| Comment Number: | OL-10503332 |
| Received: | 3/4/2005 9:28:54 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:
The essence of NSPS, is back to the past, the "spoils system". It sets up a virtual dictatorship or master and slave relationship. Those who argue that the current Civil Service System is broken are either ignorant of historical facts or are being disingenuous. What the Civil Service System did was set up a scholarly personnel system that aimed at fairness, setting in place the principles of equal pay for substantially equal work, prohibited personnel practices and merit principles, In general, it tended toward democratization and protection of public funds or tax payer money by emphasizing efficiency, effectiveness, ethics and economy. Whereas the NSPS sets up a "trust me" system. The system establishes the Secretary of DOD as supreme, his rules would be subjected to none others; marginalizing OPM, MSPB and FLRA. Any grievance reviews done by either of those organizations would be done using only DOD rules only. Title 5 personnel rules as curently writen, are as old as yesterday but they are as new as tomorrow. They are as relevant as the US constitution and Bill of Rights for protecting citizenry. A valid argument is administrators, supervisors and managers have failed to fulfil fiduciary responsibilities in implementing the current Title 5 personnel system, but the system is solid and as flexible as it needs to be. Managers have not been held accountable for their mismanagement. Mismanagement, and abuses abound, they're usually kept under the radar of public notice, however. There are thousands of smaller Darlene Druyun's in DOD, and the Federal Govt. in general. NSPS or the new system does little to address that type character. The current Title 5 personnel system requires decisions be factually validated. Whereas, the NSPS system is a throw back to the spoils system where subjectivity reigned. The NSPS sets up a virtual dictatorship, whereas employees with legitimate grievances would need to present their case to the dictator, who meted out the punishment. Any appeal which gets outside the system to say OPM, would be adjudicated using the dictator rules. OPM is not the model organization of it's past creed, ensuring equity and fairness throught the government. Summarily, both workers and tax payers will be losers under the NSPS system. Predictably, personnel salary costs will unjustifiably sky rocket, unconstrained by preclusive systems currently in place. Others argue salaries will be constrained by budgets. Partially true, but, them that got will get-- the managers--the supervisors, buddies and subjectivity the rest. Any comprehensive and objective compartive analysis of NSPS will show it's a step back in time. Even the very title "National Security Personnel System" is deceitful.