| Comment Number: | OL-10500259 |
| Received: | 2/15/2005 10:44:08 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:
The premise for the new National Security Personnel System in DoD is false. There is no problem with the system other than it has been subverted. The other issue is the current merit system could cause harm to inept and corrupt managers if merit principles were applied and whistleblower could do their job as public serrvants and protect the taxpayer and soldiers' interests ahead of the administrations ineptitude and corruption. The new regulations states: "Although the current Federal personnel management system is based on important core principles, those principles are operationalized in an inflexible, one-size-fits-all system of defining work, hiring staff, managing people, assessing and rewarding performance, and advancing personnel. These inherent weaknesses make support of DoD's mission complex, costly, and ultimately, risky. Currently, pay and the movement of personnel are pegged to outdated, narrowly defined work definitions, hiring processes are cumbersome, high performers and low performers are paid alike, and the labor system encourages a dispute-oriented, adversarial relationship between management and labor. These systemic inefficiencies detract from the potential effectiveness of the total force." No one in DoD is concerned with "effectiveness of the total force". The exiating merit system are not expedient nor expeditious to tear down the public service in favor of corruption and ineptitude in the guise of transformation. This statement is not true. The core (Merit) principles have not been operationalized, nor applied to the existing DoD Civilian Personnel System. The “one-size-fits–all” system is not used, it is circumvented and merit is denied. This is especially evident in the acquisition workforce. Experienced technical employees are prevented from doing their job to assure products acquired are worth the taxpayers’ limited funds. Those who dare to say “the developed system is bad and the tests are failed” are denied any protection under the existing core (Merit) principles designed to assure public service and not “please” superiors’ at the expense of truth and the wise use of the tax resource to give the soldier in the field a fighting chance. To enforce the destruction of core (merit) principles employees already endure whistleblower retaliation, wrongful elimination of slots, and management refusal to enforce statutes against fraud (18 USC 1001), Anti Deficiency, and demanding voluntary services of contractors (31 USC 1341 and 1342). This is readily apparent in the Ballistic Missile Defense Organization where the equipment delivered does not work but is being delivered as if it met any performance standards. This is huge fraud. The problem with the current core (merit) principles is they are inconvenient to an administration which wishes to use the defense budget to transfer wealth from the taxpayers to the military industry. The current system makes it difficult to deal with civil servants who can use the core (merit) principles as protection against inept and corrupt officials who are threatened by the truth. The core (merit) principles are only too complex for those inept or corrupt who are denied their malfeasance under the core (merit) principles. Effective reform would include assertive position management, where positions are graded based on the actual work to be performed. This is not evident in the “flexibility” described for the new rules. Nothing is done to prevent fraud and waste in the NSPS, in fact the dilution of core (merit) principles makes fraud and waste a standing condition with no support for preventing the waste of the taxpayers’ resources.