| Comment Number: | EM-020102 |
| Received: | 3/11/2005 4:32:16 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. While I support cutting time frames for taking performance or misconduct-based actions against employees, many of the other provisions of the NSPS trouble me. Eliminating requirements for written performance plans, one of the provisions of the NSPS, could lead to employees who are not certain about their responsibilities. Employees need to know what their managers expect of them, and should be afforded the protection of having those responsibilities in writing, so that they can be certain of what their manager's priorities are, and be certain of what their performance reviews will be based upon. Having job requirements and performance plans in writing ensures that employees with the same job title have similar work loads and responsibilities and are evaluated based on similar criteria. Eliminating written job performance plans will allow managers to have "gentlemen's agreements" with their favored employees to do less work or to avoid the less-favorable tasks that should be equitably assigned. I am also very concerned about the potential eliminatation of COLAs, within-in grade increases, quality step increases (QSI). QSIs are currently one of the only ways to reward high performers with extra pay. QSIs should remain. While within-grade increases are not handed out based on merit (i.e. they are not handed out only to the best of the best), they are dependent on satisfactory performance. The best employees get QSIs or an increase in grade, the satisfactory employees get within-grade increases on the anniversary of their current step, because they still have significant value to the federal government. An employee who receives an unsatisfactory job performance rating does not get a within grade increase on the anniversary of their current grade/step. There are many civilian employees who have reached the top step of their top possible grade (e.g. an attorney at step 10 of GS-14). Whether their work is excellent or just average/satisfactory, they cannot get a pay raise. Even if the system is changed so that salaries are not based on such rigid grade and step scales, there will still always be a maximum salaray for a certain job. Civilian employees aren't going to earn more than veteran senators or the POTUS. These long-time carrer professionals who do average or above-average work and have maxed out on whatever salary scale is in place, still deserve to have their salaray keep up with the standard of living they were afforded when they first achieved this maximum salaray level. If they feel that their real value of their salaries are decreasing despite their hard work, moral will suffer, as will the quality of the work. These seasoned, expereinced employees are important, and COLAs are needed to help keep their salaries competitive. 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. Public employees are proud to serve our country, but they are also responsible for caring for their families and personal obligations. Civilian and military employees serve their country proudly, but in different ways. When an American signs up for the armed forces, they are counceled about planning for the possibility that they will have to leave their family for an extended period. They are given counseling and training on foreign deployment dangers and pitfalls. Civilian employees are not given the same level of family-separation support, nor do they expect to bear the same family-separation burdens involuntarily. America is at war. We are fighting for democracy abroad. But these 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,