| Comment Number: | EM-019748 |
| Received: | 3/10/2005 8:31:33 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), 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 the DoD for 27 years both on Active Duty and as a DoD civilian. I am upset 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 if implemented as is, the new NSPS system will destroy employees trust in their fellow workers and our government representatives and will hurt the agency?s mission. 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 are 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? The cost of everything is going up every day and with more and more responsibility being transferred from the Military to the Civilian workforce compensation in regards to experience and performance should be maintained. ?Friend of the Supervisor? Pay System Appraisals as written today are written on such broad terms that they can be interpreted to mean anything. Unless a meaningful evaluation system is put in place first, tested and refined before a new pay system is implemented abuses and favoritism will abound because they will be almost impossible to challenge due to their vagueness, vanilla tones and lack of measurable standards. 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. 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 needs to be an impartial appeal system to assure that everyone is treated fairly. When it comes to pay there is no room for perceived unfairness, bias, favoritism or personal friendships to come into play. 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 or short notice schedules without adequate justification. Only those persons hired into positions that are coded as ?Mission Essential? should be made to accept involuntary short notice schedule changes and then a system should be in place to compensate them accordingly when these instances occur. Civilian Deployment Federal employees could be assigned anywhere in the world, even into a war zone, with little or no notice. I served my country for 26 years in the USAF and never stayed anywhere long enough to purchase a home. Now that I have settled down, I have personal responsibilities and obligations to my family that now take priority. I signed up for a civilian position I did not re-enlist in the active duty military. Today?s volunteer system works well, I have no problem deploying to a non-war zone. Unless an employee is hired with the understanding that they could be involuntarily deployed to a war zone, the current system should be left in place. I think everyone agrees that changes need to be made in some areas of the current system and we the workers know best what those issues are. Congress should work with Civil Servants directly through surveys and then low-level working groups to seek solutions to problems perceived by the average employee to make the current system better instead of trying to dismantle it totally. A complete overhaul of the system is just not the right answer. We should be able to work together to fix what is broke and preserve what works. 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. Unless you develop a solid foundation that supports any proposed changes, the system will crumble, missions will fail and some troops may needlessly die as a result. It will then be a costly repair to regain the trust, teamwork, respect and confidence in both our fellow workers and government representatives. I urge you to go back to square one and do this right before any new system is implemented. Consequences must be weighed and should not be made based on dollars and cents. Sincerely,