| Comment Number: | OL-10502698 |
| Received: | 3/2/2005 4:09:14 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:
Re: DOD & OPM RIN 3206-AK76/0790-AH82 NSPS I am for streamlining the personnel process however I do have some concerns. The Case for Action is based on false political rhetoric of the current personnel system. It fails to identify why the current system is inefficient and cumbersome. Labor and Management have partnered for a common goal until the administration forced their will on labor with this NSPS system and shut out the unions from active participation. The rule would place collective bargaining restrictions on unions and only mega-unions would have authority to bargain. The performance system has many faults, including difficulty to measure, especially for non-production workers. NSPS fails to identify performance, good or bad. The new system could reward employees for performance even if it risks non-compliance with applicable rules and regulations. Employees should not be compensated for risking non-compliance while trying to get the job done at all costs. This rule does not identify how the pay banding will be converted from the existing GS. Will non-supervisory GS-12 800 series engineers be banded with GS-11 or GS-13 positions? What is a senior expert in the engineering and scientific professional pay schedule? The president has stated how this nation needs more engineers and has allowed several thousands of foreign engineers into the country. The proposed NSPS will allow the hiring of foreigners at the expense of national security and US citizen jobs. How will opportunities for DOD civilians be increased when the workforce is being downsized due to budget pressures? Where is the bonus money going to come from? The rule exempts DOD & OPM from certain provisions of Title 5 USC basically giving free reign for personnel actions without any recourse for the employee. The problem with civil service employment is that performance is hampered by many rules/standards that employees in the private sector do not have to follow. The continuing collaboration process means nothing if the Secretary has final say because they can ignore the partcipants comments. No longer relying on classification standards and position descriptions may help streamline the personnel process however there may be a risk of less qualified employees taking positions where they do not have the required knowledge, and educational background. One thing that is good is employees will not see a loss of compensation at the start of implementation. The loss of step increases will hurt. Employees are making less in terms of real dollars and are not keeping up with real inflation. The proposed pay system is vague and I am disapointed that the rule doesn't discuss details but only an undefined system left to the administration to define as they see fit after the rule goes into effect. How will market pay rates be set? Why should availability of funds be entered into the equation? GS employees have lost promised raises, to pay us comparably to the private sector, from previous administrations due to budget emergencies. Seniority needs to be considered in case of RIF not just tenure.