| Comment Number: | OL-10508100 |
| Received: | 3/14/2005 6:00:09 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 have specific concerns about erosion of employee protections that we as civil service employees have come to reasonably expect; examples being the possibility of what I call a 'strategic' reduction-in-force action to eliminate or 'lay off' individuals from from federal service irregardless of their tenure or capability to assume duties in an organization outside the RIF area (sect 9901.910 (3)); another concern is the proposal allowing Mgt to override or ignore any union agreement- If Mgt can do this, why would we have union agreements? Union agreements afford a middle ground between barganing unit employees and management and have proved basically effective in the professional environment. Implementing this new possibility of a 'what management says goes' philosophy will erode workplace trust and subsequently production (sect 9901.905);Another area that needs relooking would be the option to reset pay (incl lower pay) on a reassignment to a new position in the same pay band. This practice in any situation other than less than successful performance is blatantly unfair since employees count on stable salaries for financial obligations, namely mortgages, tuition payments,etc. If lowering pay of successful performers on reassignments is not the intention of the NSPS, then this needs to be clarified. IF IT IS an option in the NSPS for successful performers to move back in their pay scale, I strongly disagree with this mgt option. (sect 9901.352); I have similar concerns regarding no cost of living raises under the NSPS. I understand the basic concept that if the lower end of the pay band is increased, then the salaries therein will be increased but this is not referred to as a COLA. The same principle would apply if the lower end of the pay band were decreased as well As a federal employee for almost 25 years, I have been able to count on some kind of COLA to accommodate ever increasing costs in insurance premiums, gasoline, tuition, food, etc. The federal Govt is not a small business and a COLA is a reasonable expectation. (sect 9901.322) Lastly, Is it really fair to ask federal employees to bless a new personnel mgt system without publishing the paybands? I think not! Pay band grouping of series and grades can significantly affect career paths and are a major part of any pay banding system. IF the paybands have not been defined then it is definitely too early to approve the NSPS. Overall, without significant concessions on mgt employee rights and responsibilities I non concur with the NSPS.