| Comment Number: | EM-019754 |
| Received: | 3/10/2005 10:42:02 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 10, 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 years. I believe the NSPS will cause many DoD employees, who have helped defend our country, to be treated as an enemy. Most DoD employees work hard and are committed. I believe the NSPS will lead to mistreating employees and will ultimately hurt the DoD?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. I believe the NSPS will allow an environment where abuse of the personnel system will become prevalent and fair treatment of the worker will become an after-thought - not the primary goal of the system. 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 to be funded by DoD. In the past ? as recently as just last year ? DoD did not fund its awards programs very well. Given the agency?s miserable record on this issue, how can employees feel confident that 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. The system will even lead to the loss of pay for some due to arbitrary methods of evaluating work performance. After all, there is no approved and published process for these evaluations that are available to assure fair worker treatment and protection. 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. Schedules and Overtime NSPS will allow managers to schedule employees to work without sufficient advance notice of schedule changes. It will lead to abusive managers harassing out-of-favor employees with bad schedules possibly with 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. We signed up for a civilian job. We did not enlist in the military. Today?s volunteer system works well. I served my country when I was called on 37 years ago. I continue to serve with pride today. I should not be abused because some DoD bureaucrats have determined the existing personnel system was a burden to them. America is at war on multiple fronts. On the one front we are at war with terrorists. On another, we seem to be at war with the leadership of the DoD. We are fighting for democracy abroad. But the regulations of the NSPS 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. The Civil Service has stood for decades to serve the needs of America. Throughout that time of service there have been many battles fought in the courts and in Congress to assure fair treatment of those America depends on to serve the public interest. The results of those battles are the Merit Protection System and the rights and protections guaranteed by the Federal Civil Service personnel system. Do we, the American Civil Servants, need to re-fight those battles to re-attain the victories over abuse and mistreatment of the DoD workforce? I believe the NSPS will make a mockery of the past battles fought to attain fair treatment for all workers. Congress ought to look more closely at the proposed DoD NSPS. Lawmakers should consider legislation that sets broad parameters for performance criteria, an appeals process that preserves civil service neutrality and union involvement. These changes are potentially too political to be left to the managers directly involved. I therefore 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,