Comment Number: OL-10504492
Received: 3/9/2005 2:51:17 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:

First, I've got to say I agree that the system needs an update and a pay-for-performance (PFP) system *could* go a long way in retaining the best and getting rid of those who don't pull their weight. I am concerned, however, in how PFP will be implemented. I work in a support squadron where the primary mission on the installation is training, and I've already seen favoritism just in office furniture and technology purchases...why should I think that this favoritism won't extend to include giving the bulk of pay raises to instructors (leaving your superior support performers hanging out in the wind)? I can't comment on the PFP system since it doesn't appear to be developed yet, but I can't help but think there's a huge potential for abuse. What will be done to achieve some level of equity and get those pay raises to deserving individuals, WHEREVER they're assigned? Also, I didn't see anything stating the commitment to employee training (except for NSPS training). If you base pay on performance, funding must be made available to train your people so they can excel. I've been GS for almost 3 years (after retiring from the AF after 22 years) and most of what I've learned as a civilian I've had to teach myself. The AF has a tremendous training system to support its enlisted force; what will DoD do to support us?? Training is paramount in a system like this...you need to set the employee up to succeed! Concerning Subpart I, 9901.910, it's stated the Department can take action 'to assign employees to meet any operational demand' without advance notification. That reads like the Department can deploy employees anywhere (including war zones), at any time, with little or no notice. Civilians have always provided continuity to organizations with a nomadic military population; are we now being considered an expeditionary workforce? DoD has publicized for years they don't want to do short-notice deployments to the military, and here they are apparently advocating just the opposite for the civilian workforce. What prevents the abuse of such power? What procedures are to be used? What are the limitations/exclusions? My biggest cause for concern: DoD is on the fast-track to implement a system where little, if any, implementation guidance has been prepared. Too often throughout the proposal, I saw a statement like 'guidance to follow' or 'yet to be determined,' etc, etc. How do you expect to garner support from the workforce when we don't REALLY know what we're signing up to support?? I'll say again, I do believe the system needs to improve, and anything that can streamline some of the archaic processes for hiring, firing, incentives, etc, is a good thing. I also believe pay-for-performance has the *capability* to motivate the workforce. However, I strongly feel everyone needs to take a breath, get more of the implementation procedures out to the workers for review, and work with us to achieve a balance between the mission and the needs of the employees. Otherwise, all you're doing is ramrodding a new personnel system down the throats of a huge workforce that doesn't see the need for radical change. As it stands now, I can't help but imagine a mass exodus of civilian personnel angry with DoD for implementing a system where the rule of thumb is 'We'll get around to making the rules after the system is in place.'