad schedules or short notice with no avenue of appeal or way to seek a fair and professional treatment. Certaintly there is room for improvement in the structureof the DOD civilian workforce. Creating a lot of anxiety for that same workforce by inplementing a pay system that has not been thought through enough to present any details or to determine how the system will be implemented is not the way to bring about the efficiencies and changes that DOD envisions. Sincerely,