| Comment Number: | OL-10501903 |
| Received: | 2/28/2005 12:35:59 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:
Officials from DOD and the OPM have been taking “great liberties” with the authorization given them by Public Law 108-136 to redesign the DoD Personnel System. Since passage of what has been referred to as NSPS, DoD/OPM reps have been hatching a plan to significantly change major personnel and labor relations systems at the Department in ways not envisioned nor intended by Congress. Under the banner of promoting “management flexibility,” neither the interests of DOD workers nor input from their democratically-elected representatives have been fairly considered. I see nothing in place to ensure accountability and cost effectiveness. I strongly object to the following proposed changes: Staffing – Federal civilian employees will be involuntarily reassigned (on a temporary or permanent basis) to any location around the globe to address changing mission requirements. Pay – Salaries of employees will be set according to an undisclosed pay-for-performance system that will assess the “market value” of the work. The prospect of periodic monetary increases will be linked to: a.) an evaluation by management of how well one’s duties were performed, and b.) special acts that managers believe warrant remuneration. Only those getting high ratings will be allowed to progress within their assigned occupational bands and receive pay increases. Pay will be set by the Secretary of DoD, not the congress. Hiring – The hiring process will be streamlined in some undetermined fashion. In addition, authority to set pay for new hires (at rates greater than employees already performing the same type of work) will be used to attract talented individuals to DOD. Until details are furnished, existing system should stay as is. Worker Rights – Provisions of law that have been in place for over 25 years will be set aside to maximize management flexibility. No independent third party review of most decisions will be permitted, collective bargaining agreements will become null and void, and the legal role of elected employee representatives will effectively be eliminated (as well as the accompanying system of checks and balances that serves to ensure that the government is being run in an effective manner). Legal standards for discipline and removal actions will be relaxed to make it easier for management to sustain such cases. Undisclosed procedures will be devised to address employees viewed as poor performers.