Comment Number: OL-10505653
Received: 3/10/2005 10:31:41 PM
Subject: Notice of Proposed Rulemaking, Request for Comment
Title: National Security Personnel System
CFR Citation: 5 CFR Chapter XCIX and Part 9901
Attachment: NSPS Comments#2.doc Download Adobe Reader

Comments:

#1. I write to express my concerns about changes to work rules in the Department of Defense (DoD), and the activation of The National Security Personnel System (NSPS). #2. I have worked for DoD for years. I believe the NSPS will cause many DoD employees, who have helped defend our country, to be treated as an enemy. Most DoD employees work hard and are committed. I believe the NSPS will lead to mistreating employees and will ultimately hurt the DoD’s mission. This system will change the way workers are paid, evaluated, promoted, fired, scheduled, and treated. These rules would create a system in which federal managers are influenced by favoritism rather than serving the civil concerns of the American people. I believe the NSPS will allow an environment where abuse of the personnel system will become prevalent and fair treatment of the worker will become an after-thought - not the primary goal of the system. #3. 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 to be funded by DoD. In the past – as recently as just last year – DoD did not fund its awards programs very well. Given the agency’s miserable record on this issue, how can employees feel confident that salaries and bonuses will be funded in the future? #4. “Friend of the Supervisor” Pay System - With the new patronage pay system, which DoD calls “pay for performance,” the amount of a worker's salary will depend almost completely on the personal judgment of his or her manager. This system will force workers to compete with one another for pay raises and permotions. This will destroy teamwork, increase conflict among employees, and reward short-term outcomes. There is no guarantee that even the best workers will receive a pay raise or that the pay offered will be fair or competitive. The system will even lead to the loss of pay for some due to arbitrary methods of evaluating work performance. After all, there is no approved and published process for these evaluations, - none are available to assure fair worker treatment and protection. 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. #5. I served my country when I was called on in the past. I continue to serve with pride today. I should not be abused because some DoD bureaucrats have determined the existing personnel system was a burden to them. #6. America is at war on multiple fronts. On the one front we are at war with terrorists. On another, we seem to be at war with the leadership of the DoD. We are fighting for democracy abroad. But the regulations of the NSPS are an attack on workers’ basic rights. Furthermore, NSPS will divert the attention of defense workers from the soldiers’ welfare to protecting themselves from abuse on the job. #7 The Civil Service has stood for decades to serve the needs of America. Throughout that time of service there have been many battles fought in the courts and in Congress to assure fair treatment of those America depends on to serve the public interest. The results of those battles are the Merit Protection System and the rights and protections guaranteed by the Federal Civil Service personnel system. I believe the NSPS will make a mockery of the past battles fought to attain fair treatment for all workers. legislation/rules that sets broad parameters for performance criteria for an appeals process that preserves civil service neutrality are needed. I therefore urge DoD to rethink this proposal. We need work rules that preserve fairness, serve the American people, and respect the rights of Defense Department workers.