Comment Number: OL-10506917
Received: 3/13/2005 9:18:04 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:

Relationship to the Dept. of Homeland Security, pg. 753: There have been no past indication or evidence that the current personnel system impacted national security negatively. . Since the National Security Personnel System has been proposed, I believed those with 15 years or more of service should be grandfathered in to allow for those employees to opt out of the new system and elect to remain in the current personnel system until our retirements. Process Leadership, pg. 7554: 30 Senior experts were selected who created this proposed new personnel system over 3 weeks. Who were they? What were their qualifications? Outreach to Employees, pg. 7556: I was not afforded my input prior to the NSPS website being publicized to me on 2/24/05. Subpart A, Sec. 9901.102, Eligibility and Coverage: Certain jobs should be exempt because performance is not objectively measurable. Subpart A, Sec. 9901.103, Definition: This vests to much control and discretion in one individual. This really runs afoul of due process and this should be reviewed by a court. Subpart B, Sec. 9901.211: Career Groups. This is too too vague. Subpart B, Sec. 9901.221: Classification Requirements: DOD should be required to specify how and when they will develop a methodology. Subpart B, Sec. 9901-222: Reconsideration of Classification Decisions: The implementing issuance needs public review and comment to be legally effective. Subpart C, Sec. 9901.302: Waivers: Request grandfathering provision for long-term employees and provide waivers or exemptions for certain professions. Subpart C, Sec. 9901.311: Major Features: The implementing issuances appears to be legally inappropriate unless the public can review and comment on those issuances. Subpart C, Sec. 9901.321 - 323: Setting and Adjusting Rate Ranges: This section is too vague. There is no substantial evidence that pay banding is better than the current GS ssytem. Subpart C, Sec. 9901.321 -323: Local Market Supplements: The Federal Pay Comparability Act should eliminate the need for these provisions. Subpart C, Sec. 9901.341 - 345: This section lacks sufficient details. I am totally ouraged and against the Pay-for-performance issue. I left the corporate world because of the abuses I witnessed on a daily basis due to this issue. Favoritism and cronyism runs rampant in the corporate world. It is demoralizing to subject us to this abuse. If DOD supervisors and managers can not seem to grant awards without playing the same game; I do not expect them to do any better when it comes to pay-for-performance. Most new supervisors are in training more than 80% of their time. They really don't have a clue as to how well their individual subordinates perform. These supervisors will reward the ones who toot their horns the most. They will reward the ones who socialize with them the most. They will reward the ones who appear to work so much overtime (whether it is needed or not). They will reward those who dressed so well or are so attractive. They will reward those who do not rock the boat with quality work; they will reward for quantity output in lieu of both quantity and quality. Many jobs, especially professional positions, involve significant judgment calls and discretion, and deal with intangible issues which are much more difficult to measure. The shy, quiet, competent employees will rarely be recognized for working hard and smart; just the extroverts who spend so much time politicking. Supervisors call this networking. As a result, this breeds insecurity and discrimination as well as potential needless lawsuits. I am more concerned for the senior and disabled employees. Pay-for-performance destroys the concept of teamwork in which the government has tried to instill in all of us over the past 10 years. Subpart F, Workforce Shaping, Sec. 9901.607 Due to this being limited to 4000 characters I can not proceed with further comments.