| Comment Number: | OL-10503975 |
| Received: | 3/8/2005 9:17:57 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:
Annual Pay Raises Under the General Schedule and FWS, employee pay was clear. It was funded by Congress and could not be taken away. However, NSPS will take away this certainty. Salaries and bonuses are funded by DoD. Also we do not know what the pay structure will be under the new system, for example what is the pay band for a GS-12 step-10? “Friend of the Supervisor” Pay System The amount of a worker's salary will depend almost completely on the personal judgment of his or her manager. This system will destroy teamwork, increase conflict among employees, and reward short-term outcomes. This system will create a situation in which workers are in conflict with one another and afraid to speak out about harassment, violations of the law, and workplace safety problems. Furthermore, there will be no impartial appeal system to assure that everyone is treated fairly. Schedules and Overtime NSPS will allow managers to schedule employees to work without sufficient advance notice of schedule changes. This will make it extremely difficult for working parents to care for their children and family. Civilian Deployment Federal employees could be assigned anywhere in the world, even into a war zone, with little or no notice. This would be a hardship for disabled employees like me with a spinal cord injury that requires specialized quality medical care/treatment that is not available in other parts of the country/world. Recommendations 1. Subpart C Pay, Sections 9901.301 to 9901.373 The employees in DoD should continue to receive the same annual pay across-the-board adjustment that other GS/FWS workers receive. We cannot afford to live in the NY area without it. The individual pay increases for performance should include guaranteed percentages in the regulations so that employees will understand the pay system and what their pay increase will be depending on their performance. 2. Subpart D Performance Management - 9901.401 to 9901.409 In order to insure fairness and accuracy, DoD employees should be able to appeal any performance rating to an independent grievance and arbitration process like they can do now. 3. Subpart F Workforce Shaping - 9901.6012 to 9901.611 DoD should not change the current layoff/RIF rules which give balanced credit to performance and the employee’s valuable years of committed service to DoD. 4. Subpart G Adverse Actions - 9901.701 to 9901.810 Due process and fairness demand that the independent body reviewing a major suspension as termination be allowed to alter the proposed penalty if they deem it to be unreasonable. The current standards approved by the courts to guide such bodies should continue to be used. 5. Subpart I Labor-Management Relations - 9901.901 to 9901.929 The labor management law that has governed the employees’ right to organize and engage in collective bargaining has worked well since 1978. There is no compelling reason to take away most of the collective bargaining rights or grievance rights. DoD should not create a “company dominated dispute board.” Any dispute board must be “jointly selected” by management and the Union.