Comment Number: OL-10501927
Received: 2/28/2005 1:54:24 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:

The NSPS can lead to significant problems because "temporary" military supervisors are not in place long enough to do the job properly even assuming they are motivated to try to do so. As an overall comment, I'd like to say that this proposed pay sytem places a large additional burden on already overly taxed supervisors at all levels. The newly added budgetary aspect may become especially onerous on top of other responsibilities. A potential for supervisor overload can effect the very livelyhood of those they supervise. Such an additional workload cannot be expected to improve anything. The fact that the existing structure is old is not a good reason for change. Considering the military grade and pay system has its direct roots in the British military of the eighteenth century, the age of that system is apparently not a factor. This comment primarily involves Subpart D and others. My concern is with military supervisors of DOD civilians to include immediate supervisors and higher level managers in uniform. A very large percentage of military personnel are resident in a particular "job" for two years with a few staying for up to four years. Many have never worked with civilians before and most expect to not work with civilians again. This tends to cause reduced concern for civil service issues. This is true at all rank levels. One may describe this two-to-four year assignment situation as hiring a "temporary military supervisor". The individual may be a twenty-year veteran, but he/she is in a given job with a given mix of people for only a short time. Also, the "temporary military supervisor" may have no prior experience with cilivian workers (worst case) or may have prior experience (not much better). One problem is ensuring the temporary military supervisor is trained on all the difficult details and is properly motivated to do the job. The real problem is that the military member will not be around the office long enough to get to know his/her civilian worker sufficiently to make accurate judgements about personal behaviors. Therefore, there is a very real chance that pay issues will be based on best guesses and no small amount of favoritism whether unintentional or otherwise. In the all civilian environment where these proposed pay concepts evolved with some success, the people got to know each other over much longer periods of time and most supervisors "grew up" in the organisation. This cannot happen in a military organization. Under the present "GS" system, the effect of temporary military supervision is a problem which is minimized but not eliminated by the exisiting structure. I have witnessed too many cases of poor personnel management decisions by military (and civilian) supervisors under the present system. Many of those errors are due to inexperience. The present GS system offers some shielding -- at least the pay is secure. In the new NSPS, those sorts of errors, intended and unintended misbehaviors will undoubtedly directly affect the income and lives of civil service subordinates. Personnally, I've seen this from both in and out of uniform. I have benefited from a series of good supervisors. Even the best of the military supervisors still had their "learner's permits" when they left. I will probably be one of the "favorites" in this new system, too. But what if the new GI in charge this week does not like me? I'm only five years away from the start of my "high three" for CSRS retirement. It is very scary.