| Comment Number: | OL-10509606 |
| Received: | 3/15/2005 4:36:01 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:
I am writing to you because of my concern about the so-called National Security Personnel System (NSPS) scheduled for implementation for more than 700,000 employees of the Department of Defense over the next year. I cannot say that the Civil Service Reform Act (CSRA) of 1978 was not in some need of “reform”, but the NSPS proposal totally destroys any fair balance between management and employees. Although, the proposal is proffered as an attractant for “skilled, talented and motivated people” and a means of “retaining and improving the skills of the existing workforce,” I believe the stated objectives of attracting and motivating a skilled and talented workforce to be disingenuous. The proposed changes, in fact, may create such undesirable working conditions as to cause a further decline in morale in the DOD workforce--which would not be a desirable outcome. Over the years working as a civil servant, I have seen a dramatic decline in morale and an erosion in the quality of managers and leaders. Contracting out initiatives and BRAC decisions certainly have contributed to the decline in morale, however, proposals such as NSPS, which virtually dismantles the employees right to negotiate a situation, be it through union representation or as an individual, is unacceptable. With this proposal, there is also great concern because there has been an erosion in the quality of managers. This proposal assumes that all managers are responsible leaders. I disagree with that general assumption. The system itself as we know it today, and how people are promoted, is partially responsible for this degradation. However, an even larger contributing factor has been the transfer of military primarily to TOE organizations. The impact of this decision has created stagnant/static organizations, where now civilian managers are remaining in positions of authority far too long. Having a system that encourages civilian managers to remain in a position for many years fosters a "Good Old Boy" scenario and under pay-for-performance and the adoption of NSPS, will create an environment, even if only perceived, as being "prejudice and unfair". The majority of workers feel cheated when advancement, promotion and pay decisions are almost completely based on the sole discretion or judgment of their manager, especially when that supervisor is not respected. And, there is no real guarantee that even the best workers will receive a pay raise or that the pay offered will be fair or competitive. The whole premise for this system began as a way to quickly attract, hire and retain employees for Homeland Security -- We were all told it was a matter of National Security. Now all of a sudden the DOD must follow in their footsteps. Homeland Security has not been in existence long enough to judge whether pay-for-performance is an improvement over the current system and if it will even achieve the stated objectives--providing a unique opportunity to improve the way we manage our civilian workforce. Until an honest and independent assessment of this new system can be made, identifying its successes and failures, why should we become a part of this system?