| Comment Number: | OL-10506753 |
| Received: | 3/12/2005 9:29:18 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 writing to express my concerns about the changes to work rules in the Department of Defense (DoD). The proposed regulations, known as the National Security Personnel System (NSPS), were printed in the Federal Register on February 14, 2005. This message will be sent to both DoD and my representatives in Congress. I am very upset by NSPS. This current proposal treats the employees who help defend our country unfairly. Most DoD employees work hard and are committed. Abusing those employees will only hurt the agency’s mission. This system will change the way workers are paid, evaluated, promoted, fired, scheduled, and treated. These rules would create a system in which federal managers are influenced by favoritism rather than serving the civil concerns of the American people. The current proposal eliminates annual pay raises. The military has automatic pay grade increases for the lower grades. This is not true for the federal employee. The federal employee cannot increase their pay grade unless they apply for a job with a higher grade or their position is upgraded. The steps between each pay grade encouraged good federal employees to remain in service. It allowed the employee with limited skills to remain in a job they are suited and can excel. As with both systems, a leader, supervisor, or manager may stop a pay grade or step increase based on job performance. The proposed system leaves that decision entirely up to 2-3 persons. This could result in cronyism, political maneuvering, or reprisal. Rather than change to a new system, enforce the current. Ensure supervisors are counseling their subordinates. Ensure management is in agreement with a pay increase. A system is in place but is not enforced. The problem is not with the system but with its administration of the program. There is no guarantee the new system will. DoD proposes an awards program. However, DoD has not and does not fund an awards program. The current system allows a leader, supervisor, or manager to award an exceptional employee a pay increase. These awards were not automatic. The current system is dependent on budget, and concurrence by higher management. In recent years budgets have been reduced and/or taken entirely back. Since the purpose of this proposal is to reduce payroll costs and the agency’s miserable record on this issue there is no “incentive” for the federal government to provide that in a budget. Therefore, there is no insurance that salaries and bonuses will be funded in the future. The new plan will reduce cohesiveness. An award for exceptional service will be decided by a “share” system to be decided solely by the personal judgment of his or her supervisor or manager. This is similar to the system that existed in Russia. I am not comparing this country to Russia but simply pointing a similarity in the new proposal. That system resulted in “Yes” people. The only way to get ahead was to detract from another employee. Those within the “party”, clique, or inner circle were rewarded. This is what the new system offers. It will create an atmosphere in which employees will not trust one another, be afraid to speak out about harassment, violations of the law, and workplace safety problems in fear of reprisal. Workers will compete for pay raises since this will be the only way to get a pay increase. The new proposal does guarantee that the best workers will receive a pay raise. Those in agreement with their supervisor or manager will. Some of this presently exists. Many times an employee must recommend or inform their supervisor of actions that supervisor “may not want to hear” but “needs to hear.” Rather than develop a new system why not improve the current. In the end government work will suffer by poor or that the pay offered will be fair or competitive. Furthermore, there is no provision for an impartial appeal system. The new regulation will change job descriptions to more general terms. This will allow leaders, supervisors, or managers to increase the responsibility of an employee without a provision for a fair and equitable pay. There will be no system to ensure a fairness of job responsibilities. This will make it possible for leaders, supervisors, or managers to cut the pay or dismiss an employee that does not meet the new goal. This could also result in some managers passing down their work load to subordinates while still being paid for that level of work. A good worker could receive a pay cut or be dismissed by not meeting a goal that was not originally their responsibility when they came into federal service. The new proposal will affect job security for the federal employee. I agree in spirit that performance should count first. But if a person has worked for 25 years in government service what is there that will protect him from termination. I am not suggesting keeping someone who is not performing satisfactorily. This type of person should have been terminated earlier in their career. Those of us currently in service will be most affected. It will create an atmosphere of the young dog. The younger employees will be valued more due to their retirement date. They will essentially be pushing out the older employees. Management will not have any incentive of employing an individual to retirement. This already occurs in the private sector. There will be no guarantee that a federal employee will come to retirement age and collect benefits. This proposal will force out good employees. The employee who is proficient at their job and is not afraid to make sound decisions will not be encouraged to remain in service or, for that matter, enter federal service. This will result in a work force of individuals who are not completely competent and will not tell their leaders want they “need to hear.” This will cause leaders, supervisor, and managers to keep inferior workers since there is no one else is available. When this occurs, government productivity will decrease and result in contracting out the work. Although this will dismiss government’s responsibilities it will not reduce cost of service. The government will then be at the mercy of the contractor. Currently, contracts are written for the benefit of the contractors. Government Contract Representatives (COR) of those contracts are not trained properly. In many instances there do not know or understands the scope of the contract they oversee. The contracts the COR write do not reflect the best interest of the government by ensuring NSPS will allow managers to schedule employees to work without sufficient advance notice of schedule changes. Work loads have been increasing while work force has been decreasing in the past few years. This will mean abusive managers can harass employees with bad schedules or short notice. Working parents will be forced to decide between their employment and care for their children and family. This country has prided itself on its ability to maintain the work force without personal sacrifices of it s employees. This new plan will reduce that. This proposal will save money for the government. However, it should not be at the expense of only of a specific tier within the federal government. This proposal does not affect the higher executive, legislative, and judicial branches. This proposal has been designed and will be decided by those it does not affect. Personally, I believe the federal government can save money by limiting and/or reducing pay to the legislative branch, reduce staff requirements, require that branch to work as many years (currently 30) as the average federal government employee for retirements benefits, and reduce current travel and daily expenses. Ultimately the goal of this regulation is to save money and to consolidate power. To some extent, I am in complete agreement. However, I do not believe the goal is to keep the “good employee”. It is not designed to preserve the work force. The plan is designed to reduce incentive, cohesiveness, and job security. It will promote cronyism, the “good ole boy network.” It will not ensure an atmosphere for employees to question their supervisors or tell them what they “must hear.” This has been the hallmark of American industry - the ability of an employee to object and not fear reprisals. New pay regulations should provide protection for both the government and the employee. Rather than creating a new system which will cost time and money, ensure the proper administration of the current system. This will be is a more cost effective and equitable to all in the government service. America is at war. We are fighting for democracy abroad. But the regulations are an attack on workers’ basic rights. Furthermore, NSPS will divert the attention of defense workers from the soldiers’ welfare to protecting themselves from abuse on the job. I urge you to force DoD to rethink this proposal. We need work rules that preserve fairness, serve the American people, and respect the rights of Defense Department workers. Sincerely yours, John L. Cicilese