| Comment Number: | EM-023008 |
| Received: | 3/16/2005 1:06:46 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 a GS-13 front line supervisor who recently left private industry to join government service and become a civilian employee. In private industry I worked with US government agencies and GOCOs responding to Request for Quotes, developing and instituting long term contracts and following-up with contract performance inquiries/actions. If one where to consider a civilian Federal government worker as a contractor and the new NSPS regulation as a contract, Federal government contracting agencies would not have allowed the release of NSPS in its present form. It does not define deliverables or requirements. Plainly said, the proposed changes the NSPS system spells out in the Federal Regulation is vague and ill defined. Some specific areas that concern me are: I disagree with pooling of locality and cost of living funds. These funds should continue to be distributed across the board. By pooling this pay as recommended by NSPS, not only will poor performers be penalized, but also staffing that works in the background (ie. office administrators, technicians, etc.) will be penalized. A better idea would be to distribute locality and cost of living funds equally and pool the present in grade step increases to be awarded to high/acceptable. From what I can read of the NSPS regulation, themethod of selecting whom and how pay is to be changed is open for interpretation. Based on recent FAA trends, one could expect the norm under NSPS system will become to award bonuses rather than increase pay. The result will be salaries to be frozen thus effecting civilian pensions in that money received through bonuses does not enter into calculation of the ?high three?, a person?s 401K stream and ultimately the Government 401K match system. In press releases NSPS says is it will not effect pensions, but present trends at the FAA indicate that it will. Being a supervisor, I have heard from several sources that supervisors will be required to rate our direct reports top to bottom. For example, if a supervisor has 20 direct reports, the supervisor will be required to rate or number their direct reports 1 to 20 even though these direct reports are classified differently, perform different jobs, have differing experience etc. If the employee does not agree with their appraisal, their right to appeal is through the supervisor?s supervisor who in most cases will uphold the appraisal. What is going to happen is there will not be an appeal through the supervisor?s supervisor but the employee will file a discrimination claim through EEO which will swamp the EEO system with new cases. Rating/numbering top to bottom is not even done in private industry so why do it here? Finally, the NSPS system is suppose to address national security issues. If so, does it make sense to institute NSPS on such a large scale in a department, the Department of Army, during a major military campaign when no one can be assured NSPS won?t be detrimental to the civilian workforce and ultimately the Army?s ability to meet the Solder?s requirements in the field. NSPS will probably get rid of poor performers, but it will also cause the loss of many acceptable performers that form the backbone of the civilian workforce. Overall, my recommendation is to tweak the present GS system by eliminating step increases within Grades or better define the NSPS system and allow another 30 day comment period before releasing it for implementation. Sincerely,