| Comment Number: | OL-10508472 |
| Received: | 3/15/2005 8:55:42 AM |
| 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:
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. Nothing in these regulations limits the amount of pay increases and bonuses that management can award themselves or others each year, other than the maximum salary rates of their respective pay bands, and the amount of money in the pay pools. Nothing in these regulations prohibit management from freezing the pay of fully successful, highly satisfactory, excellent, or other successful employees. One way to freeze a fully successful employee’s pay is with “control points”, which can be implemented in each pay band to freeze salaries at a certain level. Page 7582, Section 9901.333 - Setting and adjusting local market supplements. This section states that DoD has the sole and exclusive discretion to set and adjust local market supplements, which if implemented, will replace the current locality pay system. Currently, locality pay is set and adjusted using salary data and input from OPM, OMB, the Labor Dept., and the Federal Salary Council, which includes employee representatives. Replacing this reliable system with a sole and exclusive decision by DoD to set local market supplements seems arbitrary, unfair, and irresponsible. It will likely result in uncompetitive pay rates in critical jobs in many areas, decreasing the DoD's ability to retain qualified employees, and impacting national security. I recommend that the current locality pay process be retained to ensure fair, reasonable and competitive pay rates based on valid data. With the new patronage pay system, which DoD calls "pay for performance," the amount of a worker's salary will depend almost completely on the personal judgment of his or her manager. This system will force workers to compete with one another for pay raises, which will destroy teamwork, increase conflict among employees, and reward short-term outcomes. There is no guarantee that even the best workers will receive a pay raise or that the pay offered will be fair or competitive. This system will create a situation in which workers are in conflict with one another and afraid to speak out about harassment, violations of the law, and workplace safety problems. Furthermore, there will be no impartial appeal system to assure that everyone is treated fairly. I am certain that one of the Pentagon's objectives in advancing NSPS is to construct a so-called "pay for performance" system. This is another case of deceptive labeling. Various government agencies have been testing performance pay systems for more than 20 years and invariably, the results have been that the majority of workers feel cheated when advancement, promotion and pay decisions are given over to the sole discretion of a supervisor. The process typically reduces salaries and morale. It is too autocratic and eliminates any redress for decisions made on the basis of considerations other than merit. For these reasons, I oppose the implementation of NSPS and I urge you to act to instruct the Secretary of Defense to halt any further development of NSPS unless and until the Pentagon is willing to substantively address the issues raised by the United DOD Workers Coalition. NSPS will replace the current government job classifications by grouping them into a few occupational categories with pay being set in "bands" with the new categories. Individual employees will be unable to appeal these newly-classified positions or the broad range of duties under the revised categories to a neutral arbitrator.