| Comment Number: | OL-10503633 |
| Received: | 3/7/2005 10:12:35 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:
NATIONAL SECURITY PERSONNEL SYSTEM SECTION 9901 General provisions As a career civil service person with superior performance ratings, I feel this new proposed system is a slap in the face. I keep being told that management wants all these new responsibilities….ask management…they don’t. Through years of civilian reductions, there are not enough personnel to accomplish the work that needs to be done. No one has the time to take on additional duties. This new system will cause several new authorizations in the budget arena to be created to manage pay pools. This is additional work that is not essential in the war on terrorism. The management officials do not want to print their own listings of candidates, make qualification determinations, set pay, etc. They are far too busy to deal with these issues. They would prefer for their human resources offices to take care of these things, as would the employees. Employees want fairness and equality, not a “buddy system” which pay for performance will create. NSPS is indicative of court cases and many monetary payouts for cases lost! SUBPART B – 9901.201-9901.231 Classification The position classification standards accurately measure job duties and responsibilities assigning an appropriate grade. Management officials do not have the expertise to grade positions appropriately. Again, if NSPS is passed, grade controls will erode and taxpayers will be paying out far more money than is required to get the mission accomplished. Managers will pay their favorite subordinates more money. Morale among the workforce will decline and job performance will ultimately suffer. The government always upholds integrity. Integrity will go out the window with the classifications changes proposed in this new system. If you view the OPM job standards they are generally evaluated the same from one government agency to another. Classifiers have trained for years to properly administer these standards. I can assure you that my base has 100% regulatory compliance. We do not have a problem recruiting personnel. Every time we recruit for a position we have plenty of well qualified candidates who are willing to pay their own move. SECTION SUBPART C 9901.301-343 Performance Based Pay This system was tried 30 years ago and proved to be a “buddy system”. It was then decided to go with the GS/WG system of pay. The GS/WG system has worked fairly and equitably during the past years and should continue to be the system civil servants work under. The pay for performance proposal will cause a buddy system to exist and will cost taxpayers far more money than the current performance system costs. Performance pay pools There is a shortage of civil service jobs at the current time. Every military base would love to have more civilian workers due to continuity. This proposal for performance based pay pools will require each organization to set up another position to manage the pay pools and to input the required personnel actions. Why not leave these duties in the current civilian personnel office? This new system will require management to create new jobs that aren’t necessary to fulfill mission requirements. These jobs will take the place of positions management really needs in order to meet their mission requirements. These jobs will not be full-time jobs but they will have to be created as full-time for continuity. The current civil servants positions are all overworked now and there isn’t time for someone to take on the additional responsibilities. Each manager feels their secretaries are invaluable. You can bet every secretary will be given performance ratings at the highest level until they are paid as much as the management officials. Pay Administration The new pay administration guidelines are bogus. There are career fields whereby the government has a problem recruiting because of pay differences. The management officials should present their individual cases to Congress and pay should be established on special salary rate tables for the hard-to-fill jobs such as attorneys, scientists, etc. By allowing management to set salaries however they want, this is giving them an inappropriate license to pay wages that probably will not be appropriate. Again, if you allow management to pay whatever they deem appropriate, morale within the government employee network will lessen. Some pays have centralized civilian pay budgets and some bases have decentralized pay budgets. At my particular base, the pay was decentralized which severely limited management’s ability to hire. Several years ago, our base went to a centralized pot of money which enabled the base to set up and base actions on a wing-wide mission basis. I encourage you not to make decentralized pay mandatory—please let the decision be up to each base. Decisions need to be made on what is best for each location of the country. SUBPART D 9901.401 – 9901.409 Performance and Behavior Accountability I am certainly a proponent of removing poor performers. However, it has been my experience that most managers and supervisors want to be “good guys and gals” and they don’t want to hurt anyone’s feelings, therefore, they do not give good, honest feedback, nor do they perform their duties in following through will poor performers. As a personnelist, I have assisted managers in firing individuals for discipline and performance, and I have never lost a case before a third party. It is not true it takes forever to fire a civil servant. The management official has to follow the advice given and follow through with poor performers. The manager’s who whine about not being able to remove poor performers, are those individuals who have not done their jobs, they have allowed a poor performer to function with no adverse action…the manager wakes up one day and expects to remove the poor performer overnight. I predict that if this new NSPS system is adopted, many of these cases will end up in EEO channels and in court rooms, with the government being found liable in a number of cases that are erroneously handled. The current system works fine, if management will work within the system as it should be worked. SUBPART E 9901.501 – 9901.516 Staffing and Employment The current staffing methods work. However, it is frustrating to work among the regional centers that have been established throughout DoD to promote efficiency. The bases know their needs and they could recruit in less than half the time it takes the recruitment centers. Congress needs to poll managers at bases…they would much prefer to have a local personnel office to administer their needs. When the bases recruited, they had time limits on what was considered an appropriate number of days to hire…recruitment times have increased ten-fold with the recruitment centers. If Congress and DoD are serious about ensuring hiring is done faster, they should do away with the regional centers and put personnel back to each base. The OPM qualification standards are not hard to administer and when administered properly, there is little room for complaints or grievances. The new proposals under NSPS favor a “buddy system” which will not be putting the right person in the right job. This new system will favor moving up “buddies” within the chain. While it might work for a year or two, there will be other commanders and supervisors who don’t view the work of the individual that has been rapidly promoted as much as their “buddy” did—then the individual will be fired. SUBPART F- 9901.601-9901-611 Workforce shaping Under the previous reduction-in-force rules, most bases have been able to minimize the adverse impact of RIF. Normally, there are enough employees who will accept a buy-out in order to preclude others from being RIFd. Reading between the lines regarding the new proposals, reductions will hurt every phase of every department….personnel will be reduced ….federal employment will not be secure any longer. If managers and supervisors accomplished their jobs, they would take care of the poor performers and you wouldn’t have to worry about the reduction in force rules. Several years ago, there was a 5-tiered performance system. If an employee was rated in the top section of their performance, the employee received 20 years service credit for RIF. That system enabled a difference in employees to be noted. Rather than the current proposals under NSPS maybe the old performance system should be re-issued. SUMMARY In summary, I would appeal to Congress to revoke this NSPS system. The persons who are advocating this system do not work at base level and they are using horror stories to scare persons into believing the system doesn’t work. I have 30 plus years of experience n personnel and I know there are faults in the system, but they are not as dramatic as to what Congress and DoD has been led to believe. I think the new system is horrendous and will cause a state of flux that is not needed right now. Most of the civil service workers are dedicated and work a tremendous amount of uncompensated hours to ensure their work gets accomplished. Most civil servants believe in what they do. Again, I think the new system is a slap in the face to the dedicated workers in the system. I truly believe the proposals are going too fast and the persons writing these proposals are not at base level where we see the issues day in and day out. I encourage you not to adopt this new system…leave the system alone. Hold managers accountable for ensuring their workers are satisfactory and solid performers.