| Comment Number: | EM-019853 |
| Received: | 3/14/2005 1:38:29 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 14, 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 DoD for 15 years. I am very angry that these proposals seem to treat the employees who help defend our country as the enemy. Most DoD employees work hard and are very committed to supporting our service men and women. They take pride in ensuring the best for the best. I believe that NSPS 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? DoD has been concerned about employee retention. With NSPS, I foresee many qualified employees leaving Federal service for employment with private industry where salaries are higher. ?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. In my 15 years of Federal service, I have had 15 supervisors. I was initially hired as an intern, spending three years rotating through various jobs, learning all aspects of my chosen profession. With each rotation, I had a new supersor. When I completed my internship and was finally assigned to a permanent position, I continued to have new supervisors just about every year, due either to their promotion or to their reassignment. Where I work, there seems to be an almost continuous shuffling of supervisors and employees. How is an employee supposed to be fairly evaluated when he is continually being reassigned "to meet the needs of the mission" or when his supervisor, who knows his work ethic and abilities, is constantly being changed for someone who doesn't even know his name (I once worked for someone who after a year didn't know how to spell my name correctly!) One advantage to working for the Federal Government was that, as a female, I was guaranteed the same pay as my male counterparts. During my time with DoD, I have had two supervisors who believed that women did not belong in the workplace. One individual insured that every man under his supervision was promoted before any of the women in his section were ever considered. In his words, the men needed the higher salaries because they had families to support. Under NSPS, this same individual would not just be deciding my promotion potential but would also be the one determining if I should receive a pay increase. NSPS will force workers to compete with one another for pay raises, which will destroy teamwork, increase conflict among employees, and reward short-term outcomes. Why should I help train someone new and share my hardwon experience when I shall now have to compete for my pay 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. 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,