| Comment Number: | EM-019950 |
| Received: | 3/15/2005 7:31:19 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). I have worked for DoD for over 25 years and have seen many changes. NSPS is the worse thus far. I am deeply concerned that the DoD hierarchy believes it's acceptable to treat the employees who help defend our country as the enemy. It not only sends a negative message to the employees as well as the managers/supervisors but to the public as well. If this regulation is implemented without another serious look from Congress and changes made that are fair and equitable to all, DoD will have a difficult time hiring quality personnel in the future. Most DoD employees work hard and are committed to the mission and trustworthy. I believe that NSPS will cause low morale, incite workplace violence, distrust among the workers and ultimately it 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 fairness. Annual Pay Raises Under the General Schedule and FWS, employee pay is funded by Congress and can't be taken away. However, NSPS will take away this certainty. Salaries and bonuses will be funded by DoD. DoD has a history of not funding its awards program. Given the agency?s miserable record on this issue, what guarantee will employees have 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 trust, 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 who have conflicts will be 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 by giving them 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. When all is said and done, who will monitor the supervisors and make them accountable for their actions? Who will be the employees' champion? 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,