| Comment Number: | OL-10503245 |
| Received: | 3/4/2005 2:39:59 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:
Thank you for letting me voice my concerns about the proposed NSPS regulations. I have been a Federal Civil Service engineer for over 24 years, and am very concerned about several aspects of NSPS. My first major concern is the threat of supervisor favoritism, or even worse, the threat of what could happen to your pay and career if your supervisor doesn’t like you for whatever reason. With NSPS putting so much power (to determine pay increases and disciplinary actions that could affect your pay/career) in the hands of supervision, a major increase in abuses and unfair actions seem inevitable. It is my understanding that the old Civil Service Pay System with its grade levels and steps was designed to prevent such unfair practices by supervision. Even with those protections, I know of cases where promotions were withheld from employees by supervisors who simply didn’t like the employees, regardless of their exemplary performance. NSPS would only increase these abuses by supervision since pay increases, draconian disciplinary actions affecting pay by 10% or more with no real means to appeal, and easy firings would also be put in the hands of these same supervisors. This is an insult to Civil Service employees’ rights. My second major concern is the “gutting” of Union representation necessary to help protect Civil Service employees’ rights. Although many of the Unions will still exist, there is no means to force management to abide by any contract except in court, which is costly, meaning that many small Unions will not be able to support lenghy litigations. In short, NSPS appears to be a thinly disguised version of “Union busting”. While I was not originally a big fan of Unions, I have come to realize that Union representation is very important in protecting Civil Service employees’ rights – especially in this era of “militarization” of Civil Service in the DOD. My third major concern involves funding and pay. Apparently, funds have not been identified or provided for the operational costs to implement NSPS. Agencies who are required to implement NSPS changes will be required to fund it from existing budgets, forcing each agency to “rob Peter to pay Paul”. Of course that will mean even less funding to support pay increases at each agency, with any pay increases totally in the hands of management. What are the chances that employees will receive their fair share of pay increases? Indeed, in this era of tight budgets, what are the chances that employees’ pay increases will even come close to keeping up with inflation? Although we will theoretically be paid based on performance, where will the pay increases come from if there is little or no money to pay for increased salaries? In this respect, NSPS seems to be a thinly disguised version of pay cutting. My final major concern is employee morale, which I predict will be a major problem if NSPS is implemented as proposed. Given the assaults on employee rights, pay, and career security described above, how could it be any different? I was encouraged when the DOD began to embrace the concepts of Deming’s Total Quality in the early 1990’s, realizing that most employees will perform with excellence if given the tools, opportunity, respect, and fair treatment by management. NSPS seems to abandon, and even reverse, that progress. Employee morale problems will surely result if NSPS is implemented as proposed since all of its provisions are negative as far as employees are concerned. What in NSPS is beneficial for employees? Give us the tools, opportunity, respect, and fair treatment, and we will perform with excellence. Get rid of those that don’t, even if that means adding provisions for employee removal to the current Civil Service System, but don’t force the unfair provisions of NSPS on all of us.