Comment Number: OL-10508900
Received: 3/15/2005 11:21:34 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:

Decrease Your Standard of Living Funding: Under the General Schedule and FWS, employee pay was clear. It was funded by Congress and could not be taken away. However, NSPS will take away this certainty. Salaries and bonuses are funded by DoD. In the past – as recently as just last year – DoD did not fund its awards program. Given the agency’s miserable record on this issue, how can employees feel confident that your salaries and bonuses will be funded in the future? In the Federal Aviation Administration, many employees have not had a pay increase in two years because the pay schedule did not increase. While the GS system went up by over 7% in the last two years, they got no increase. Pay : With the new pay system, which DoD calls “pay for performance,” the amount of a worker's salary and pay increase will depend almost completely on the judgment of your manager. Furthermore, the managers above your supervisor can change ratings if they wish. 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. If there is a problem, you won’t be given a fair appeal process to challenge the performance and pay decisions. Take Away Your Job Security Reductions in Force ( RIF) : The new rules state that if RIFs occur, the decision of whether to keep an employee will depend first on his/her performance appraisals, which are issued by supervisors. Those employees with the best ratings will be kept. Those with lesser ratings will be let go. Only in the case of a tie between employees will a worker’s seniority be considered. Before NSPS, your years of dedication to DoD counted a lot in the event of a RIF. Now it is clear that DoD doesn’t care about commitment anymore (or maturity or knowledge awareness). Civilian Deployment: Federal employees could be assigned anywhere in the world, even into a war zone, with little or no notice. This will make it difficult for working parents who care for a family and have personal obligations at home. Is it too much to ask that I be guaranteed sufficient notice to plan for such assignments? Are all civilians going to become just like the military? Change Your Work Life Work Rules, Schedules, and Overtime Rotation: NSPS will weaken unions and the rights gained through union contracts, such as flex days, advance notice of work schedules, and overtime rotations. If an employee is disciplined by a supervisor, there will be very little chance of overturning the punishment. NSPS will allow managers to schedule employees to work without sufficient advance notice of schedule changes. This will make it extremely difficult for working parents to care for their children and family. It will also mean that abusive managers could harass employees with bad schedules or short notice. Overtime rotations can be canceled, which means that employees may not be able to plan adequately for childcare and other important responsibilities. Suggested Comments about NSPS to send: I write to express my concerns about changes to work rules in the Department of Defense (DoD). The proposed regulations, known as the National Security Personnel System (NSPS), were printed in the Federal Register on February 14, 2005. This message will be sent to both DoD and my representatives in Congress. I have worked for DoD for years. I am angry that these proposals seem to treat the employees who help defend our country as the enemy. Most DoD employees work hard and are committed. I believe that mistreating the employees will hurt the agency’s mission. I am very upset by NSPS. This system will change the way workers are paid, evaluated, promoted, fired, scheduled, and treated. These rules would create a system in which federal managers are influenced by favoritism rather than serving the civil concerns of the American people. It also appears to me it will tend to drive out the most senior people at the top of their pay rate, which is exactly the opposite of the DoD goal to retain hard-earned knowledge. Annual Pay Raises Under the General Schedule and FWS, employee pay was clear. It was funded by Congress and could not be taken away. However, NSPS will take away this certainty. Salaries and bonuses are funded by DoD. In the past – as recently as just last year – DoD did not fund its awards program. Given the agency’s miserable record on this issue, how can employees feel confident that our salaries and bonuses will be funded in the future? Pay System 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. Schedules and Overtime NSPS will allow managers to schedule employees to work without sufficient advance notice of schedule changes. This will make it extremely difficult for working parents to care for their children and family. It will also mean that abusive managers could harass employees with bad schedules or short notice. Overtime rotations can be canceled, which means that employees may not be able to plan adequately for childcare and other important responsibilities. Civilian Deployment Federal employees could be assigned anywhere in the world, even into a war zone, with little or no notice. I am proud to serve my country but I am also responsible for caring for my family and my personal obligations at home. We signed up for a civilian job. We did not enlist in the military. Today’s volunteer system works well. America is at war. We are fighting for democracy abroad. But the regulations are an attack on workers’ basic rights. Furthermore, NSPS will divert the attention of defense workers from the soldiers’ welfare to protecting themselves from abuse on the job. I urge you to force DoD to rethink this proposal. We need work rules that preserve fairness, serve the American people, and respect the rights of Defense Department workers. I am convinced that a “national emergency” will be the order of the day just like it has been for 20 years under the Pay Comparability Act. There is always a way to abrogate laws written by Congress. NSPS will be no different. After 32 years in service to DoD, I can say I will not recommend this to my children!