| Comment Number: | OL-10509474 |
| Received: | 3/15/2005 3:38:26 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:
Grievances, adverse actions, and appeals. There is no way a system that creates its own review board to second guess Administrative Law Judges and MSPB decisions will be seen as fair, impartial, or effective. This system will, in my opinion, cause the mistrust between management and worker to grow greater than it is now. It assumes you will have an ideal set of well trained managers who all will not allow their own personality quirks to affect their decisionmaking. You provide little legitimate relief for employees who will very likely have to grieve an action at some point. You have set the fox loose in the henhouse - and that is bad business. The DOD has not, does not, and never will be effectively run like a business organization - upon which many of your assumptions for managing people are based. The constant downward pressure of increased workloads driven by unrealistic timetables will force managers to demand the unexpected and in order to save their careers, will likely find fault with the people least able to control the big picture. You also make assumptions about the current system that are selective, and on the whole, quite erroneous. There have been checks and balances and effective managers have used them effectively. You are creating a system to cater to the lowest common denomiator managers who are - in essence - ineffective. That doesn't make the whole system broken like this will cause to happen. Union Activities. Unions are the only way for employees to have a strong voice in their corner. The NSPS has painted them and their activities as the devil business incarnate. Who is going to ensure managers do the right thing? Not this system. It will create fear, mistrust, and a clear us and them relationship. Its design will provide ample cover for and free reign vindictiveness, cronyism, and nepotism. Pay banding is a wide open invitation for the birth of a new good old boy system. The ideal of managing to performance and then justly rewarding is laughable. Targets and objectives are constantly moving goals due to the unpredictable nature of DOD business and the demands of senior officers and managers who don't know how, or are unwilling, to say no to unreasonable and burdensome mandates. There is a serious gulf between the realities of the ground support employees and the demands of lofty thinkers and theoretians. That's why the current pay system works. It doesn't allow for unfair progression and compensation practices. This new system will open up a pandora's box of problems instead of solve them. If congress were paid for what it accomplished effectively or to the people's satisfaction, I daresay alot of them would be lining up at soup kitchens to supplement their take home. They'll tell you it's because the system is unwieldy. That is our reality too. You are taking a meat cleaver to a brain surgery procedure.