| Comment Number: | OL-10509071 |
| Received: | 3/15/2005 12:32:49 PM |
| 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:
Some more reasons I do not NSPS GENERAL: There is no indication that the new authorities granted to DOD will produce a more effective or effieceint accomplishment of the DOD mission. To the contrary, the overwhelming experience in the federal sector with pay for performance plans has been a dismal failure. That includes both the historical efforts and the current efforts under the current administrations " Management flexibilities" just ask the employees of the Transportation Security Agency, or the managers at NASA. NSPS is not necessary to reduce the dependence on the military performing work that could be done by civilians. The directives from congress to DOD to make that happen dated back to the Clinton administration, and all that is necessary is for DOD to make the conversions. It is happening where DOD can move those positions directly to contractor provided services rather than haveing the work done by Civil Service. Just ask DOD about how quickly they were able to move security services to the private sector once they found a nobid option to do it-are there contractors at your gates? Do you feel motivated? Do you have confidence that the same management you have today will reward you appropriately tomorrow. Rcognizing your service and rewarding your excellence? NO i don't think that will happen. Haven't they done that to this point? YES. The provisions to do so are already in the existing laws governing personnel. If you have been lucky enough to have a supervisor who rewards your efforts, will they have the funds available to to reward you in the future? Not under NSPS. Under NSPS DOD civilians can be asssigned anywhere in the world, even to a war zone with little or no notice. Yes, DOD has the authoity to assign some employees to deployment in support of a mission.These positions are designated by DOD, and employees know when they hired into positionn that this is a condition of employment. OH by the way these positions are exempt from being contracted out, BUT NSPS does away with that little job security feature, by making ALL DOD positions deployable. So the authority is not unaffected, it is expanded. BENIFITS ( HOW YOUR RECEIPT OF BENEFITS AFFECTS NATIONAL SECURITY) NSPS may not affect the formula for calculating your retirement benefits, BUT your pay is still the main element for determining your annuity-and that provision has been drastically altered, but you know they only want to take you higher. Subpart C 990.300's The whole process of setting your pay has changed, with performance being the highest reward of all the pay prvisions. Remember the multi-level rating system DOD had in place a few years ago-the one they said was unmanageable and wanted to get rid of, and did-in favor of a manageable pass/fail system? Well you will be comforted to know that those same folks who couldn"t manage it then. arenow singing its praises. We know now you won't be able to file a grievance over your performance rating 9901.922(c)(4)BUT DOD will develope through implementing issuances a method to appeal your performance rating 9901.409(g). Thisa is just another reason I am against this NSPS. Eligibility for RETIREMENT: Formula stays the sameBUT your ability to satisfy the criteria that is to stay long enough to earn a meaningful benefit is now a decisionthat management has a greater control over than you do. That I don't like. With the changes DOD is making with RIF my opportunity to retire might be greatly enhanced, since they will be able to do "designer" RIF's with an area of competition custom designed just to meet your needs.9901.605. I worry because yes my Benefits will be affected under NSPS.