Comment Number: EM-019850
Received: 3/11/2005 1:34:36 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: 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 nearly 27 years. I am angry that these proposals seem to treat the employees who help defend our country as the enemy. IT IS A SHAME THAT DoD APPEARS TO BE USING THE TERRORIST ATTACK ON THE WORLD TRADE CENTER AS A MEANS TO PROMOTE THE DESTRUCTION OF THE CURRENT PERSONNEL SYSTEM. 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 are influenced by favoritism rather than serving the civil concerns of the American people. The Government's own review of "Pay for Performance" systems states that after more than 20 years of study, they remain a "work-in-progress" MY AGENCY HAS ABSOLUTELY NO IDEA OF HOW TO MEASURE EMPLOYEE PERFORMANCE and probably never will. Supervisors rarely spend no more time on employee performance measurement than is needed to do the paperwork. During my last performance review, my supervisor prepared the documents while I was sitting in their office. That took about 5 minutes of their time. It is all show and no go. It is a system that lacks substance. I have never had a supervisor who could explain their "plan" to gather the information needed to evaluate employee performance. And you want to give them more responsibility? They can't handle the responsibility they currently have. 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. Creativity and risk taking for improvement will be smothered as employees will be wary of not "toeing the party line" and risking getting a raise. 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 will be no impartial appeal system to assure that everyone is treated fairly. Just look at surveys of employees now...FAVORITISM by supervisors ranks among the highest of complaints. A few years ago, I had the opportunity to review citations for performance awards given out by management. They wouldn't give me copies, I had to request copies through the Freedom of Information Act. Still, the copies had redacted information such as the recipient's name and even pronouns such as "he", "her", "his" were obscured. WHAT ARE THEY TRYING TO HIDE? These awards were given to "recognize" those employees as "superior" performers, it is hypocritical and highly suspicious to later remove this information from the award citation. What I did notice by comparing the award citation with the employee performance standards was that nearly all of these awards described nothing more than the "fully successful" level of performance. Obviously the awards were given to the supervisor's "favorite" employees and not to those who truly excelled in performance of their duties. 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. There is nothing wrong with the current system other than how it is "managed" by those in power. Sincerely,