| Comment Number: | EM-022936 |
| Received: | 3/16/2005 3:53:07 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: Subpart A: I believe that the idea of implementing a whole new Personnel and pay system accross the board at this time in history is ludicrous and a huge waste of taxpayer monies. Especially with the same people in place trying to implement a new more expansive system than they have now, and have taken it to the point of extinction because of ineffectual and unaccountable directorate as now seen. The monies to implement this system by OMB's own studies will mount well into the billions of taxpayer dollars. We could wisely use these monies in other areas and modify the current system to effect the necessary changes to make it more efficient and less time consuming for hiring and firing. The Secretary completely buffaloed the congress into believing that this system is not effective and too cumbersome to work with when he all along had the power and ability to make the necessary changes to the current system without having to enact a new law to cover the ineffective management of the current system while retaining the same people who made the current system ineffective to implement the new system. And I might add, with less accountability than the current system demands. Subpart B: Replacing the current GS and WG systems with a pay banding, pay for performance program will surely shift the focus of employees. From being the dedicated loyal employees that we currently employ that have the mission and country as top priorities to a system where it will be everyone for themselves, and also a system of spoils where an employee will have to pledge his allegiance to an individual supervisor rather than the mission. Thereby having the complete opposite effect that is desired. Subpart C: The cost of implementation of the NSPS will be more than we pay out in raises to our federal workers now, and to not let employees know up front before this comment period is over that their whole livelihoods, to include their retirement pay will be changed is unconscionable and underhanded management. Subpart D: Not setting mandated rating periods and communication dates for employees and management is nuts, as they are not adhered to now with mandated dates. Then to not allow for the real ability to challenge an unfair rating will surely destroy the morale of the workforce. Any internal review completely chosen by the secretary is never going to be construed as fair and impartial. Again having the exact opposite effect desired or at least stated by the Secretary. Subpart G: Creating a list of MROs sometime in the future again is going to serve as a deterrent to bringing in new and better tallent to the workforce. Then making them solely up to the secretary to mitigate will serve as a stumbling block to effective and timely review. Unless he decides to just use a rubber stamp to reject all appeals, because there is no way one person can do the work required on each case to review. Subpart I: Limiting the roles of Unions in the Federal workforce will ultimately destroy any faith in the Government that employees have held. When you limit bargaining, and dictate that employees may not have the representative of their choosing or possibly any representation at all during investigations. The trust in the system to be fair and equitable will be thrown right out the window. Thereby again having the exact opposite of the desired outcome of the rule changes. SUMMARY: In total, the NSPS must be reaccomplished as proscribed in the law effectuating the creation of this monster. By sitting down with the affected employees representatives to develop a workable fair and just personnel and pay system that is fully laid out for all to see before it is published. If this is done properly, it will have the full buy-in of all representatives and the backing to impliment and use the NSPS. What we have created here is a system that will destroy morale and cost the American taxpayers billions in unnecessary expense and is doomed to fail. You cannot give one person the ability to affect this many lives without the common decency afforded even Wall-Mart employees and expect that without due process laws that you will create a system that will attract the best and brightest to the ranks of Federal employment. Please reconsider accomplishing the creation of a new system with the help of representatives that the law demanded. Or you may also choose the option that was always available without writing a new law, and revamp the current system that would only need minor adjustments to it to accomplish all the needed goals of the new system. And be more cost efficient for the American taxpayer at a time when there is precious little resources to accomplish our missions now. Sincerely,