| Comment Number: | EM-022896 |
| Received: | 3/16/2005 6:17:26 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: II am writing to express my outrage at the proposed NSPS regulations. You have gone way beyond what Congress intended and what Congress authorized you to do. Congress required you to develop the new personnel system in collaboration with DOD employees' unions through a very specific process spelled out in the law. Instead, you have kept the details necessary for there to be any meaningful collaboration on the actual system from the unions, the employees and the public. You say that you will reveal those details in later implementing issuances through a process that will involve the unions far less than Congress intended when it called for the process it put in Section 9902(f) and (m) in the law. Congress intended that collective bargaining be retained. What you have proposed is an insulting mockery that would not be called "collective bargaining" by any reasonable and honest person. You have flouted Congressional intent and gone far beyond your authority. You are proposing a pay-for-performance and market-based pay system without providing enough details to comment or collaborate. You have distorted the research on pay-for-performance, which has never been shown to improve organizational performance. While it may be true that many private companies use pay-for-performance, almost none of them use it for employees across the board. Some use it just for managers, some for sales staff, etc. Without a lot more money than DOD plans to invest, or Congress would ever give you, pay-for-performance does more harm than good. We cannot afford to pit employee against employee in this Department we count on for protecting our nation. Instead of proposing a modern, credible and understandable system, NSPS as proposed, is positively 19th century, complex, and so subject to abuse and error as to be totally lacking in credibility. An employee who gets an outstanding rating might get a little or a lot based on so many things outside of his or her control as to make it laughable to think this will be a clear and understandable performance-based system. Don't do it! Rethink what you have proposed and make a serious effort to reach agreement during the meet and confer period. Thank you Sincerely,