| Comment Number: | OL-10507775 |
| Received: | 3/14/2005 2:59:03 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:
I've read through every fact sheet and presentation, as well as the actual NSPS regulations. After doing so, I feel that the published regulations have several main points, none of which seem to be to the benefit of the employee: 1) Granting authority to the Secretary of State and the Department to dictate any future changes in the form of "implementing issuances." These implementing issuances contain the bulk of actual changes that might be used to form an opinion about whether the NSPS as a whole is good or bad. The sheer number of issuances that have yet to be made makes it clear that the current phase of the NSPS is not about informing the employees, but about fulfilling other purposes as listed below. 2) Reducing the power of collective bargaining and other impediments to the Secretary of State and the Department. It is my opinion that the Department feels that any barrier to their will should be removed or mitigated to the maximum extent possible. The section on collective bargaining is one of the very, very few areas where actual numbers, time periods, and processes are outlined (as opposed to requiring an "implementing issuance"). This makes it clear that this is the only important part to get through /first/, before going through and making further sweeping changes. 3) Drastically reduce the number of government employees with the goal of saving money. Money also appears to be at the core of the NSPS. A great number of the people who dislike this new pay-for-performance system have the ability to retire, now or by the time the NSPS is implemented at their site. The NSPS, then, will be one more push out the door to force old employees under different retirement systems to leave, and to "correct" practices that are costing the government more money (by providing more benefits to employees). It also greatly streamlines the firing process, making it much easier to reduce the number of employees on a consistent and long term basis. I see this as the destruction of the government's internal knowledge, and feel that the great many contractors, who will only be increasing in number, will continue to suck out more money and leave at the term of their contract with all the knowledge the government needs to continue. This dependency on contractors will grow, and the noticeable effects will worsen in every aspect except the current, yearly budget. These three main goals, while perhaps beneficial to the bottom line over the next 10 years, will drastically effect the morale and work output of every employee within the Department of Defense. I highly doubt that it will be for the better, even with the extremely limited amount of information the Department has released so far. Management does not want to spend their time rating employees. They will not have the time or resources to do so, not with even fewer employees meeting even more stringent budgets with greater oversight and more regulations to follow. Do more, with less resources, following even more regs. This is not a formula for success in the long term. Please fill in every occurance of "implementing issuance" with actual information, and require an additional 30 to 60 days of review. Then, perhaps, you will receive truly informed opinions about what the NSPS is trying to do, and will find just how many flaws it surely contains.