Comment Number: OL-10500714
Received: 2/18/2005 4:52:59 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:

Basically this system nearly eliminates the usefuness of unions. There is over reliance in the proposed regulation on the ability of managers to "manage". Most managers are promoted on the basis of technical skills. I do not believe the Government, especially in a time of tight budgets, will devote the extraordinary time and dollars that would be required to adequately train every supervisory in the organization. This system appears to be a method to lower costs. Pay will be set on very nebulous factors, including "availability of funds", local labor markets as interpreted by the Department, etc. Management will be able to manipulate these to meet their own goals and needs - primarily fiscal ones. Employees will never be able to plan ahead as to what type of pay may be expected. There will be a limited pool of money, therefore there will be intense pressure for quotas, or limiting the number of employees identified as superior performers, even though the purported goal is an organization full of exceptional performers, weeding out the dead wood. There is great potential for losing consistency across Agencies in pay and other benefits. If you work for a very conservative manager, you will receive nothing. If you work for someone "who can't say no", you will receive higher pay increases. This will create very low morale and have just the opposite effect desired. If you break your neck trying to do the very best possible, and you have a poor manager, you will be penalized. The system does need change. This would appear to go way to far in giving managers the ability to completly dominate workers. The success of the American Civil Service has been in part to the consistency of the workforce. This is going to be lost. People will be trying to jump around managers that don't reward their employees. Historically Government has done a very poor job in training managers. In our Agency training in this area is basically non-existant. The excuse is always given there is no budget. That excuse will continue after the first flurry of training. The result will be inequity, increased litigation due to poor management, and less consistency in the workforce. In a perfect world, the proposed system would work. However, given my 23 years of government experience, it is likely to fail. The basic reason is human nature. Just like there are poor workers, there are poor managers. This system does not appear to recognize that. There needs to be increased flexibility in hiring, and changes to classification system for sure. I am in a standard that is 40 years old and does not reflect my current responsibilities. However, under the guise of national security, Management is using this opportunity to get rid of all those annoying employees rights they hate, at least in my perspective. The proposal needs to swing a back to the center a bit in order to have credibility with the mainstream employee.