Comment Number: EM-022917
Received: 3/16/2005 5:01:34 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:

Mr. Bunn, Continuing Section 9901.407 Are manager's going to be given time to manage their people versus their now focus on being a working manager getting credit only for the tangible outputs of reports or project completions that their bosses want. This is going to take training and your $158 million to train everyone isn't enough if it is ever budget and approved. > -----Original Message----- > From > Sent: Wednesday, March 16, 2005 4:44 PM > To: 'nspscomments@cpms.osd.mil' > Cc: > Subject: Comments on Proposed NSPS Regulations--RIN > 3206-AK76/0790-AH82 > > Mr. Bunn, > > The DOD proposed NSPS has already had and in the future will continue to > have a demoralizing effect on the workforce. Some representative of DoD > reported that 1000's of NSPS commenters are anonymous. Why? Because they > are afraid and believe me they have something to fear under this system. > You have basically decided to cut out meaningful input from your workers by > diminishing their protections and you might wonder why you get anonymous > responses to something like this. Using the fear, you suggest because of > terrorism our workplace needs to become a national security issue. All the > while you DoD puts forth an NSPS that will operate basically by keeping > employees fearful of what management might do to them. > > Pay: Congress and the President in the past worked out the federal > salaries. However, NSPS will take that away. Salaries and bonuses are to > be a part of DoD's budget. 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? > > Section 9901.313 > for compatibility you say nothing but at a minimum you have to allow for > step increases and rates of promotion. Here and later in 9901.3_ _ I don't > see where there is any commitment to a yearly evaluation for adjustment of > pay bands. It is discretionally. So how do we not loose out as employees on > what would have been the yearly pay raise portion that was not locality > pay. We should get factored in for comparability anything that the military > gets for an annual raise plus all that you indicated for step increases and > rates of promotion. > > Section 9901.342 > Since union full time positions do not get a rating under this system they > should get the average increase or raise of those at their grade or band > where they are permanently assigned. > > DoD will determine when there will be an increase in basic pay. Will there > ever be one. I DoD contemplating more than annual? I think not. Are they > contemplating less than annual? Maybe it will cut costs and pay people > less. > > Section 9901.401 > If DoD's strategic plan is to do more for less then NSPS will help. DoD > doesn't have to do yearly raises (its their discretion) and they don't have > to do yearly local market adjustments (its their discretion) and they don't > have to use experts at Dept of Labor or elsewhere to determine the amounts > they pay they do so that themselves. They certainly should be able to reach > a strategic goal of more for less. However, how are they going to check the > costs of contractors? Ban any dealings with contractors that have unions as > there may be a national security issue? Will that do it? In short I object > to this control by DoD and there should be mandatory yearly evaluations for > pay raises and market supplements and an already existing department of > government should calculate the amounts they should be. > > Section 9901.405 > Generally once a year performance reviews proposed in NSPS falls in line > with discretionary timing of raises in NSPS. I object to this as it seems > to say no performance appraisal- no raise. If you are out of sequence it > may be awhile before you ever do get consideration for a raise. DoD can't > make its management get performance appraisals done yearly now, granted > there is reason for a few exceptions. This is wrong what has DoD done about > it. The focus here should be on management doing its job. > > > > > > >