| Comment Number: | OL-10506773 |
| Received: | 3/12/2005 11:29:16 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:
My, and many of my co-workers, concern over the proposed NSPS is that there is very little business case provided for implementing many of the sweeping changes that have been proposed in the body of the policy's text. While most of us realize there are instances where poor performing employees should have been removed from federal service and were not (which frustrates us all), it seems that under NSPS all employees (the vast majority who are hardworking and dedicated) will be punished so that a few "bad apples" can be removed (while opening up all employees to the subjective whims of a flawed performance management system). And by implementing the NSPS, besides being unfair in terms of striping away merit principal protections of "well performing employees," the DOD will be hurting itself in terms of future competitiveness in its quest to attract its number one resource, talented people. Speaking of talented people: What sustainable competitive advantage will the DOD have over the private sector in terms of attracting the “best and brightest” talent (or even retaining the talent it has for that matter) when, as a whole, DOD pay is already lower than comparable private sector entities (Defense Contractors) Factor in the loss of most basic merit protections as a result of implementation of the NSPS and why would the “best and brightest” chose to come work for DOD? My friends and family that I have talked to about the proposed changes under the NSPS have said that it sounds like a losing proposition for employees and that if they were to consider Federal Employment they would do so at an agency that still had basic job protections and not DOD (due to the NSPS). So that leads to the question of why would the DOD want to implement a policy that would lead to other Federal Agencies having a distinct advantage in attracting the best of the best? Seems like this goes against one of the purported aims of implementing the NSPS. And as fact, based upon ever present budget constraints, DOD will never be able to match the pay of comparable private sector enterprises. It makes no sense from a business point of view. The end result, based upon the reasons stated above, is that the DOD will lose many great people to other Federal Agencies and will have even a harder time getting the best talent in an ever competitive labor pool. It seems like this isn't in the best interest taxpayers and the American public in general. While, due to time constraints, only looked at the impact on the recruitment and retention facet of implementing the NSPS, other areas such as changes to pay structure and performance management, seem to be equally lacking in their business logic. It seems DOD should have to provide solid evidence (a.k.a. a business case) for all the the proposed changes and how doing so will lead to greater benefit to the taxpayers (which I would say is a doubtful proposition under the NSPS). The American people, and specifically DOD employees, are more than willing to accept changes as long as the case can be made for a need for a change. There is no evidence in the policy of the proposed NSPS that I can find that establishes this need (based upon facts and figures and impact analysis). Congress should not allow implementation until DOD has done so.