| Comment Number: | EM-017676 |
| Received: | 3/14/2005 8:19:04 AM |
| 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 concerns about changes to work rules in the Department of Defense (DoD), known as the National Security Personnel System (NSPS), and printed in the Federal Register on February 14, 2005. I have worked for DoD for years, and am concerned about the implications involved. NSPS will change the way workers are paid, evaluated, promoted, fired, scheduled, and treated. These rules create a system in which federal managers are more apt to be influenced by favoritism rather than serving the civil concerns of the American people. Federal Civil Service has a majority of competent and fair supervisors and managers, however, the minority of managers that allow their personal vindictiveness and ambitions to rule their decisions, can make civil service employment difficult, even under the current system. Federal job performance standards and appraisals are notorious for their lack of real, measureable, and valid objectivity, largely due to the nature of the tasks. This has been an ongoing weakness of the performance appraisal system for decades, and despite management's best efforts, has yet to be overcome. Ratings, even under the current system, are FAR too often dependent more upon hte employee's relationship with the supervisor than on objective work measurement. With the new pay system, the amount of a worker's salary will depend almost completely on the personal judgment of his or her manager. Although my current manager is fair, and I feel that I would be treated fairly in NSPS under him, I have worked under, and am currently aware of, several supervisors and managers who allow their subjective personal inclinations, rather than objective work measurements, to determine work assignments, performance ratings, awards, and promotions. Working under them entailled a situation in which I was afraid to speak out about harassment, violations of the law, and/or workplace safety. Under NSPS, ineffective or abusive managers could more easily harass employees with bad or short notice schedule changes, or unfair performance ratings. There does not appear to be any measure of protection from this sort of abuse. Additionally, the current system has adequate measures to remove poor performers or undesirable employees, however, a great majority of current managers simply neglect to follow the requirements of the system, and thereby perform their duties. While some modifications to the current system may be merited, placing the complete onus for employee evaluation and compensation onto a manager's subjective opinion will more than likely be detrimental to national security. This system will create a situation in which workers are in conflict with one another. It will force workers to compete with one another for pay raises, which will destroy teamwork, increase conflict among employees, and reward short-term self-centered 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. Furthermore, there will be no impartial appeal system to assure that everyone is treated fairly. NSPS will likely divert the attention of defense workers from the soldiers? welfare, to protecting themselves from abuse on the job. I urge DoD to rethink this proposal. We need work rules that preserve fairness, serve the American people, and respect the rights of Defense Department workers. Sincerely,