| Comment Number: | OL-10502895 |
| Received: | 3/3/2005 10:52:01 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:
After reading the NSPS as published in the Federal Register I would like to comment on the premise under which this system was developed. The purpose of the system is to establish "a more flexible civilian personnel management system" The Federal Register states that the "current Federal personnel management system is based on important core principles" and goes on to say "those principles are operationalized in an inflexible, one-size-fits-all system of defining work, hiring staff, managing people, assessing and rewarding performance and advancing personnel."...."hiring processes are cumbersome, high performers and low performers are paid alike and the labor system encourages a dispute oriented, adversarial relationship between management and labor." As a DOD employee, I must refute these statements. If the current personnel system is used correctly, low performers are not rewarded the same as high performers. There are mechanisms to give high performers more bonuses based on their performance, incentive awards, cash awards, on-the-spot awards, quality step increases, and promotions. On the other hand, it is management’s discretion as to whether anyone gets a step increase, therefore if utilized properly, low performers would not receive any pay increases. It is true that low performers can actually received a 10% reduction in pay in the proposed personnel system which does not happen in the current system. Likewise, currently, management does not necessarily advertise positions to be filled internally first. There are mechanisms in place to hire contractors to fill positions. Therefore the statement “the limitations imposed by the current personnel system often prevent managers from using civilian employees effectively” is not true. It is true the “Department sometimes uses military personnel or contractors when civilian employees could have and should have been the right answer” . DOD civilian employees often do have the right answer but are not asked. DOD does not need a new system to become "more competitive in setting salaries, and help attract skilled, talented, and motivated people while also retaining and improving the skills of the existing workforce". The current system needs to be properly implemented and enforced. There are mechanisms in place in the current system which allow for all of the positive attributes of the new proposed system to be fulfilled if it is implemented properly and used effectively while at the same time ensuring DOD personnel some protection and job security. One of the advantages of working for the government is the job security which would be eliminated with the proposed NSPS. Also, DOD workers are basically loosing all of their union representation under the proposed NSPS. Therefore, how will this system make the government more competitive with industry for talented personnel? Many DOD employees have opted for lower pay in lieu of job security. And many of the so -called non-performers in DOD have been created because they are not given the opportunity to excel within the system because others (contractors etc.) are brought in and promoted over them. How is the new system going to change this? The proposed system NSPS will worsen this situation. DOD needs to implement the current personnel system effectively instead of trying to implement a totally new system which highlights all the downfalls of the current system, down plays all the advantages of the current system and will create an even more dispute-oriented, adversarial relationship between management and labor.