| Comment Number: | OL-10508138 |
| Received: | 3/14/2005 6:42:38 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 am a career civilian employee of DOD and I have serious problems with the NSPS as proposed in the February 14 Federal Register. My specific concerns relate to the proposed new rules on Pay and Pay Administration. 1. The proposed rules contrain the potential for a serious conflict of interest. Nothing in hte regulations prohibit supervisors and other managers from being placed in the same pay pools as non-management employees. This means tjat supervisors could compete against employees they rate for the same pay pool funds. This is an obivious conflict of interest. 2. The proposed rules contain the potential for abuse of pay pool funds. No limits exist on the amount of pay increases, bonuses, and other awards that management can award themselves or others (favored by managers), leaving little or nothing for the remaining employees in the pay pools. The proposed rules do not assure that funds will be allocated fairly. 3. The proposed rules allow for the possibility that my pay could be frozen even if my performance is rated satisfactory or better. This could happen to a fully successful employee's pay with the use of "control points", which can be implemented in each pay band to freeze salaries at a certain level. If a control ppoint were set to require an employee to recieve the highest rating to be awarded a pay increase, employees who get the 2nd highest rating and lower would recieve nothing, and their pay would be frozen, possibly for the rest of their career. This is clearly unfair, and would result in distrust of management, decreased morale, and lower productivity, ultimately harming national security. In my view, no changes should be made to the current pay system used by DOD agencies until complete and detailed proposals are provided, and a full comment and review period is completed, followed by a full collective bargaining process with the unions representing DOD employees.