| Comment Number: | OL-10500184 |
| Received: | 2/15/2005 2:15:22 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:
15 Feb 2005 February 10, 2005 Fact sheet The attached responses and comments were discussed between several civilians in A48, responses were not aimed at any one in particular, just observations in current daily operations and concerns for the civilians currently in A4. 1. “Hiring is too slow, and cumbersome adversely affect our ability to attract and retain high quality talent.” a. Comment I: Moving all of the civilian personnel support from each base and centralization has slowed the process. b. Comment II: Appears to me the problem isn’t the processes as much as a lack of understanding by users. 2. “Simplified pay banding structure, allowing flexibility in assigning work.” a. Comment I: Who understands “pay banding structure”, people are being shoved into a pay system no body understands or how it works. b. Comment II: Labor could be structured where those doing a higher level of work could be getting paid less. Could decisions result in a reduction of pay and therefore negative retirement impact? 3. “Pay increases based on performance, rather than longevity.” a. Comment I: This sounds good if everyone was on the up and up, friendship and buddy system will play a big part in this pay system. Don’t say it will not happen, but it goes on now! b. Comment II: Who determines this? Will those already progressing toward the next step increase then lose that time accrued and the corresponding step pay increase? 4. “A performance management system that requires supervisors to set clear expectations (linked to DoD’s goals and objectives) and employees to be accountable.” a. Comment I: Most military supervisors don’t know or even want to know what most civilians do; they are only here for a short period of time. Supervisors at HQ AMC change every 18 months and in some offices they change every year or quicker. b. Comment II: Most military are temporary employees at best (rotate), so just how intense can the training be and how knowledgeable can they become. 5. “Streamline and more responsive hiring processes.” a. Comment I: Lack of civilian personnel office support has had an impact this process from the beginning. Current process has opened the door for military (officers) to come back into the civil service community as upper management over and above civilians already in the system. It is much easier for an external civil service person to get hired into a position than an internal civil service person. 6. “More efficient, faster procedures for addressing disciplinary and performance problems, while protecting employee due process rights.” a. Comment I: So now if you have a short term supervisors, they will have more of a long term impact on a civilian’s career. b. Comment II: It is my understanding the arbitration process guaranteed by the current Collective Bargaining Agreement (CBA) will be imperiled, as with the elimination of the ADR panel for grievances. 7. “Whistle- blower protection” a. Comment I: Sounds great, but even if you turn in a complaint about a supervisor, the first person the complaint comes back to is the supervisor you are complaining about in the first place. This makes the situation even worse, now the supervisors have the power to impact your future pay forever. 8. “ Rules against prohibited personnel practices” a. Comment I: Will this stop the hiring of relatives and current/past supervisors. 9. “Simplified structure replaces General Schedule system” a. Comment I: Current system protects individuals from pay discrimination. New system will encourage pay favoritism to friends and buddies 10. “Positions grouped in broad career groups and pay schedules bases on nature of work, mission, and career patterns, and competencies” a. Comment I: This assumes your new supervisor knows and understands the civilian position. (Short term supervisor). 11. “Lengthy, detailed job descriptions no longer needed” a. Comment I: A job description tells each new supervisor what the employee actually does, without detailed job descriptions, new supervisors do not know what each individual’s job actually is. b. Comment II: If we stuck to the job descriptions we currently hired on with, the organization wouldn’t get a large part of the workload done that they request. We currently must perform ill defined work, poorly defined and little understood. 12. “Movement through pay band based primarily on performance, contribution” a. Comment I: This promotes friendship and buddy system to the ultimate high. b. Comment II: As determined by those often times unqualified/unconcerned with determining the actual requirements. ADDITIONAL COMMENT: It seems to me the system is being introduced prior to meaningful and thoughtful review and input by all parties. A lot More dialogue between union representatives and management is needed before initiating this system. Could a congressionally mandated activation date be the reason for rushing into this less than visible and poorly detailed system that will ultimately affect many dedicated employees, quite possibly in a negative way?