| Comment Number: | EM-023273 |
| Received: | 3/16/2005 12:06:01 AM |
| 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. It worries me that what is posted as security reasons are not logically security reasons. It appears that it only thinly veiled as such. Most DoD employees work hard and are committed. Many federal employees are giving their all. Yet the proposal calls into question their integrity. I believe that will result in mistreatment of the employees thus hurting the OPM's mission. This system will change the way workers are paid, evaluated, promoted, fired, scheduled, and treated. These rules would create a system in which federal managers are influenced by favoritism rather than serving the civil concerns of the American people. I have witnessed favortism in small amounts. If implimented the NSPS would be a carte blanche to the will of small minded managers. Employees may feel powerless and despondent; resulting in a much less than best performance on their part. But an empowered employee wants to protect, serve, facilitate an agency's mission because they are vested in its vision for the future. 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. In the VA, where I work, some years ago our administration (I don't know if it were regional or national) took away the reward system because they thought it biased and fed into favortism. While I agree favortism occurred, the subsequent lack of incentives had a lackluster effects; results became a, "why even try." There is a better way. Consideration for the hard work; ways that nonsupervisors can nominate a fellow employee for incentive rewards, for example. But also automatic raises for years of GOOD service. One may look at it as a hybrid of incentives/performance and seniority. ?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. 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. Do you remember one of your first jobs where the boss was intolerable? Or a professor who was only concerned with weeding down student population rather than teaching? Can you imagine if that type of personality was now managing you and endlessly finding fault. "Pay for performance would be a farce." We can't deny there are mean spirited persons in this world. Do we really want to give them any more power? 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. Our nation's families are already at risk from neglect. We have an obligation to them at least as much as we do our employers. The workplace should have an understanding of this. Families are the future of our nation and not be shortchanged for the wants of the here and now. It calls for all of us to be forward thinking and planning America is at war. We are fighting for democracy abroad. But these 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. Sincerely,