Comment Number: OL-10503000
Received: 3/3/2005 4:35:36 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:

Reference: Docket Number NSPS 2005-01 Supplemental Information and Chapter XCIX Department of Defense National Security Personnel System (Department of Defense -- Office of Personnel Management) Part 9901 -- Department of Defense National Security Personnel Management System in Total Civil Service as it has stood for almost the last hundred years is under attack. Why is this? I believe we have lost the idea of the civil service as an independent body and are quickly reverting back to the old “spoils system.” On paper, politics has no place in the NSPS rules but things like mandatory removal offenses, adverse actions, pay for performance can all be turned into politics since many agency heads and most DOD secretaries are political appointees. The idea of Civil Service is to provide a knowledge base to maintain the Department’s functions from administration to administration. I cannot convince myself of anything except that NSPS will become the “spoils system” all over again. Another issue of great concern is “Workforce Shaping” This is a great idea and being in management I agree that sometimes it is important to be in a position to move the human capital around to make sure that all jobs are getting done and our mission is supported. However, “Workforce Shaping” can also lead to all forms abuse. If all managers in DOD were enlightened and understood all the tenets of good human resource management, then I could see it succeeding. In DOD, we do not have the most enlightened managers, over years I have personally worked for only a couple. Excellent managers are few and far between.. There is one area where NSPS might be of help; if we could reward the individuals who do the heavy lifting but do not want to be managers that would be a great help. We could give the salary of the next grade but they could continue to do the work that they love and are good at. I am not sure pay banding will help accomplish this. I believe that NSPS will undermine the DOD’s ability to maintain “corporate knowledge” of policy and procedures because a lot of information resides in the memories of employees and these skills are not readily available in the general population. It is a way to get rid of A-76 studies and make contracting out easier as part of “workforce shaping.” It may also provide a way to reward cronies and punish rivals. It is also way to cut the pay of DOD employees. Initially, the pay will be set at not less than what a person is making now but in the future the pay will depend on the amount in the pay pool. This could lead to furloughs due to lack funds, firings, and reductions in pay which could undermine “corporate knowledge” by driving away knowledgeable personnel. NSPS sounds good at least in the propaganda that has been published but is it in actuality an end to civil service in the DOD? Maybe it should be stopped. I personally supervise a small office with big responsibilities for the supplies and parts needed in the War on Terror; this is a worthy function and my staff is dedicated. We work hard but we rely on Civil Service rules to protect us and thereby protect the nation. With NSPS, we could spend our time protecting ourselves.