| Comment Number: | OL-10509677 |
| Received: | 3/15/2005 4:57:30 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:
Federal Register/Vol.70, No. 29/ Monday, February 14, 2005 / Proposed Rules National Security Personnel System (NSPS) Part II DoD OPM/ 5CFR Chapter XCIX and Part 9901 Docket # NSPS-2005-001 RIN 3206-AK76/0790-AH82. Th description of the NSPS in the Federal Register is vague, inadequately defined, and sorely lacks detail. It is a disservice to DoD employees to implement the most revolutionary personnel system in decades, without providing employees the details and impact of changes to pay, benefits and employee protection. The NSPS website and associated readings to include the myths and facts paper and other brochures -- are all intended to promote the NSPS. The detail provided in these publications is, at best, obscure but, in practice, wholly absent. It is unlikely that the Seven Guiding Principles of NSPS can be accomplished at the expense of alienating and undermining dedicated and loyal DoD employees under NSPS. The Key Performance Parameters (KPPs) are worthy goals, but remain only that - goals - under NSPS as this system will create an uncertain, insecure and demoralized workforve. It is only through our employees that the work is done, and done well. When employees feel valued by management and motivated to serve, they will step up to the plate. NSPS will create exactly the opposite morale and motivation that it purports to achieve. NSPS will not attract and retain high-caliber candidates to Federal Service, rather, it will detract and discourage retention. Why is this? NSPS is driven by a DoD goal to become more cost effective and fiscally sound while also becoming more flexible and responsive. Linking basic pay and locality pay to budget constraints and market conditions creates insecurity among employees. Pay can be adjusted from year to year. The NSPS tenet of pay for performance may sound appealing, but linking pay to budget constraints, is not ! The Federal Register states: NSPS will generate more opportunities for DoD civilians by...providing an incentive for managers to turn to them first when certain vital tasks need doing. This will free uniformed men and women to focus on matters unique to the military. How can involuntary deployment of civilians attract and retain the best and the brightest? If implemented, NSPS has far-reaching implications for all DoD employees and their families. Despite its lack of detail, the Federal Register describes DoD's intent in establishing a new personnel system. In my review of the NSPS, in addition to linking basic pay and locality pay to factors that include market conditions and budget constraints, I also learned that NSPS: increases the authority of supervisors and management in the performance review process; decreases the area of union representation; and changes RIF retention py putting performance ahead of length of service. While performance before tenure sounds like a positive goal, in reality, it can prove to be unfair to even top performers who may be saddled with unethical and biased supervisors. Flawed human behavior exists in supervisors and management and no amount of training can change that. Though the current personnel management system may not be perfect, NSPS is even less so. Re-think, re-visit, review and revise! NSPS will not benefit DoD employees, rather NSPS will demoralize even the top employees; NSPS will not attract and retain the best and the brightest -- ultimately, implementation of NSPS will undermine our ability to support soldiers.