| Comment Number: | OL-10508770 |
| Received: | 3/15/2005 10:40:25 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:
I would like to comment on Department of Defense Office of Personnel Management 5 CFR Chapter XCIX and Part 9901 National Security Personnel System; Proposed Rule. Thank you for allowing me this opportunity. NSPS looks to be a way to pay employees less, to eliminate a yearly raise, to hurt workers and to bust unions. All of this is done in the guise of national security and the need for flexibility. How does the General Schedule pay system threaten national security? What is so wrong with it, other than a yearly raise? Why the need to replace it? I don't hear my fellow workers begging for a new personnel system. NSPS is a way for the government to save money and pay lower wages, plain and simple. Having managers rate employees to determine whether they get raises is unfair and flawed. The premise is that all managers are fair and unbiased. Two employees do similar work, but one of their supervisors is tighter in his/her evaluation. So one employee gets a raise while the other doesn't, or gets less of one. DoD isn't saying just how managers will evaluate. It's setting up a system of favoritism. The pay pools and share systems are unfair. Even if a supervisor recommends an employee for a raise, the pay pool manager can deny it. Workers with similar evaluations could be given different amounts of shares, thereby getting different raises. A particular rating doesn't automatically convert to a fixed number of shares. DoD could tell lower management that there's no money for raises and to purposesly give out bad evaluations to prevent the raises. You'll have employees thinking that they're bad workers when the truth is that there's no money for raises. In Reduction in Force situations employees with more years worked and, most likely, making more money could be laid off or terminated before someone making less money with less time worked. Evaluations hold more weight than seniority in RIF decisions. This sounds like a way to discriminate against older employees making more money. The flexibility and national security arguments are just ways to bust the union and hurt workers. There are too many areas in which management doesn't have to negotiate. For example, manaagement has too much control in directing workers within the organization and in setting salaries within pay bands. Management should have to give the union notice before taking an action. Management wants the right to change employee expectations throughout the year. The NSPS document says it is the manager's job to communicate these changes. Once again, not all managers are good communicators. Flexibility and national security are just reasons to treat workers unfairly. Workers' rights are being eliminated. Why was the filing deadline for Merit Systems Protection Board cut from 30 to 20 days? Department of Defense could reverse an MSPB decision due to national security issues. Employees need a better way to challenge performance ratings and a way to appeal performance pay decisions. Why have these employee rights been limited or taken away? Is it because DoD realizes that the NSPS system is unfair? Why not let employees rate their supervisors and have the supervisors' salaries depend the the evaluations? Why should they be afraid of that? DoD wants the freedom to deploy civilians, to include going into war zones. That's wrong. If civilians wanted to be treated like military they would've enlisted in the military. It sure looks like employees' wages and rights will be lessened under NSPS and that the new system is a way to avoid paying the annual raises that federal employees have received in the past and to bring back the Old Boy Network. It reminds me of some advice I received years ago: When management tells you that they're doing something to help you, keep one hand on your wallet. Thank you.