| Comment Number: | EM-023234 |
| Received: | 3/15/2005 3:24:22 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 15, 2005 DoD NSPS Comments , DoD NSPS Comments: I an writing to express my concerns about changes to work rules in the Department of Defense (DoD). The proposed regulations, known as the National Security Personnel System (NSPS), were printed in the Federal Register on February 14, 2005. This message will be sent to both DoD and my representatives in Congress. I have worked for DoD and specifically Army for 27 years. I am a second level supervisor. I believe that this system will treat me and my employees who help defend our country unfairly. I believe that this personnel system will not only hurt employees but will also hurt the agency?s mission. I am very upset by NSPS. This system will change the way workers are paid, evaluated, promoted, fired, scheduled, and treated. It is far easier to only be responsible for yourself and do a good job than it is to be responsible for the achievements of others. Most supervisors will likely end up in the same pay band as their employees and before long will likely earn the same or less than subordinates. So, since there will be no real financial incentive to become a supervisor and take over that level of responsibility ( and all the hassle of doing this type of performance evaluation), you will only get the folks applying for supervisory work who like power. That in turn will cause favoritism in preformance rewards. I can also tell you from experience that agencies will be short of funds to reward employees and it will become an issue of dividing what funds there are by some kind of quota. That is NOT motivating to employees!! The SESs will make big bonuses and the rest of us will see nothing or very little. A good boss does not take credit for the good things their folks do-- they only take the heat when things go wrong. That is how you build a high performance team. This system will not reward that. Annual Pay Raises 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? ?Friend of the Supervisor? Pay System With the new patronage pay system, which DoD calls ?pay for performance,? the amount of a worker's salary will depend almost completely on the personal judgment of his or her manager. This system will force workers to compete with one another for pay raises, which will destroy teamwork, increase conflict among employees, and reward short-term outcomes. 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. Furthermore, there will be no impartial appeal system to assure that everyone is treated fairly. And, from my perspective, a supervisor like me will get nothing done but try to keep the peace and be fair. In this environment, building a really good team will be very difficult. Schedules and Overtime 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. Civilian Deployment Federal employees could be assigned anywhere in the world, even into a war zone, with little or no notice. I am proud to serve my country but I am also responsible for caring for my family and my personal obligations at home. We signed up for a civilian job. We did not enlist in the military. Today?s volunteer system works well. I did not sign up for this kind of deployment duty and to suddenly impose it on me in my 50s without my consent or any discussion is unethical and very poor communication. America is at war. We are fighting for democracy abroad. But the regulations are an attack on workers? basic rights. Furthermore, NSPS will divert the attention of defense workers from the soldiers? welfare to protecting themselves from abuse on the job. I urge you to force DoD to rethink this proposal. We need work rules that preserve fairness, serve the American people, and respect the rights of Defense Department workers. And finally, I think the way this has been handled is poor. We are given a short window to comment on this regulation and the detail is not there yet. As they say, 'the devil is in the detail'. My staff and I are now undergoing an A76 competitive sourcing study. How our rights will change is unknown. This is important because we will be under NSPS by the time the A76 decision is announced. I have personally written to the NSPS website and asked about such specifics. The answer is, 'we don't know yet'. Well, if no one knows what the final rules will be, how can we be implementing this system as soon as July? There are lots of folks who are now dealing with competitive sourcing and many more who will be soon. I believe more detail is known, but it is being withheld so that there is less controversy now during the public comment phase. That is a serious injustice to us as Federal employees. I have been in DOD for too long not to know how things work. Once we get the system in place, then it will be harder to complain and the answer will be that 'well, you had your chance to comment'. So, in summary, I am not happy with the proposed NSPS and I think it is very poor that we do not have complete information to comment on. Further, I have some serious concerns that no one can answer. What incentive is there to be a GOOD supervisor? What will the pay bands look like? What assurance is there that the awards program will be funded and what safe guards are there that all the money does not just go to the highest paid employees like 15s and SESs? Exactly how will NSPS change RIF and other processes that affect more employees every day? I appreciate this chance to comment and I hope that you will take some of these thoughts into consideration. Sincerely,