| Comment Number: | OL-10501615 |
| Received: | 2/27/2005 1:35:31 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 concerning - Federal Register: February 14, 2005 (Volume 70, Number 29) Proposed Rules: FR Document 05-2582/NSPS (National Security Personnel System) Page 7553: "At best, the current personnel system is based on 20th century assumptions about the nature of public service and cannot adequately address the 21st century national security environment." The reason civil service exists is to provide a structure to prevent abuses by management and elected officials. How is destroying these safeguards going to be beneficial to the country and its security? "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 Currently, pay and the movement of personnel are pegged to outdated, narrowly defined work definitions, hiring processes are cumbersome, high performers and low performers are paid alike, and the labor system encourages a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. " This a problem because management will not use the tools it currently possesses. All management has to do is learn what the rules are and how to use them. It is not the fault of employees that management does not get the training (at a much lower cost than this exercise) it needs to do its job. "The Department's 20 years of experience with transformational personnel demonstration projects, covering nearly 30,000 DoD employees, has shown that fundamental change in personnel management has positive results on individual career growth and opportunities, workforce responsiveness, and innovation; all these things multiply mission effectiveness." This an unproven assertion. "More specifically, the law provides the Department and OPM--in collaboration with employee representatives--authority to establish a flexible and contemporary system of civilian human resources management for DoD civilians. " Originally, DoD did not include OPM in its efforts to bring about this system. Only when Congress intervened did DoD begin to follow the law - PL108-136. At no time has DoD collaborated with the unions. It has dictated what and how this will occur. "Despite the professionalism and dedication of DoD civilian employees, the limitations imposed by the current personnel system often prevent managers from using civilian employees effectively." This is an unproven assertion. It is a failure of management to use the tools it possesses. "The law requires the Department to establish a contemporary and flexible system of human resources management. DoD and OPM are crafting NSPS through a collaborative process involving management, employees, and employee representatives, and are inviting comments from a broader community of other interested parties. DoD leadership will ensure that supervisors and employees understand the new system and can function effectively within it. The system will retain the core values of the civil service and allow employees to be paid and rewarded based on performance, innovation, and results. In addition, the system will provide employees with greater opportunities for career growth and mobility within the Department." These are assertions as there is nothing to back mere words. Management flexibility is a management problem that can be easily solved by using the current toolset.