| Comment Number: | OL-10506568 |
| Received: | 3/11/2005 8:38:26 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 believe the NSPS as proposed will hurt DoD employees, the DoD itself and the country. As a Federal employee I am particularly concerned with provisions related to Performance Management and Pay Bands. As to Performance Management, the goal is flexiblilty but the authority given to management is so broad and arbitrary that it will likely open the door to favoritism and de-emphasize the importance of job skills, education and experience. Even constructive criticism and questioning of supervisory authority may have repercussions. In addition, grievance procedures for keeping such abuses in check will be weakened. As to pay banding and pay pools, as I understand it pay raises will become less certain and more arbitrary. Rivalry among employees competing for the same dollars will hurt team activities and hinder the accomplishment of Agency missions. In the end, these rules, which are supposed to improve management flexibility and increase productivity by stimulating competition will lead to resentment, poor DoD staff morale and high turnover. The high turnover will in turn hurt Agency memory which is important in carrying out long-term projects or learning from previous mistakes. The DoD's mission of keeping the country safe from outside threats is too important to be jeopardized in this way. These proposed NSPS rules should not be finalized without considerable revision.