| Comment Number: | OL-10506024 |
| Received: | 3/11/2005 10:28:53 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:
Federal Register / Vol. 70, No. 29 / Monday, February 14, 2005 / Proposed Rules National Security Personnel System (NSPS) Part II DoD OPM / 5CFR Chapter XCIX and Part 9901 Docket # NSPS-2005-001 RIN 3206-AK76/0790-AH82 If implemented, NSPS has far-reaching implications for all DoD employees and their families. The Federal Register, though sorely lacking detail, still reflects DoD's intent in establishing a new personnel system. The NSPS: provides DoD the ability to link basic pay and locality pay to factors that also include market conditions and budget constraints; increases the power and authority of supervisors and management in the performance review process - further exacerbating the existing flaw of supervisor favoritism; decreases the range and strength of union representation; changes RIF retention by putting performance ahead of length of service -- and more. Implementing just these personnel changes in NSPS will undermine the security and loyalty of dedicated DoD employees and, further, will serve to detract -- not attract and retain -- potential candidates from considering DoD as a fair employer and an employee-supportive environment. Specifically, I object to the following Pg 7559-7560 Adjusting Rate Ranges and Local Market Supplements “DoD will determine the rate range adjustments and local market supplements considering mission requirements, labor market conditions, availability of funds….Rate range adjustments and local market supplements may differ by career group, pay schedule and pay band. The minimum and maximum of a range may be adjusted at different rates. DoD may determine local market areas as well as the timing of these pay adjustments.” The labor market continuously changes - linking basic pay and locality pay to local market conditions (unemployment rates, for example) can negatively impact my ability to care for and plan for the future and well-being of my family. Linking pay and locality pay to availability of funds in DoD means that, in any given year, employees or select career groups, may or may not receive locality pay -- that is, when budgets are tight (and they're always constrained), locality pay may be eliminated or reduced across-the-board or for select career groups. With this uncertainty, I cannot plan for my family's future, because I will have no idea from year to year what my pay will be -- if I will or will not receive any locality pay. I also object to: Pg 7560 Rating Methodology: DoD “….The rater will prepare and recommend the rating, number of shares, and the distribution of the payout between basic pay increase and bonus, as applicable, for each employee. These recommendations will then be reviewed by the pay pool panel to ensure equitable rating criteria and methodology have been applied to all pay pool employees. …. The final determination of the rating, number shares, and payout distribution will be a function of the pay pool panel process and will be approved by the pay pool manager.” The pay pool manager is vaguely defined in the FR; in practice, s/he is an undefined person at an undefined location. Under NSPS, despite my supervisor's performance payout recommendation, as well as that of the pay pool panel, it is the pay pool manager who makes the final decision. The pay pool manager determines my basic pay and, ultimately, my retirement. The pay pool manager is likely to be subject to DoD direction related to payout distribution; bonuses are less costly than increases to basic pay and this can be significant when budgets are constrained (and they're always constrained.) Again, my pay and my retirement are very uncertain under NSPS. I can't plan and I'm less secure than ever before. Bottom Line: The NSPS holds no benefit for current employees -- top performers included -- and, certainly, is a disincentive to future employees. Who would even want to work for DoD under NSPS in the future?