| Comment Number: | OL-10507757 |
| Received: | 3/14/2005 2:47:50 PM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| Attachment: | NSPS specifics.doc Download Adobe Reader |
Comments:
I know you will get many, many comments from current personnel in opposition to the new system. I’m trying to not take the new regulation personally and to review the regulation with objectivity but find that’s impossible as it will be our governing directive for years to come. My comments are provided in an attempt to highlight issues I believe are important. I do not believe this system should be implemented and feel the current system could be adapted to fix problems of concern to DOD without designing a completely new system and implementing it on such a huge scale without adequate testing. The impetus for this was supposedly 9-11. I saw nothing after 9-11 that showed the DOD wasn’t prepared. In fact it was just the opposite. I believe there are many good things about the current system, however, I believe it could use some changes in the way we hire, fire, and reward high performing employees. I believe changes could be made more easily in the current system than to completely throw out the current GS grade and step system for a new, untested system of pay banding. A pay banding system, to me, is untenable. The whole tone of this document is insulting to all employees. Additionally, I believe 30 days is insufficient time to review and provide comments. I do think that Civil Service has difficulty in attracting and hiring some fields that earn substantially more in civilian agencies than they do in Civil Service. I think an annual bonus of some sort could exist for this. There does need to be changes in the way the hiring is accomplished when it takes forever to just get the job announced via the normal hiring procedures. To think we are going to be able to hire doctors, nurses, computer personnel, etc., and pay them what they can get on the outside would seem to mean that many, many other personnel would have to be eliminated to make up the substantially higher pay for these folks. Changes should be made in the way we can currently fire our employees, i.e., withhold annual salary increases or simply move the employee to the next lower GS grade if they are doing unacceptable work. The cash award money after the annual rating period is presumably to go to the better performers and perhaps some changes need to be made to this system to be better able to reward high performers. I am also concerned with individuals such as myself who may perhaps be at the top of a pay band when they decide those. Where is the incentive (i.e., the annual Congressional pay increase and/or cash award that I have now) for me to do the best job I can? Under this new system it appears there will be no monetary compensation unless you get promoted to the next band. This situation (where personnel are at the top of a pay band) could actually be a disincentive for civilians who have been here a long time, who are the most knowledgeable in their jobs, and may, in fact, be the most productive. I do believe longevity should account for something. We are not just sitting here biding our time until retirement. I feel all that experience is excellent and it comes into play every time we get new, lower grade officers into the headquarters from out in the field (which is a very often occurrence). Each and every day we work with these officers and train them on how to properly do staff work and interact with other internal and external agencies. I’m also very concerned with how we plan to hold the supervisor accountable in a new system they will have to learn. Most of the supervisors I’ve seen had a hard time with an old system that has been around a long time. Specific comments on these issues are attached.