Comment Number: OL-10506554
Received: 3/11/2005 7:15:08 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 am submitting comments on the newly proposed National Security Personnel System. As a DoD employee with thirty-two years of experience, I am saddened by the NSPS proposals to decrease DoD employees standard of living, to take away our job security, and to change our work life. With the new pay system, which DoD calls pay for performance, the amount of a worker's salary and pay increase will depend almost completely on the judgement of the employee's manager. There is no guarantee that even the best workers will receive a pay raise or that the pay offered will be fair or competitive. 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. In other words, DoD gives itself the right to lower overall payroll amounts to less than other federal agencies. Further, DoD's record in funding pay for performance pilot programs and even pay programs for its executives is poor. Together with Congress 's unwillingness thus far to "prime the pump" with money for the Government's best, the record and signals sent all point to a potentially dismal program that rewards few at the expense of everyone else and motivates fewer. The new rules state that if RIFs occur, the decision of whether to keep an employee will depend first on his/her performance appraisals, which are issued by supervisors. Those employees with the best ratings will be kept. Those with lesser ratings will be let go. Only in the case of a tie between employees will a worker's seniority be considered. Apparently, in the last decade with minimal hiring and the loss of significant numbers of civilian DoD positions, the experience drain has not been enough for DoD management who proposed these rules. Expect high employee turnover to be a grand result and less loyalty to the organizations with profound impact on continuing programs. Under these proposed rules working conditions will change allowing federal employees to be deployed anywhere in the world, even a war zone, with little or no notice. Whereas, current law prohibits civilian employees to be involuntarily assigned against the conditions they were hired. This will make it difficult for working parents and others who care for loved ones and have personal obligations at home. NSPS will weaken unions and the rights gained through union contracts, such as work schedules, and overtime rotations. NSPS will allow managers to schedule employees to work without sufficient advance notice of schedule changes. This will make it extremely hard for working parents and others to fully take advantage of daycare for their children or elderly parents. It will mean that abusive managers could harass employees with bad schedules or short notice, or threaten their pay. Overtime rotations can be canceled, which means that employees may not be able to adequately plan for childcare and other responsibilities. The current personnel system for civilian employees is not perfect by any means, but it does not deserve dessimation and the policitization that would occur with NSPS.