Comment Number: OL-10502558
Received: 3/2/2005 12:27:08 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:

I have worked for DoD for over 20 years. This system is not right for the government with the way many supervisors are. This system will change the way workers are paid, evaluated, promoted, fired, scheduled, and treated. These rules would create a system in which federal managers are influenced by favoritism rather than serving the civil concerns of the American people. The new regulations talk about rewarding good behavior. What precludes a superior from evaluating an employee's behavior as unacceptable when in fact it is not? Favoritism will run wild. Also, what precludes superiors from developing good old boy networks of employees with this system? The system is NOT very specific about checks and balances when it comes to this area. Some of the regulations are very subjective in nature, which means that if one does not agree with superiors, one can be graded down and have reduced pay and responsibility. Is this what we want? I do not think so, what is the check on this behavior and what can be done about the bad boss in this system? The new regs open the way for backsliding into the Good 'ole Boy system where politics play too large a part. What bargaining rights we Federal Employees have managed to get need to be preserved. This new system is no way to repay the loyalty & hard work of Civil Service employees The historic division of the GS-13 level has been equated with a "field grade" assignment. In fact, civilian deputies to field grade officers are GS-13's and above. Most GS-13's are serving in leadership, management and figurehead positions, which fully warrants the inclusion of this grade in the top pay band. Failure to place the GS-13 grade in the top band would severely limit a commanders/senior managers and place the leader/manager in the same band at the supervised. It would then be common for employees with less responsibility to potentially be paid more. Failure to make this distinction during the conversion will threaten the success of the new system. Annual Pay Raises Under the General Schedule, employee pay was clear. It was funded by Congress and could not be taken away. However, NSPS will take away this certainty. Salaries and bonuses are funded by DoD. In the past as recently as just last year DoD did not fund its awards program. Given the agencys miserable record on this issue, how can employees feel confident that our salaries and bonuses will be funded in the future? Friend of the Supervisor Pay System With the new patronage pay system, which DoD calls pay for performance, the amount of a worker's salary will depend almost completely on the personal judgment of his or her manager. This system will force workers to compete with one another for pay raises, which will destroy teamwork, increase conflict among employees, and reward short-term outcomes. There is no guarantee that even the best workers will receive a pay raise or that the pay offered will be fair or competitive. This system will create a situation in which workers are in conflict with one another and afraid to speak out about harassment, violations of the law, and workplace safety problems. Furthermore, there will be no impartial appeal system to assure that everyone is treated fairly. Schedules and Overtime NSPS will allow managers to schedule employees to work without sufficient advance notice of schedule changes. This will make it extremely difficult for working parents to care for their children and family. It will also mean that abusive managers could harass employees with bad schedules or short notice’s. Overtime rotations can be canceled, which means that employees may not be able to plan adequately for childcare and other important responsibilities.