| Comment Number: | EM-023251 |
| Received: | 3/16/2005 2:14:31 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: I write 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 for 28 years. I am angry that these proposals are going to treat the employees who help defend our country as the enemy. Most DoD employees work hard and are committed. I believe that mistreating the employees will hurt the agency?s mission. This system will change the way workers are paid, evaluated, promoted, fired, scheduled, and treated. These rules will create a system in which federal managers are influenced by favoritism rather than a fair and partial system, which already has some of the same problems. The main difference between the current system and the NSPS is that the employees being treated unfairly now, have an avenue under which they can grieve an issue, or file an EEO complaint. Under the NSPS, even employees falling under the ADA are at risk. 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? The area in which I work, all of our management is in another city and state. No one under this business line has received a bonus or award since going to work for them four years ago. Their reason, they cannot verify the work we do. We copy them on every piece of work done, and send weekly work reports to the first line supervisor. One employee was given an exceeding on her annual appraisal, but did not receive an award, while the employees physically located with the manangement team received awards, even the ones who received highly satisfactory. ?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. Unfortunately, this type of treatment is already going on within the Defense Finance and Accounting Service. There is a manager within my business line that only promotes and rewards the females under 40. This has been noted and grieved, yet nothing is done about this GS-14 manager, who was only promoted to that grade after filing a race discrimination suit. 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. In this regard, it will be the same as the "Friend of the Supervisor" category. This is just another way to get rid of employees the supervisor doesn't want in their area. To be able to deploy a civilian employee to a war zone is wrong. To be able to force an employee to be deployed anywhere, and if that employee refuses, discipline them, should be considered an unfair labor practice. America is at war. We are fighting for democracy abroad. But this pay system is an attack on workers? basic rights. Furthermore, NSPS will divert the attention of defense workers from the military member's welfare as well as the wefare of the dependents of the member, 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. Sincerely,