| Comment Number: | OL-10506794 |
| Received: | 3/13/2005 9:17:28 AM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| Attachment: | Coments on NSPS system.doc Download Adobe Reader |
Comments:
Program Executive Office National Security Personnel System Attn: Bradley B. Bunn 1400 Key Boulevard Suite B-200 Arlington, VA 22209-5144// Dear Sir:// I am a career civilian employee of the Department of Defense and I have serious issues/questions with the “National Security Personnel System” as put forward in the February 14 Federal Register. My three specific concerns relate to the proposed new rules on Pay and Pay Administration (Part 9901 Subpart C). 1. The proposed rules contain the potential for a serious conflict of interest: Without specific guidelines, there isn’t anything to keep supervisors and other managers from being placed in the same pay pools as non-management employees. With that being said, what will regulate supervisors competing with the employees they rate (and provide pay increases and bonuses to each year) for the same pay pool funds. Thought the NSPS was going to institute a more fair system. Feel like we are being sent to the wolves. Supervisors could intentionally hold down the ratings, pay increases and bonuses of employees to ensure that more funds are available for supervisors and their bosses in the pay pools. How does this “respect the individual”. 2. The proposed rules lack the needed details to protect us from the potential for abuse of pay pool funds – No limits are mentioned on the amount of pay increases, bonuses, and other awards that supervisors/management can give themselves or others (favored by managers), potentially leaving nothing for the remaining employees in the pay pools. These new “streamlined” rules do not assure that funds will be divided fairly. If managers and top performers are awarded large pay raise increases, bonuses, Extraordinary Pay Increases (defined in section 9901.344 and on 7560), Organizational Achievement Recognition (described on page 7560), and other payouts from pay pool funds, the pools could be depleted, leaving nothing for the employees at the bottom like me. This will turn into a system of who likes who. We are all humans and therefore not perfect and as proposed this system WILL have dire consequences if the guidelines are not specific. 3. The proposed rules allow for my pay to almost probably be frozen even if my performance is rated satisfactory or better. This could happen to a fully competent/successful employee’s pay with the use of “control points”, which can be implemented in each pay band to freeze salaries at a certain level. Section 9901.342(d)(3) states: “DoD may provide for the establishment of control points within a band that limit increases in the rate of basic pay. DoD may require that certain criteria be met for increases above a control point.” If a control point were set to require an employee to receive the highest rating to be awarded a pay increase, employees who get the 2nd highest rating and lower would receive nothing, and their pay would be frozen, possibly for the rest of their career. This is clearly goes against the advertised “pay for performance” to put these limitations on the pay system, and would result in distrust of management, definite morale decline, and lower productivity, ultimately harming national security. It comes across as insulting when NSPS says they’re going to “preserve the core enduring values of the Civil Service” by putting in place such an obviously one-sided plan, especially when legitimate questions can NOT be answered. In my view, no changes should be made to the current pay system used by Department of Defense agencies until complete and detailed proposals are provided, and a full comment and review period is completed, followed by a full collective bargaining process with the unions representing DoD employees. Sincerely, Kent Sterling International Aircraft Clearances, 18th Air Force, Tanker Airlift Control Center Scott AFB, IL. 62225, (618)229-3008, DSN 779, Fax 0154