| Comment Number: | EM-019864 |
| Received: | 3/15/2005 11:03:59 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 15, 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 almost 30 years. I am angry 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 mistreating the employees will hurt the agency?s mission. 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. 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. 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. There are many weaknesses with this system. Among them, and an issue that cannot be explained to me, is that each activity receives an annual budget for salaries. And given the cut backs which have become continual, that means that there will be fewer dollars for payroll. Since the activity cannot exceed its payroll, I believe this puts us in a situation where only a favored few within an activity will receive pay increases. This will be, and a person would have to be very foolish to believe otherwise, reserved for the highest ranked and \ or most visible employees within the activity. Further, that a supervisor would have complete authority and power to "rank" their employees on performance, and issue so subjective that civilian employees were previously put on a pass \ fail rating because supervisors could not handle an actual graded system, is totally unfair. Only the very naive would believe that this authority would not be used to intimidate or punish employees that are quite productive, but not in favor. That is not to say all supervisors are incapable of making good, production based decisions, but that there are an equally large number who would mis-use this new found power. The recourses mentioned for discriminated empoyees is purely lip service. Civil Servents already know that any objections they pose will be summarily dismissed in most cases. Unless the supervisor is completely ignorant, all but the most blatant mis-doings can be justified. A good, hard-working employee who is ranked poorly is up against the wall trying to PROVE they do their job well. And the ramifications for going "against the system" becomes even greater as the same system of people will be allowed to rate the objecting person again and again. Sincerely,