| Comment Number: | OL-10509811 |
| Received: | 3/15/2005 6:34:26 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:
Comments for RIN 3206-AK76. Supplementary Information, The Case for Action has a statement regarding Sep 11, which is a blatant attempt by the authors of this NSPS to scare federal employees into reform. The pretense that the current system is broken is false and misleading, regardless of how long it has been in use. Currently mgmt is allowed to hire, fire, and award within sufficient boundaries. Under Authority to Establish a New HR System, the mention of national security within this text is also an attempt by the authors to use scare tactics, since this NSPS has no merit. There are federal employees who have Secret positions, and most do not, perhaps those within the Secret/Top Secret positions should adopt this NSPS, otherwise national security has no place within the definition of this system. DoD wants to overhaul the current system, hire, fire, and award without using justification nor retaliation, the only purpose for this new system. OPM should take a very critical look into how many EEO cases are presently tied up in the DoD system based on unfair hiring, promoting, and awarding practices, to see that mgmt is not capable of staying within current regulatory boundaries, so how could the same mgmt be trusted to create and fulfill the promises of NSPS, where much less oversight is involved. The purpose of this system, is so that there will be no EEO cases filed, as there would be no oversight in the hiring, firing, awarding and promoting. Under Pay and Pay Admin - Subpart C, rate ranges will be based on factors such as labor market rates...overall budgetary constraints. This statement is very vague and arbitrary, with more subjectivity involved than is currently allowed in much of the private sector. The rating methodology section states DoD expects to use..., This shows that there is not even a rating methodology in place, because if one uses the words "expects", this is subject to change. Once the rater prepares employees ratings, it is then review by a pay pool panel. Who is the pay pool panel, who is the pay pool manager, the ultimate decider of one's fate. Staffing and Employment, Subpart E and Workforce Shaping(otherwise known as RIF), Subpart F give much discretion to mgmt, who are currently abusing these systems, promoting individuals strictly based on who one knows, not what one knows. The NSPS touts that it will ease the administrative burden, when in fact the only purpose is to get the regulations mgmt has not been able to work around, out of the way. It is my firm belief that this sytem has been created to get around the valid regulations in place today, and should OPM allow DoD to adopt this system, the result will be a very unhappy civilian workforce. There is nothing human in this supposed human resources management system.