| Comment Number: | OL-10503743 |
| Received: | 3/7/2005 2:13:01 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 NSPS as introduced in the Federal Register misrepresents the DOD employee's role in its development as well as in the proposed implementation of the system itself. As stated "25 to 30 senior experts used the Defense Acquisition Management Model as a way to establish the requirements for the design and implementation of the NSPS". The PEO established working groups " over 120 employees representing Military Departments (ARMY, Navy, Air Force), the other DOD components and OPM began the process of identifying and developing options and alternatives". As stated, " a comprehensive outreach and communications strategy is essential for designing and implementing a new HR system" however, the select few that were in the designing process never filtered down the information to the workforce. " The PEO identified channels for disseminating relevant, timely, and consistent information" " a website was developed however, there was little if any information disseminated through the website other than the fact there was a new personnel system being proposed. Like the Federal Register specific details were lacking. "106 focus groups were held throughout DOD, including overseas locations"," town hall meetings were held in DOD facilities around the world", " 10 joint meetings with officials of the 41 unions that represent DOD employees"were held. " The sessions assured that civilian employees, managers, supervisors, union leadership and other key stakeholders were involved in the design and implementation of the NSPS and had ample opportunity to provide input". Why then, are there so many objections by the unions and employees against the NSPS? The Federal Register leads one to believe that this was a coordinated, agreed upon system which took everyone's input into account. In reality, the concept of a new personnel system was suggested, but as in the Federal Register, no details were given as to exactly how it would be implemented and affect the individual DOD employee. Separate personnel demonstrations that were developed at DOD installations which did entail a considerable amount of employee input were cast aside in lieu of this system which was designed by "senior experts" "senior DOD and OPM leaders" and "subject matter experts". The so-called communication we received was "DOD is working with the Office of Personnel Management on finalizing the NSPS enabling regulations. When completed, the enabling regulation will be published in the Federal Register for public comment and statutory collaboration with employee representatives followed by the publication of DOD implementing regulations. Once this process is completed, we will begin implementation. We anticipate that the first Spiral 1 implementation will take place as early as July 2005 In addition; the Labor Relations system will be implemented across the entire DOD as early as July 2005. One of the most important steps in smoothly transitioning to NSPS will be your understanding of the new system" this is quoted form a letter dated 14 Dec 2204 and was sent to the Army Material Command Workforce. The letter goes on to say " DOD is developing an employee handbook and NSPS tutorial for your use. These will be posted on the DOD website when they are completed.... I encourage you to periodically visit the website... Army guidance and detailed plans will be posted ... when they are developed." This is an example of the "comprehensive outreach and communications strategy ". The NSPS sounds like a done deal. Do our comments even have any impact?