| Comment Number: | OL-10509235 |
| Received: | 3/15/2005 1:52:06 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:
A. Labor Relations-Subpart I - The DOD should not create a "company dominated" dispute board, rather a dispute board that is jointly selected by management and Unions. Collective bargaining rights or grievance rights should not be taken away since it has worked well in the past for the employees. B. Performance Management- Subpart D- The proposed linking employee's pay to their performance ratings will not improve output performance but rather be a popularity contest to please their immediate supervisor whose subjective decisions will determine their future pay. C. Employee Appeals- Subpart H- It is unfair to eliminate the right of a union to submit serious adverse actions imposed against bargaining unit employess to an arbitrator. It is unfair to reduce an employer's burden of proof in adverse actions cases to a standard that would require Dod's decisions to be upheld even if they are more likely than not to have been improper. It is unfair to impose a higher standard of review for an employee to prevail in a grievance challenging a performance rating, which is used as a determinant of an employee's pay under the new system. D. Pay and Pay Admainistration- Subpart C- The pay-for -performance system does not provide an equitable method for appraising and compensationg employees. It is unfair and will become political tools of the supervisors to reward their friends and punish their enemies. I suggest that the proposed NSPS regulations be withdrawn, and a more thorough and collaborative process be initiated between management and labor representatives. Sincerely, Ronnie Hu March 15, 2005