| Comment Number: | OL-10501897 |
| Received: | 2/28/2005 12:15:31 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:
Pay and Pay Administration - Subpart C: It is not proper that DoD gives itself the right to lower overall pay amounts of a particular agency to less than that of other agencies. This is very dishonest and underhanded. The employees are not going to accept this lack of fairness in the new personnel system. Also, I have an issue that there is no promise to try and ensure that any individual employees are not disadvantaged because of conversion to NSPS. It seems to the employees that this new personnel system is a way to save money by not giving people fair pay; not a system to reward high performers like it is being sold. Setting and adjusting rate ranges: The DoD needs to ensure that cost of living and inflation is reflected in an employee's pay. After reading the proposal, it appears that if the minimum rate in a band does not increase, then there will be no general increases for employees in that band. Once again, this infringes upon respect and rights of humans who have devoted their lives to public service. NSPS needs to create a way that each employee gets at least some slight pay increase each year to reflect the changing economy. Also, the increasing of rates based on occupation is not fair because it appears that there will be a tendency for the higher paid occupations to get fewer pay increases in order for DoD to save money. Once again this reflects not only bad ethics but creates a hostile environment throughout the government between different occupations. Local market supplements: The same philosophy applies here, as did with the rate increases by occupation. Please see above comments. Performance payouts: Under the newly proposed NSPS system, it appears that job responsibilities will be blurred. Currently, for instance, a GS-12 will be a team lead and is required to have more job responsibilities. With the new system, since there will be no formal ranking and pay will differ, it may cause an environment where certain employees do not want to take the lead because other may be paid more than they, even if they have more experience. It is going to create a "hands off" environment where the only goal is to please management to get pay increases and the job at hand will be secondary. This is not good when we need to be supporting our troops. We do not need to create this type of environment. Challenging a rating: I do not agree that challenging a rating should be an internal process and not a negotiated grievance process. There needs to be a system of "checks and balances" to discourage favoritism. If the ability to grieve is removed, we are left with a system that gives supervisors too much power and there must be a system to check potentially dishonorable management. Adverse Actions - Subpart G: Coverage: There is not enough clarification in this section of the proposal. The Mandatory Removal Offences need to be specified and delineated before this system is passed. Appeals - Subpart H: I do not agree with shortening the deadline for appeals. There will be more appeals with this new system so the work log for appeals will most definitely increase. Therefore, shortening the deadline for appeals will work against both those processing appeals and the worker who wishes to appeal. Labor-Management Relations - Subpart I: National Security Labor Relations Board: The new system grants too much power for one body. In this case, NSLRB would need some other system of checks and balances to ensure that corruptness due to increased power is not created. Scope of Bargaining: I do not agree with restructuring the bargaining rights. Once again to infringe on the employees rights through this new implementation will have many adverse effects.