| Comment Number: | OL-10506538 |
| Received: | 3/11/2005 6:13:14 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 disagree with the basic premise of the implementation of the NSPS. I do not agree that a case has been made for this action. --“..current .. system is based on important core principles, those principles are operationalized in an inflexible, one-size-fits-all system .”//Disagree-If managers would take the time to utilize all the tools available the current system is not inflexible and can accomplish targeted goals. There is consistency in the current system which is not an adverse feature. --“…inherent weaknesses make support of the DoD’s mission..risky.”//Disagree-I would like to have explained in detail how a system that’s been in place for years is now a risk to mission. --“…high performers and low performers are paid alike”//Disagree-Cost of living is applied to everyone but bonus’ and Quality Step Increases award performance. Step increases can be withheld if an individual is not doing their job adequately and the manager has documentation to substantiate this situation. --“…labor system encourages a dispute-oriented, adversarial relationship between management and labor..”//Disagree-The labor system is simply a controlled environment in which parties are able to present the specifics of a situation and objectively arrive at a resolution. --“The attacks of September 11 made it clear that flexibility….must become the foundation of DoD civilian human resources management.”//Disagree-I do not understand the link between September 11 and the necessity for a complete overhaul of the federal government employee personnel system. If all the tools available in the current system were utilized, there is flexibility. --“NSPS is designed to promote a performance culture in which the performance and contributions of the DoD civilian workforce are more fully recognized and rewarded.”//Disagree-There is currently an abundance of awards with which to recognize the performance and contributions of the workforce, also a suggestion program to acknowledge new, creative ideas and efficiencies to existing procedures. --“… the limitations imposed by the current personnel system often prevent managers from using civilian employees effectively. The Department sometimes uses military personnel or contractors when civilian employees could have .. been the right answer.”//The use of contractor personnel as a percentage of the workforce was dictated to the commands by Washington. --The current RIF procedure, although not perfect, is much better than the proposed one. A RIF based on seniority cannot be questioned as seniority is an objective fact. It is difficult to apply a uniform performance criteria to all. It is easier to reward employees you work with most often and hold the more high visibility jobs. A RIF based mainly on performance takes a managers potentially biased opinion and uses that to determine if a person will have a job or not. My area has all exceptional employees. A person who must be RIF’d from this area could easily have a higher performance rating than someone not RIF’d from another area. Since all people in an area cannot be exceptional, a manager is forced to stratify performance. --Making positions instantaneously mobile is extreme, unfair, and abuses employees. There is difficulty filling EE/Mobile positions, it normally seems to attract ex-military. If all positions are EE/mobile, as you recruit you will ultimately end up with a certain type of personality. It is best to have a more diverse workforce. --I recommend looking more closely at the current system rather than going to the extreme of an entirely different system. If managers did their jobs (recommend intensive training) and used the tools available to them, it would be an excellent system and only in need of selective reform. The major overhaul which is proposed is not objective in it’s implementation. --For these reasons I oppose the implementation of NSPS.