| Comment Number: | OL-10504455 |
| Received: | 3/9/2005 1:45:05 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:
-Reducing the number of job series will reduce rather than improve the effectiveness of the federal workforce. We must retain he proper number of job descriptions to allow for proper training and expertise. -I don't see how national security requires our current system of pay raises to be tampered with. NSPS would allow pay banding. No reason has been given to explain why the current system is not working. -The NSPS proposal would establish pay bands and raises would be based on performance. I know personally from my work experience that the bias demonstrated by my supervisor would prevent those employees in my area doing the most work from being paid the most. -Based on my personal experience with supervisors it will take tight internal controls and oversight to insure that supervisors do not use the new pay banding systems to reward their friends. Awards are handed out in this manner and if pay banding is allowed, wages will be controlled in the same manner. -DOD is removing the union's institutional right to be present during EEO proceedings, to include mediation efforts. This will allow DOD to make deals with employees in the EEO process and disregard any previously negotiated agreement bargained in good faith between the parties. -Outdated personnel practices are referred to, but why not keep the existing system and properly administer it? This seems like an excuse to replace the existing civil service system with something that is unproven. -The DOD proposal mentions that civilian employees must be flexible and a responsive part of the team. Does this mean that they can be deployed with notice to anywhere in the world to support military activities? What safeguards will protect the DOD civilians from being placed in harm's way? -Many feel that the recent centralization of personnel offices has contributed to the slow down in hiring. It seems that the NSPS proposal is an admission of the failure of this process. Why not reestablish local personnel offices? -It appears that the NSPS proposal would allow civilian employees to be assigned to war zones without any recourse on the part of the employee. What if I don't want to be sent to a war zone? -It is stated that high and low performers are paid alike as part of the justification for this new system. Why not correct the failure of management and supervision to correctly manage the current pay system, which does allow for compensation to be linked to performance? -Management seems unable or unwilling to correctly apply the existing civil service rules to eliminate poorly performing employees. But then management's track record of correctly identifying such individuals without bias or labeling certain employees as "trouble makers" would most likely be allowed to grow even worse under the new system. -The proposed National Security Personnel System seems to be using the new terrorist threat as an excuse to dismantle the civil service system that has served this country so well for so many years. -From what I read it appears that classification determinations are excluded from the list of conditions of employment so now employees will no longer be able to contest or appeal their job classifications. Rather than eliminate this protection, why not simply better use the existing system and use job classifications as they are intended to be used under civil service? -What does national eecurity have to do with redefining a "confidential employee" which effectively will remove most if not all secretaries from being in the bargaining unit? -Limiting the number of job series to a few broad groupings will destroy the expertise built up in many specific areas, and result in misassignments further reducing the professionalism of our federal workforce.