| Comment Number: | OL-10510146 |
| Received: | 3/16/2005 6:42:16 AM |
| 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:
General: It seems absurd to ask for comments on a proposed system that is so lacking in detail. It is apparent that the lack of substance is designed to avoid specific criticism. Implementation: Why does DOD want to implement a system that is lacking specifics, so quickly, and across such a large segment of its employees? DHS is going to take a much slower approach to implementation depite starting much earlier on the changes to their system. DHS has provide more detail and will only involve 10,000 employees on the first wave before evaluating and modifying the system before subjecting additional people to the changes. Pay banding: No specifics on what the bands actually will be. How will it work? What will be the pay pool? If supervisors are in the same pool, there is no doubt who will get the lions share of the money available. Performance Management: An oxymoron. Again no detail on how it will work. In 21 plus years with the DOD, I have only seen 1 or 2 managers even remotely capable of acurately rating their employees in an unbiased and objective manner. This is one reason we are now on a Pass/Fail system. All the training in the world won't solve the problem, and as we all know training is the first thing to go in the current fiscal situation. This system will destroy the team work concept because everyone will be competing for the limited pool of money available for raises. No one will trust their fellow employees and the relationship betweeen workers and managers will likely become even more resentful. Labor relations: Again little or no detail. Two words...Union busting. Using words like "substantial", "foreseeable", and "significant" regarding bargaining is an allows management to pick and chose anything they want to negotiate, which will be "nothing". Saying that management can implement policy before negotiation is the same as saying there will be no negotiation. Appeals: No detail. What are the MRO's? Another attempt to circumvent the Unions and employees rights. Using words like "perponderance" of evidence ensures a variable interpretation of employees appeal rights. This system basically dismantles the MSPB by limiting their ability to mitigate decisions on displinary actions. DOD officials will be able to pick and chose which MSPB decisions they agree with and change those they don't.