| Comment Number: | OL-10505947 |
| Received: | 3/11/2005 9:52:26 AM |
| 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:
NSPS is an outrite attack by the current administration to weaken 60 years of labor law. They (the current administration) are systematically attacking the labor unions of the United States. They are starting with the unions of the federal government and have made inroads into the teachers unions using “No Child Left Behind” But that is another issue. They are using a smoke and mirrors strategy with NSPS. The smoke is that the unions are to strong and we promote shiftlessness in the workplace by defending pore performers. Then the panted mirrors that are shown to the public, unions are bad for the country and we need drastic changes. DoD already has the ability to do everything proposed in NSPS Subpart C Pay, Sections 9901.301 to 9901.373 The employees in DoD should continue to receive the same annual pay across-the-board adjustment that other GS/FWS workers receive. The individual pay increases for performance should include guaranteed percentages in the regulations so that employees will understand the pay system and what their pay increase will be depending on their performance. There is a pay for performance system in place now. It is called the awards program. Managers have the ability to reword above average performers with monetary incentives. This is an under utilized program where we see managers getting large awards for doing great and wonderful things and workers getting scraps. Pay for Performance will not change this practice; it will only serve to make it an even more accepted practice. Subpart D Performance Management 9901.401 to 9901.409 In order to insure fairness and accuracy, DoD employees should be able to appeal any performance rating to an independent grievance and arbitration process. There is also performance Management in place with the present system. It is called Total Army Performance Evaluation System (TAPES). I would venture to guess that the other services of the DoD have a similar evaluation system in place. This system works well, when managers do their job and use the TAPES correctly. The system has in place a means to adjudicate disagreements to a third party if needed. NSPS strips labor rights by doing away with this independent third party. Subpart F Workforce Shaping - 9901.6012 to 9901.611. DoD should not change the current layoff/RIF rules which give balanced credit to performance and the employees valuable years of committed service to DoD. Congress has a seniority system! Subpart G Adverse Actions - 9901.701 to 9901.810 Due process and fairness? Without an independent body review their are no checks and balances. The current standards approved by the courts to guide such bodies should continue to be used. A manegement abointed internai board of revew can only serve to promote cronyism. Subpart I Labor-Management Relations - 9901.901 to 9901.929 The labor management law that has governed the employees’ right to organize and engage in collective bargaining has worked well since 1978. There is no compelling reason to take away most of the collective bargaining rights or grievance rights. DoD should not create a “company dominated dispute board.” Any dispute board must be “jointly selected” by management and the Union. Civilian Deployment: Federal employees could be assigned anywhere in the world, even into a war zone, with little or no notice. This will make it difficult for working parents who care for a family and have personal obligations at home. Is it too much to ask that I be guaranteed sufficient notice to plan for such assignments? Are all civilians going to become just like the military?