| Comment Number: | OL-10504604 |
| Received: | 3/9/2005 6:50:56 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 a veteran and have 30+ years of federal service. I have experienced and seen much discrimination, nepotism, and unfairness during the course of my employment. I have endured all of the BRACs and have been in one RIF that abolished my job. Because of the RIF I was placed in a situation where I had to use my veteran status as a means to achieve fair treatment. The federal government is based on the merit system but I have seen the least capable people e.g., those who could not read or write or those who had no people skills get promoted. Once promoted, these supervisors and managers work feverishly to get their friends and family promoted. The NSPS will only increase this behavior. I believe that the step increase system currently in place guarantees that increases can be expected despite the politics. In order to be fair and provide equality, at a minimum the step increase system should be retained. I see the possibility for even greater unfairness in the new system with even less recourse for a workable grievance system. I currently have a Congressional Inquiry, Second Step Grievance and a formal EEO Complaint filed because of the aforementioned. I have only filed two EEO and two Union grievances in my entire career. Is there a guarantee that politics will play a lesser role in the new system? With this new system it appears that politics will flourish. It also appears that mismanagement will increase because management’s discrimination, nepotism, and unfairness will be allowed to run rampant and unchecked if this system is implemented 100%. The following applies: a. Subpart I Labor-Management Relations – 9901.901 to 9901.929: There is no sound reasoning being identified to take away the majority of the collective bargaining rights or grievance procedure rights available to employees. Creating a management dominated dispute panel will not solve issues but only create management/bargaining employee problems. b. Subpart G Adverse Actions – 9901.701 to 9901.810: Any unreasonable decisions that impact an employee’s employment requires the current standards to be followed in order to be fair and equitable. c. Subpart F Workforce Shaping – 9901.601 to 9901.611: In order to be fair and reasonable, current Reduction In Force rules should be retained. The current system uses an employee’s performance and years in service as a fair and reasonable measure for determining retention. d. Subpart D Performance Management – 9901.401 to 9901.409: In order for management not to be able to create an atmosphere of unfairness, employees will require an avenue to appeal any performance rating to an independent grievance process. e. Subpart C Pay, Sections 9901.301 to 9901.373: DOD employees should be allowed to continue to receive annual pay increases. Without definitive guidelines and guarantees, management will be able to use pay as reprisal vice a reward. In conclusion, without checks and balances the workforce will suffer, management will eventually be impeded and DOD will have created an unfair and biased work environment by using the NSPS.