Comment Number: OL-10504260
Received: 3/8/2005 8:19:21 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:

I am afraid that almost every aspect of this proposed plan troubles me. The biggest issue I have with the NSPS is the proposed pay system. I don’t agree with allowing our supervisors complete control to raise or reduce our pay. I could accept a guaranteed cost of living raise and an additional pay increase that would be based upon performance but I could never support a pay reduction. In addition, where is the pay incentive for center/base/agency performance? If this plan is attempting to model itself after the private sector, companies the size of the DOD pay a performance bonus based upon the overall company performance. There is no mention of such a bonus in the NSPS. I hate to bring this up but the NSPS assumes the workforce trusts the DOD and the Country’s leadership to allocate enough raise money to fairly compensate outstanding performers. Unfortunately, the current administration has consistently proposed cost of living adjustments below the adjustments given to the armed services and the DOD does not fully fund its own outstanding performance bonus fund. Since everyone would get a different raise under the NSPS it would be very easy to not give out as much money as the agency is forced to under the current system. The issue of trust pops up throughout my review of the NSPS not just in pay. The NSPS asks the workforce to trust the DOD’s judgement in the areas of Job Classification, Pay, Performance Management, Hiring, Reduction in Force, Adverse Actions, Appeals, and Labor Relations. The overriding theme in each area is the management will perform better if allowed wider latitude to make uncontested decisions. However, I’m afraid I just don’t trust the DOD’s judgement in these areas without the oversight currently in place. For example, during a RIF under the NSPS the people that will stay or go would no longer be based upon seniority but the management’s judgement of the best workers. A manager’s judgement of the best employees is very subjective and can vary from manager to manger within a department. I fear the decisions will not reflect the best employees but the whim of management to keep the people they personally like the best. In addition, the NSPS would start to create pay disparities between employees in similar positions, RIF decisions could be based on who is the cheapest. In the end, the DOD’s management has not demonstrated enough good judgement in the past to warrant the trust of the DOD’s employees that it would demonstrate good judgement with additional authority.