| Comment Number: | EM-019833 |
| Received: | 3/11/2005 5:49:38 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 11, 2005 DoD NSPS Comments , DoD NSPS Comments: 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 31 years. In those 31 years, I have worked at two different bases and in many different organizations at many different levels. My experience has been that most DoD employees are loyal, hard-working individuals committed to the mission. I do not believe that NSPS as currently proposed will render the desired results. While our current system may not be perfect, it provides objectivity absent in the proposed NSPS. Managerial Influence: Supervisors will wield enormous control over employees--everything from pay and awards to assignment of work and even deployment. I fear NSPS will foster a decision-making environment based on favoritism rather than fairness. It will create competition among workers rather than fostering a spirit of team play. And, I fear it will ultimately eradicate any openness or innovation simply because employees will have little or no recourse when a supervisor fails to appreciate or capitalize on differing ideas or viewpoints. Annual Pay Raises & Awards At one time, there was a lot to be said for the security and benefits of a government job. Today, there is less of a gap in benefits, but there is still some level of security--annual pay raises and longevity rights. Without either, how does the government expect to attract and retain good people? Pay banding is ill-defined. Roles and responsibilities are unclear. NSPS does not provide the necessary foundation for managers and supervisors to be able to objectively determine any better distribution of pay raises and awards than the current system. "Pay for performance" cannot succeed without objective performance measures. The amount of a worker's salary or award 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. 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. 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 and do not have the same benefits of the military. If that's a condition of employment, why wouldn't it be a military position? I believe that NSPS, as currently written, will only escalate DoD issues. I urge you to rethink this proposal. If you want more soldiers, increase the military endstrength. If you want dedicated civil servants, DoD will be far better served by work rules that preserve fairness, serve the American people, and respect the rights of Defense Department workers. Our system is far from perfect. But, it has served us well for 50 years. Perhaps we should take the lessons learned from those years and fix only what is broken. Sincerely,