| Comment Number: | OL-10506754 |
| Received: | 3/12/2005 9:36:09 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:
As a 20 plus year federal employee, I would like to take this opportunity to comment on the above referenced system. There is so much to comment on that I’m afraid it will appear that I am rambling, so please bear with me. In general, I cannot believe that such high ranking government officials would even propose such a system. If we all lived in a perfect world and personalities didn’t interfere with doing what is right, then maybe this type of personnel system might work. However, we don’t live in a perfect world and personalities do interfere with doing what is right. Additionally, there are too many references to “implementing issuances” and “…all provisions of this part be interpreted in a way that recognizes the critical national security mission of the Department. Each provision must be construed to promote the swift, flexible, and effective day-to-day accomplishment of that mission, as defined by the Secretary. DoD’s and OPM’s interpretation of these regulations must be accorded great deference.” The devil is, as they say, in the details, which are extremely lacking in this proposal. Specifically I object to: 1. Subpart A – General Provisions (Sections 9901.101-108) a. NSPS was not developed with employee representatives taking a meaningful part in the discussions as required by law. 2. Subpart B – Classification (Sections 9901.201-204) a. The apparent elimination of job descriptions and qualifications. I chose the career field I currently work in and do not want to become a general employee assigned to whatever job the Secretary feels needs to done at any given time. 3. Subpart C- Pay and Pay Administration (Sections 9901.301-373) a. The employee’s pay increase (or lack thereof) is wholly based on their supervisor’s rating of the employee. Furthermore, the pay increases may not be available if money is needed elsewhere. 4. Subpart D – Performance Management (Sections 9901.401-409) a. The new regulations call for “attitude” and “teamwork/cooperation” to be a tracked and measured aspect of an employee’s performance. As a local union representative my “attitude” has been brought into question numerous times. Any question of management’s actions can be construed as an “attitude problem” and therefore be detrimental to the employee. Including questioning the frivolous or wasteful spending of allocated funds. What will this do to the fraud, waste, and abuse reporting system? 5. Subpart F – Workforce Shaping (Sections 9901.601-611) a. Employees may be deployed overseas at any time with little advanced notice without appeal, and may lead to dismissal if not agreed to by the employee. If I had wanted to participate in this type of assignment I would have remained in the Armed Forces and not become a civilian. 6. Subpart G – Adverse Actions (Sections 9901.701-721) a. Employee termination under Mandatory Removal Offenses, which are not defined, cannot be mitigated by anyone except the Secretary of Defense. How often do you think that will happen? These are just some of my objections to this new system. I sincerely hope that someone will stop this insanity before there becomes a huge exodus of experienced employees.