Comment Number: OL-10506197
Received: 3/11/2005 12:27:30 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:

Reference supplementary information: The Case for Action – page 7553 How does 9/11 have anything to do with personnel systems, hiring and firing policies, bargaining rights or raises? How do any of these personnel issues have to do with national security? Mobility and deployment are words that are used in the document over and over. They are harmless words by themselves but within this context it seems like DoD, by implementing this new system, wants to be able to move civilians at will whenever and wherever they think they are needed. There is no mention of PCS in these areas of the document. This will result in mass exodus of people from DoD, not towards it. This system allows for the "buddy" system for promotions and raises. Examples: If a person is an excellent performer but is not a "favorite" of the boss, they won't get a high rating and therefore little to no raise. If a person is a poor performer but is a "favorite", they will receive a raise regardless of performance. It makes raises and promotions much more subjective, much less objective. Performance Management – Subpart D – page 7561 The modifying, amending and changing of performance and/or behavioral expectations at any time within the year places an unfair burden on both the employee and management. This does not allow for stability within the workforce. Employees will constantly be on their guard just in case management decides to change something just for the sake of change or because higher level management tells them to do so. Adverse Actions – Subpart G 3. Adverse Action Procedures – page 7565 There should be a requirement for a formal, set period for improvement. Employees should not just have adverse actions slapped on them without knowing what the set time period for improvement is. This should not be deleted from the current regulation. E.O. 12866, Regulatory Review – page 7573 I would like to know who the "significant public" is that has an interest in the Federal employment system. I do not hear this as talk on the streets, in elevators, airports, etc. and I haven't seen any public opinion polls concerning this matter. It is not right that someone could come in off the street and make more money than someone who has spent many years in the government. Page 7574 What is the difference in the $158M expected cost vs. the cost of the present system? It is well known that an expected cost will usually go up significantly between the time of concept and the time of implementation; therefore, the $158M is most likely a lowball figure. When that happens, could the new system still be considered cost effective and in the publics best interest? Page 7574 It is rather insulting to current federal employees when it is stated that DoD wants to attract, build and retain a high-performing workforce and a more qualified and proficient workforce. That is like saying that the current workforce is inept and not qualified to be working for the federal government. Page 7574 The new system will most likely not generate respect and trust; it will most likely generate mistrust and animosity. Paperwork Reduction Act of 1995 (44 U.S.C. Chapter 35), page 7574 There will be more reporting and recordkeeping because the supervisors have to fill out more forms for appraisals and the pay board at each location will have to also have more forms and documentation. Throughout the supplementary information There is a lot of vagueness and undecided ness in this proposal. In most areas it states that DoD will establish this or will decide that. This leads the reader to believe that these decisions have either not been made yet or are published under separate cover. These issues should be decided in their entirety before launching a completely new personnel system. The government is notorious for implementing new systems without thorough thought being put into them. These systems then cost more and more