Comment Number: OL-10503762
Received: 3/7/2005 2:45:31 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:

Comments concerning NSPS proposed regulations on personnel & pay changes. RIN=3206-AK76/0790-AH82 The events of 9/11 are a poor justification for the sweeping depth of the proposed changes. However, some efficiencies to the civil service personnel system can be justified. I am deeply concerned the proposed changes are a step backwards for Civil Servants and the system that employs them. My biggest concern is that the proposed changes open the window for politicization of individual shop labor-management dynamics. Pay will become subjective and this will lead to inequalities and poor morale. The biggest reason the union came into the National Guard workplace in the late 60s’ is just for this reason. At that time, pay raises were not automatically distributed to the employee. A board was convened where the commander/supervisor decided how much of the raise the employee was to get. They had the power to give all, some or none of the raise to the employee (exactly what is being proposed). They would take any $$$ not awarded to that employee and give it to someone else. Favoritism was a rampant element in this procedure. It was often quite demoralizing to the employee. There were no appeals. How is reversion back to this procedure supposed to improve our workplace? The present system already allows supervisors to do their job and discipline unproductive workers. I agree that better rewards, such as bonuses, could improve performance. I agree that the present system is inadequate and not timely in providing positive reinforcement. The biggest problem is poor supervision. I agree that some improvement in the compensation system needs to occur if we are entice top performers into civil service. Sign-On bonuses are the most popular. Better incentives would help the entire system. Fast Tracking would be preferred to the extraordinarily slow hiring/advertising system we now suffer with. It is not unusual for a job to be vacant for a year awaiting the paperwork process. This is intolerable and a perfect example of what really needs repaired in Civil Service. The compensation and rating systems as now evolved over the decades is adequate if used. But there should be an expeditious way to fill jobs that still does not discriminate or foster favoritism. I fear what is being proposed may be a step backward from the reason Civil Service was established to begin with. The weak link again is execution by poor supervision. Another root cause of system problems is simply poor managers. How is any NSPS system change going to cure that? Accountability is the biggest system deficiencies. That is not addressed. The excessive percentage of “outstanding” & “excellent” performance ratings within the National Guard speaks to the poor job supervisors do rating their people now. How is any new rating system going to fix the raters? Accountability for all managers should be the primary focus of any reform. Increased accountability should be accompanied by appropriate compensation. Job banding accompany pay banding. Exempted civil servants (such as National Guard Technicians) should be allowed to compete for competitive jobs. Not being given credit for “exempted” experience unfairly limits the field of candidates for competitive positions. Active Military title 32 employees should not be mixed with technicians in the same job assignments; the compensation and benefit packages are very different. This creates unnecessary morale issues. It fosters double standards and preferential treatment. “Performance” and “contribution” have always been subjective in work areas. The Civil Service rating system was designed to minimize that subjectivity. The proposed NSPS job banding changes will increase that subjectivity. Hence, politics will re-enter basic government services without these controls. I agree that many jobs are overspecialized and this restricts competition. Western Classification is tasked with fixing this but they are woefully slow and unresponsive. This is why people who can make more $$$ outside the system leave. They get tired of under-compensation, woefully slow recognition, and self-serving management. The real fix for this system is not reinvention but rather compliance with reduced lead times for compliance. Make people responsible for inaction. Negative job actions can be streamlined without changing anything. Union involvement should be considered a benefit to management. If used properly, the union becomes a compliance tool. People in civil service often are under-compensated. But they have been willing up to now to trade that for the job security/stability. These proposed changes will impact that stability without fixing compensation. Someone in each workplace will lose as much as another gains. This is an unfair labor practice. It is why civil service protections were established. To use the events of 9/11 as a justification for this step backwards for government employment is callous. Specific system fixes should considered; not complete overhaul.