| Comment Number: | OL-10507557 |
| Received: | 3/14/2005 12:22:02 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:
Defense Secretary Donald Rumsfeld told Congress, "...current rules [DoD current civil service system] have hindered the department's ability to recruit talented employees. He said managers often turn to private contractors or assign military personnel to perform tasks that would be better handled by civil service employees." This statement is not entirely correct. The Defense Finance & Accounting Service (DFAS) has a very successful Entry Level Professional Accountant (ELPA) program. The ELPA program is used by DFAS to recruit talented employees with accounting degrees. These ELPAs are very bright, and will be the leaders of DFAS in the future. Mr. Rumsfeld's statement about using contractors and military personnel as evidence the current civil service system isn't working isn't correct either. The reason agencies rely on contractors and military personnel to fill civilian federal jobs is because each agency within DoD is restricted by the Office of the Secretary of Defense in the number of civilian work-years (civilian employees) they are authorized to employ. However, contractors and military personnel do not count against these limited civilian work-year allocations. DoD agencies with work requirements, and no available work-year allocations, rely on contractors and/or military personnel to accomplish the work. I believe Mr. Rumsfeld is using these false arguments to switch from the current civil service system to the National Security Personnel System (NSPS) in order to dismantle federal employee protections provided by the current system. Congress enacted the current civil service system decades ago to protect federal employees from unfair labor practices. Under the current civil service system, federal employees are protected from supervisors who want to adversely impact a federal employee's career and/or pay. Under the current civil service system, supervisors cannot arbitrarily reduce federal employees' pay. Under the current civil service system, a federal employee cannot be fired from their federal job without just cause. Under the current civil service system, a federal employee's years of loyal service protect the employee during a Reduction-In-Force (RIF). Under NSPS, federal labor unions will have no power to protect federal employees from supervisors who want to adversely impact a federal employee's career and/or pay. Under NSPS, decades of federal employee protections against unfair labor practices will be removed. Under NSPS, a supervisor will have the authority to arbitrarily reduce a federal employee's pay. Under NSPS, a federal employee can be fired without just cause, and without employee recourse. Under the NSPS, a federal employee's loyal service and seniority will not benefit them during a RIF. Congress must take a hard look at what the NSPS will mean for federal employees. Does Congress really want to return the federal workforce to an era were federal employees had no protections from unfair labor practices? Does Congress really want DoD political appointees and supervisors to have the power to fire a federal employee without certain "checks and balances" in place? Does Congress really want DoD political appointees and supervisors to have the power to reduce a federal employee's pay based solely on subjective opinions? Does Congress really want DoD to have the power to "reshape" the federal civilian workforce without congressional oversight?