| Comment Number: | EM-022886 |
| Received: | 3/16/2005 9:41:57 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 16, 2005 DoD NSPS Comments , DoD NSPS Comments: The National Security Personnel System new personnel rules will eliminate the General Schedule and FWS, allow bad managers to abuse and intimidate workers, and make our valuable years of committed service worth virtually nothing in the event of a layoff. The trust of Americans has been broken with the new pay band system. In fashioning a new pay system for federal employees, Congress should not move from listening to the meeting on the NSPS personnel system changes in the Department of the Defense. The Pentagon has promised that the NSPS will reward employees based on their job performance, and replaced them with a broad salary range, which is not true. Under the new system, rolled out last year, federal executives are no longer guaranteed an annual pay raise, as was the custom. Now, raises are supposed to be determined through performance evaluation systems, which must be certified by the Office of Personnel Management. Our livelihoods, health rights and civil rights are being taken away as American citizens. It?s bad enough when $50 billions from Social Security since the start of the war in Iraq which is immoral. In plain English it is being said that to take what we get and shut up don?t say a word. I am an American citizen that does not wish to be deployed without my knowing that I am going to have to serve involuntarily somewhere else in the world, I have a family, and I don?t believe that congress should ignore all facts. Decrease my Standard of Living Funding: 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? In the Federal Aviation Administration, many employees have not had a pay increase in two years because the pay schedule did not increase. While the GS system went up by over 7% in the last two years, they got no increase. Pay: With the new pay system, which DoD calls ?pay for performance,? the amount of a worker's salary and pay increase will depend almost completely on the judgment of our managers. Furthermore, the managers above our supervisors can change ratings if they wish. 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. If there is a problem, you won?t be given a fair appeal process to challenge the performance and pay decisions. Workplace violence incidents take many forms, threatening people or property, throwing objects, stalking, physical screaming, yelling, physical attacks, fist fights, use or threatened use of weapons and most extreme act of violence is homicide. An employee will not notice anything until it is too late to inform another coworker or manager. DCMA is no different from other workplaces. Take Away our Job Security Reductions in Force ( RIF): The new rules state that if RIFs occur, the decision of whether to keep an employee will depend first on his/her performance appraisals, which are issued by supervisors. Those employees with the best ratings will be kept. Those with lesser ratings will be let go. Only in the case of a tie between employees will a worker?s seniority be considered. Before NSPS, your years of dedication to DoD counted a lot in the event of a RIF. Civilian Deployment: Federal employees could be assigned anywhere in the world, even into a war zone, with little or no notice. This will make it difficult for working parents who care for a family and have personal obligations at home. Is it too much to ask that I be guaranteed sufficient notice to plan for such assignments? Are all civilians going to become just like the military? Work Rules, Schedules, and Overtime Rotation: NSPS will weaken unions and the rights gained through union contracts, such as flex days, advance notice of work schedules, and overtime rotations. If an employee is disciplined by a supervisor, there will be very little chance of overturning the punishment. 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 Two people can be doing the same identical job, one gets a raise, and the other one doesn?t this creates a conflict between workers. Job interviews are at stake, the same thing can happen because a manager doesn?t like you. Protection should be given for the younger generation to attract them to a safe working environment, where they know that they will get paid fair wages and fairly treated. The reason things are never told is because of retaliation This agency already leaves a lot to be desired because of the managers, bias, racism, and prejudice, non promotions for the same jobs across the board are higher than others are. NSPS is like the Trojan horse. Someday the younger generation will become older. This is a major concern for our representatives and us. We need representatives with open minds. The NSPS will require degrees when a lot of these jobs don?t require degrees. Performance Appraisals: Another change occurs during the performance appraisal review. Our behavior can be taken into consideration. That means that if you had an ?issue? with our supervisor (legitimate or not) at the beginning of the year, she /he could (and is encouraged to) openly consider that instance during the performance appraisal review. Add to that, the fact that there are not currently any appeal steps built in to appeal this inclusion. Some managers will feel this is an opportunity to dismiss employees that they personally don?t like and federal executives, meanwhile, say they have not been adequately informed of how the pay raise process works, and feel they have been left out of the loop. Concerns about the new pay system have recently emerged at the National Aeronautics and Space Administration, providing a glimpse of the challenges involved in winning acceptance of performance-based systems. In January, about 50 percent of NASA executives received a 2.5 percent pay raise, the highest increase given. Twenty-seven percent received raises ranging from 0.5 percent to less than 2.5 percent, and 23 percent got no pay raise. In making pay decisions, the importance of the jobs held by civilians will cause conflict because the rewards will go to the administrator or the ones that are the inner circle or mostly those in the top echelon rather than applying a uniform performance criteria. This year, agencies -- such as NASA -- that have won OPM approval for their SES performance appraisal system may pay executives between $107,550 and $162,100. If an agency does not have OPM certification, the top salary is limited to $149,200. NASA officials said the agency communicated its plan for pay raises before implementing the new system. Some NASA executives, in comments similar to those of executives elsewhere, said they were not briefed in advance or told how raises would be allocated. They contended that limiting the size of pay raises to certain SES segments, regardless of performance, had lowered morale. "While we are fighting for freedom, we must see, among other things, that labor is free." Woodrow Wilson As the Defense Authorization bill moves through conference, I urge you to continue to oppose the National Security Personnel System contained in the House version of the bill. To support efforts to preserve the collective bargaining and appeals process for civilian DoD Employees, I urge you to oppose replacing the annual pay raise by Congress with a pay system which lets only supervisors, not Congress, decide whether employees should get a raise. Sincerely,