| Comment Number: | OL-10509358 |
| Received: | 3/15/2005 2:44:42 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:
The bottom line with the proposed NSPS system is that it significantly reduces job security for all covered DOD employees. Job security has always been the chief draw/appeal of the DOD civil service. DOD employees typically take less pay in exchange for job security. This proposed NSPS system effectively takes away that draw/appeal from DOD civil service jobs. Removal of that draw/appeal is at odds with one of goals/purposes of the proposed NSPS system, i.e., improved recruitment. Without the substantive draw of dependable job security future recruitment for DOD civil service positions is bound to be seriously hurt. Potential job applicants will be more inclined to go into private industry or to go to work for another government agency such as GSA which is not under the proposed new system. More seriously, the proposed version of the NSPS system will push the best and brightest of DOD employes with the experience and technical knowledge needed by DOD to take retirement where eligible or to leave for other government agencies under the original system or to go into private industry. This is already happening in contemplation of the proposed NSPS system. Many of our most experienced employees we very much need are leaving our agency for GSA and other agencies still under the original personnel system. If just the contemplation of the proposed NSPS system is creating a talent drain, the actual inplementation of this system in its current form will open the flood gates of talent flight. This comes at a very bad time for my DOD agency which is already facing a severe shortage of experienced talent without which it cannot meet the challenges of both fighting wars overseas and meeting the nation's changing domestic needs. The proposed NSPS system could not have come at a worse time for our already overstressed DOD employees who have been tasked for several years with doing more and more work with fewer and fewer personnel and fewer resources. Now these same DOD employees are faced with a proposed new NSPS personnel system largely perceived as a return to favoritism and the old spoils system. Review of the vague and sketchy "details" of the proposed NSPS system confirms that these fears are largely valid. The proposed NSPS as currently formulated effectively leaves pay, retention, discipline and other terms of employment to the discretion of the supervisor, i.e., to the whims of the supervisor. This frightens the daylights out of the ordinary DOD employee who has seen the unfairness and favoritism of other "pay for performance" initiatives and other systems based on the supervisor's discretion. The perception of the ordinary DOD employee, for good reason, is that these programs based on supervisory discretion have been a failure and full of internal political unfairness. If a system does not have the confidence and support of the employees who work in the system, it is doomed to both short-term and long-term failure. Review of the comments received on the proposed new system make it clear that it does not have the confidence or support of the bulk of DOD employees. As such it should be at a minimum substantially reevaluated and redrafted with greater attention being given to specific details, emphasis on addressing employees very valid concerns regarding provisions for excessive supervisory discretion which allow for whimsical decision making. Further, for realistic short-term and long-term DOD recruitment and retention efforts, the revisioned plan should provide greater emphasis on employee job security and greater emphasis on the integrity and fairness of the personnel processes. An extended comment period is also needed so the patriotic, hard working DOD employees have an adequate opportunity to give substantive input into the process. Without these much needed changes, this proposed NSPS system will in effect be shooting ourselves in the foot, not an exercise in wisdom or good planning.