| Comment Number: | EM-023303 |
| Received: | 3/15/2005 12:51:13 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 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 12 years. I am angry that these proposals seem 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. I am very upset by NSPS. This system will change the way workers are paid, evaluated, promoted, fired, scheduled, and fairly treated. I truly believe these rules would create a system in which federal managers are influenced by favoritism rather than serving the civil concerns of the American people. And, as a taxpayer, I wonder why DOD and the Government as a whole, would be willing to spend great amounts of money on a backwards effort such as this. Wouldn't it be better to spend these large monetary and manpower resources on meeting the needs of the soldier in the field?? And helping the DOD civilian employee to have enough resources to get the soliders what they need?? I just read a story today in "Inside the Army" that stated the Abrams Tank is doing 12 times the amount of work than it was meant to do, and more funding is needed for the modification of the M1Abrams for fiscal year 2006 -- about four times the amount requested and granted in FY-05. We are facing many years of war efforts overseas and an enormous deficit. How can we justify this incessant spending on programs like the NSPS that just don't make sense?? 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. We already have many EEO actions within the current impartial system. The proposed system interjects too much subjectiveness into the process and will, undoubtedly, increase the number of disgruntled employees. There were some very good reasons the Government went with a GS pay system when it replaced Merit pay (which is similar to NSPS) many years ago --- why are we moving backwards??? 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. As a single mother, this situation would be very difficult for me and a step backward for DOD in the area of flexibility for its employees. 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,