| Comment Number: | OL-10501386 |
| Received: | 2/24/2005 11:17:19 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:
(Comments continued from previous submittals) 15. Why is it necessary to arbitrarily deny collective bargaining under NSPS? Consultation in lieu if bargaining has always been a joke. Management uses this to give the appearance that employee unions are in agreement with their actions. Meetings may take place but they are one sided and without true negotiations or meaningful discussions. DoD has always had the power to deny bargaining during emergencies. Unions have never stood in the way of national security. How did we come this far if unions were a threat to DoD? 16. Some matters are suited for national level bargaining. I say this as a union official. Hopefully DoD will not take this concept too far but given their track record with unions lately, they probably will. 17. Although "performance pay" makes a good sound bite, it cannot realistically be implemented fairly in the public sector. The vast majority of the public sector employers use systems similar to the GS system. Twenty-five years of DoD demonstration experiments and DoD surveys of participants have shown that the majority of employees on these alternative systems would prefer to go back to the GS system. 18. Under NSPS, team performance pay might mitigate some of the damage if it is emphasized over individualized performance pay. One of Deming's seven deadly sins, “individualized performance pay” is an outdated concept and is no longer advocated in modern day management academic courses. Individualized performance pay will create a backstabbing and suck up culture within the DoD civil service, ultimately hurting the mission and national security. 19. If NSPS must be implemented, then it should be implemented similar to the way FERS (Federal Employee Retirement System) was implemented when it replaced CSRS (Civil Service Retirement System) twenty years ago, applying only to new hires. Congress recognized then, that it was unfair to change the rules midstream during an employee's career. Long time civil servants will feel betrayed and demoralized by such a profound change as NSPS. 20. Under the NSPS proposal, a 1-year employee with a Level-5 rating of record would be retained over a 20-year employee with a Level-4 rating of record, in the event of a layoff or RIF (reduction-in-force). This is alarming and demoralizing. There is no loyalty to the employee under NSPS, which in turn creates no loyalty to the employer. 21. NSPS does not address the subject of performance ratings for union officials who are full time or who require significant official time. This subject need to be addressed.