| Comment Number: | OL-10509049 |
| Received: | 3/15/2005 12:21:17 PM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| Attachment: | NSPS Word Document.doc Download Adobe Reader |
Comments:
From your Web site's fact sheet: --Nothing delays management’s ability to act. --DoD may review initial decisions within thirty days (or it becomes final); may remand, modify, affirm, or reverse initial decision, based on stringent criteria. --Final DoD decisions (including AJ decisions that become final) may be appealed to full MSPB, which retains limited review authority. --Greater emphasis on performance (over seniority) in retention The four items above prove to me that management will be handed far too much authority. Using these powers, an unscrupulous supervisor could effectively destroy the career of a good worker. Having survived one such supervisor, I know how easy it is for a boss to set up a subordinate for failure. With these proposed new rules, it will be even easier. The fourth item above (and all the similar “performance-based” pay incentives) mean that office politics will carry too much weight. The supervisor's favorites will be at the head of the line for job security in the case of a RIF and for pay raises/bonuses (in the doubtful event that any make it down to this level). A worker who has had superlative performance ratings for most of the past 20 years could be replaced by a newcomer if more recent performance ratings are unfairly manipulated. If seniority is worthless, then an important benefit of long, loyal service has been stolen. There are undoubtedly some bums in the civil service, and there's also no doubt that it's difficult to get rid of them. A judicious revision of the current system could have addressed that problem. Instead, you propose this slash-and-burn replacement that eliminates many worthwhile employee gains of the past 30 years. The new system seems designed to keep government employees cowed and fearful. If management through intimidation was the aim of this change--Mission Accomplished. PS. The guidelines for public participation are especially amusing. If I could wade through the 50 pages of the gobbledygook in “Federal Register, Vol. 70, No. 29, 5 CFR Chapter XCIX, Proposed Rules,” and list the appropriate subpart and section numbers (and provide supporting data), I wouldn't need a government job--I'd be a tax lawyer. Why didn't you key the points in your fact sheet with the appropriate subpart numbers? Would that have made it too easy to participate?