| Comment Number: | EM-023317 |
| Received: | 3/16/2005 5:09:39 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 close to 4 years. I graduated from New York University at 20 years of age, and immediately went to work for the Army as a management intern. My father was a civil servant, and my sister has also worked for the federal government. All of us have been attracted to federal employment for many reasons, but primarily for the opportunity to serve our country every day with pride and honor. In addition, although more money can be made in the private sector, the government has been an attractive employer because of the rules governing civil service employment. This was a large factor in my own decision to seek federal employment and reject opportunities in the private sector. Thus, I am angry that a new personnel system has been created with virtually no employee consultation. Most DoD employees I have had the pleasure to meet work hard, work competently, and are committed to their mission. I believe that the NSPS is a solution to a problem which does not exist, with the horrors of 9/11 being used as an excuse to trample on hard-won and fair employee rights. I am very upset by NSPS. This system will change the way workers are paid, evaluated, promoted, fired, scheduled, and treated. I believe many of NSPS' concepts would be beneficial in theory; however, I am doubtful that any amount of training will overcome managers' playing favorites. I am doubtful that enough training will even be provided or funded. My own nightmare scenario is that NSPS regulations are implemented, issued to the personnel offices and each HRO is left to interpret and utilize the new rules as they see fit, with insufficient guidance from the DoD or agency Secretariats. 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. 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 proposed NSPS 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 and comply with the written word of the authorizing legislation. We need work rules that preserve fairness, serve the American people, and respect the rights of Defense Department workers. Sincerely,