Comment Number: EM-019747
Received: 3/10/2005 8:54:26 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 10, 2005 DoD NSPS Comments , DoD NSPS Comments: I am writing 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), that 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 years. I am angry that these proposals seem to treat the employees who help defend our country as the enemy. Most DoD employees work hard and are committed. I believe that mistreating the employees will hurt the agency?s mission. I am very upset by NSPS. This system will change the way workers are paid, evaluated, promoted, fired, scheduled, and treated. These rules would create a system in which federal managers would be more influenced by favoritism rather than serving the civil concerns of the American people. Annual Pay Raises 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. Salaries and bonuses are funded by DoD. In the past ? as recently as just last year ? DoD did not fund its awards program. Given the agency?s miserable record on this issue, how can employees feel confident that our salaries and bonuses will be funded in the future? ?Friend of the Supervisor? Pay System With the new patronage 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. This system will force workers to compete with one another for pay raises, which will 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. Under the GS Schedule system, there were avenues already in place to reward good performers. These avenues were called ?Quality Step Increases? [QSI]. A supervisor, who felt that an employee was performing ?above and beyond? the job requirements, could put that employee in to receive a step increase escalated in advance of the required waiting period. In the 20 years I have been with the federal government, I can not remember anyone telling me that they ever received a QSI. When I asked management why they did not utilize this method of rewarding good performers, I was told that the paperwork was too difficult, or they couldn?t convince their upper management to approve it. It was there, it just was never used. The new pay system also increases the potential for discrimination and bias. Under the GS Schedule, the amount of money an employee was to receive for a particular level or step within that level was posted for all to see, with the only variation being the locality premium offered depending upon where you lived and worked. Under this new system, there will be no way to compare your salary or increase with others in your similar situation, thus permitting the potential for unfair treatment by management, allowing them to reward friends, while also permitting them to discriminate against those that management did not like or wanted to force out. This system will also create a situation in which workers could be 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. In the agency that I have worked for the past 8 years, I have seen management abuse the award policy, rewarding friends with large awards, while ignoring those who truly deserved to be rewarding for their efforts above and beyond. An employee will be placed in a position to blindly support and obey his/her supervisor, for fear of what the alternative would be, an adverse impact on their increase or no increase at all. In the wake of the Darleen Druyun and Michael Sears incidents, and applying these new rules being considered by the new personnel system, would anyone be willing to jeopardize their future pay increase, by questioning the actions or policies of their superiors, even if they new the decision was wrong or violated the law? Under the current GS Schedule, I am assured of what my next increase would be, and this would not be overly influenced should I make a decision based upon my understanding of the law or federal acquisition regulation, rather than how this decision would be received by my supervisor, or disagreed with that supervisors request or wished. Schedules and Overtime 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. Civilian Deployment 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. Today?s volunteer system works well. 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. Sincerely,