| Comment Number: | OL-10508257 |
| Received: | 3/14/2005 11:00:50 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:
The NSPS regulations as published in the Federal Register contain only general guiding principles that will be interpreted and implemented by the various agency political appointees to their advantage. Since there are really no specifics to comment on, I will offer a few general comments. 1. Basically the way I see it, the NSPS is a flawed system that will be manipulated at the whim of the various agency heads. The NSPS cannot deliver on its promises to reward the exceptional performers because of the way in which these supposedly exceptional performers will be identified, which is by their supervisors. This system will lead to a system where brown-nosers get the recognition and the people who are really getting the job done will be pushed aside. If the boss does not like you, you will not get the recognition, period. 2. One thing the politians are always harping about is that pay in the civil service needs to be more like the pay in the private sector. Well, the civil service is different than a private company. The primary mission of a company is to make money, let's not beat around the bush here. The primary mission of the civil service is serve the American people. It appears to me that the people pushing the NSPS have lost sight of this basic difference. 3. The concept of pay bands as proposed in the NSPS is worrisome to me. Let's look at an example. Let's say that one of the pay bands consists of what is now currently GS9 through GS12. If a person is currently a GS12, Step 10 and is placed at the top of the aforementioned band, how does this person ever get a pay raise, if he is designated as a top performer and is deemed worthy? The band probably won't be expanded enough to give him the raise. Maybe he will get a performance award? Well he can get that now under the current GS system. It just seems to me that people who are put into the top of a band will be at serious disadvantage. 4. Let's look at pay pools. Let's say that Sylvester and Martha work in the same office doing essentially the same work and would therefore probably be placed in the same pay pool. Now let's say that Sly is struggling a bit with a particular work item and he asks Martha for assistance, knowing that Martha has experience working with the particular issue that he is struggling with. Should Martha help Sly, know that helping to improve Sly's performance will ultimately result in helping Sly perform his job better with a resulting increase in pay, which will reduce the money in the pool and possibly result in a smaller pay increase for her? This NSPS will have a detrimental effect on morale in the office in my opinion. 5. One of the reasons offered for going to the NSPS is that the current GS system rewards the outstanding performers the same compensation as the poor performers. This doesn't have to be this way. The current GS system does have a way to reward the outstanding performers. It is called a performance award. 6. Another reason set forth for implementing NSPS is that current "rigid, inflexible rules hinder DoD's ability to act without delay to meet mission needs and manage from a total force perspective". I think that this is a way that civilians in DoD could be involuntarily assigned to places like Iraq at the discretion of the heads of the agency. I know that some agency heads were extremely disgruntled over their inability to reassign civilians oversees to Iraq during the current conflict. 7. I could go on and on with the problems I forsee with implementing the NSPS, but I know the die is cast and it will be implemented. I have just tried to identify a few of the problems as I see them. I have worked for DoD for 31years and I think that the NSPS will have a more detrimental effect on the workforce that any other thing I have seen during my time. 8. I see that I have almost reached my limit of 4,000 characters. I appreciate the opportunity to offer comments.