| Comment Number: | OL-10508646 |
| Received: | 3/15/2005 9:40:31 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:
The guiding principles and KPPs are good, but in order to achieve them there needs to be a realization that getting and keeping good and trusted people means compensating them well and giving them a belief that they can continue to progress in their careers and be correspondingly compensated for their work. Fairness also plays in this with respect to the rest of the Federal workforce. If there is less job security and more requirements such as the protection of classified data, there should be the expectation that a higher level of pay will be provided to employees who are asked to do more. Some of the problems with the current pay system are carried on into the new system. Even though pay bands are expanded, they still retain some of the same caps and limitations. Supervisors don't have the flexibility and power to pay people what they are worth and have their hands tied. For those working for the federal government, there are times when the employees are faced with the decision to either leave the government or take a more enjoyable position because they have been told that they won't get promoted to a higher pay band. This is bad for morale, bad for the project, and causes waste and inefficiencies in the government. In private industry, that person would be paid an amount corresponding to the importance of the position and the budget of the project. This doens't happen now in the current system and the fixed caps on the pay bands ensure that it continues (as it does now under pay demo at NUWC Newport RI). There are also a number of serious flaws in the proposed system which do not address a number of problems that I have observed during my 25 year career. There is talk about encouraging pay for performance, but the trend has been to take less time to document performance and little to document performance in a number of jobs over time. Sustained performance needs to be identifed, documented and rewarded. Also, there is much to be gained inflexibility if there is a history of what you workforce has done over time; what types of programs/projects and the experience gained from each. This proposed system doesn't sufficiently address these needs. In fact when it comes to RIFs and reductions in force it ignors the past and only looks at current assignments to determine who should be retained and let go. This is shortsighted and wastefull. An orgenization needs to retain those employees who have shown themselves to be the best performers and most flexible. Limiting the RIF process to a particular program, project, branch, or department is incredably shortsighted and is also unfair to the empoyee who has demonstrated the ability to work on may programs and projects. I am particularly interested in this part because of my experience with BRAC and how my career was impacted by arbitrary administrative rules to control the movement of people between organizations. Demonstrated expertise in areas of need should be the overriding factor, not the artificial decision of what organization or program a person has been assigned to. Another flawed element of the proposed system is the method by which pay should be determined. Most of the DOD Programs other than those buying off the shelf items, are the result of very specific needs by the military to procure items that are not intended for the general market place. They are specific to the military and are purchased in limited numbers for that purpose. This means that these are not local in nature. There are only so many shipyards and aircraft factories to supply the military and although they are located around the country, they only serve a single nationwide client. Lookiing only at local cost s to determine pay for products that are not local is unreasonable and unfair. The programs and costs are not local and the competitors and contributors are not local. Pay needs to be determined on a national level for the skills, knowledge and ability that it respresents.