Comment Number: EM-023274
Received: 3/16/2005 6:30:30 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. I have worked for DoD for 9 years. These rules would create a system in which federal managers are influenced even more than they are today by favoritism rather than serving the civil concerns of the American people. Annual Pay Raises Under the General Schedule and FWS, employee pay was clear and for some employees the only fair way to be awarded without favoritism or neglect of many of our military leaders. It was funded by Congress and could not be taken away. However, NSPS will take away this certainty. DoD funds salaries and bonuses and distribution of this old system is bad enough but a new system without the guidelines required for performance measurement will be even worse. In the past ? as recently as just last year ? DoD did not fund its awards program and it effected me personally in a detailed assignment where my split leadership (who I worked for and who I was assigned to assist) denied having responsibility for my value. 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 are no guarantees that 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. I have worked in industry for 20 years prior to joining the government and I understand what the government is trying to do with this new pay system. However, because industry is driven on profits and that is something that performance can be measured against, it fits well with industry. But since the government is bureaucratic and built on personal egos of its leadership (not the good of the whole public as some may say), I find that this new system could be devastating. Accountability is important but before you have accountability you need to have processes in place that define DoD?s overall goals not local managers individual goals which in many cases are based on personal agendas and not the best solutions for the country. I am very proud to help in my efforts of designing the future military force in experimentation but I find it very difficult working in these personal agendas and see that already today favoritism flourishes even in the old pay system. The new system would only excel this dysfunctional atmosphere. 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. 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. Sincerely,