| Comment Number: | OL-10502496 |
| Received: | 3/2/2005 10:23:22 AM |
| 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:
As a 26 year civil service employee, I view the intentions of the NSPS as admirable, but have serious concerns over the resulting structure after implementation. First, government should honor its agreement with existing employees. Such as changes to military pay retirement calculations, members were grandfathered when implementing new policies. Along the same line, the major overhaul of civil service retirement system from CSRS to FERS was mandatory for newly hired employees but current employees had the option of maintaining the current system or switching to FERS. The decision to adopt NSPS, should be an option of existing employees. While this may be more beneficial to many employees, the actual results cannot be known and should be a personal decision (as with FERS selection, once a decision is made it should be irreverable but this option should be provided). Second, the NSPS proports a benefit to employees in being able to more easily reward good workers. The problem with this conclusion, fairness of supervisors and surpervisor authority or ranking come into play. The pay issue is essentially a net sum zero gain. Employees who receive the larger bonus or pay rate, are at the expense of others lowered. Theoretically this is practical if all supervisors complete equally for the "pay pool" resources. However, reality is pay pools are limited and higher ranking supervisors (especially within the military services) will have the leverage to get their employees the highest rates of pay. No procedures are in place to assure fairness. My last point is with regards to professional, trained staffs. If DoD truely wants a well educated, professional workforce, pay and benefits should be structured as such. It is assumed management will assign pay based on these principles, but has no mechanism to ensure this happens. If DoD is serious about its committement to a quality federal work force, mandatory percentages or credit should be awarded for: education, professional certifications, formal training, and the breadth of experience. This would take much of the subjectivity out of pay setting, and provide employees with the information they need to reach specific pay goals. The system would be viewed by employees as fair and impartial when the same rules apply to all. NSPS opens the way for abuse of hiring and pay setting if more stringent goals for both are retained. Taking away GS designations, along with educational requirements (such as for accountant/auditors) lowers the standards and potenetially the quality of future recruits. I believe the systems needs more review and safeguards to take out some of the subjectivity to ensure fairness for all prior to implementation. Current employees should be provided the option to enroll or abstain from participation in this new system. Respectfully, Lori A Tetla