Comment Number: OL-10510474
Received: 3/16/2005 9:54:43 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:

I wish to express my concerns with the NSPS proposed regulations. The regulations, as written currently, are vague and disturbing. They do not define the new system and much is left to be spelled out later. Thus, one can not review the regulations and determine if the system will be fair to employees. The current system does not need "fixed" in any event. The current system is perfectly adequate to weed out problem performers if used properly. Management has always been able to deny step increases if a person was not adequately performing. It is up to management to ensure that the step increase is not given, which they can easily do. The new system does not change anything in this regard. What it does is ensure is that it is completely up to management to decide when a well-performing employee receives a raise, which depending on the supervisor, could be never. It eliminates raises (step increases) at defined intervals (which management could always deny.) This fact in itself, is an extreme morale buster. Employees need a safeguard with this new system because supervisor's/management just don't see the need for awards and/or raises, even with well-documented, exceptional performance ratings. Supervisor's/management should have to justify why bonuses and/or raises aren't given if the employee does receive exceptional ratings, especially year after year. I would also emphatically like to state that the annual raise that the public keeps hearing about, is in fact, a cost-of-living adjustment, and barely keeps up with inflation, and usually barely (if it does) covers our ever rising health, insurance, etc. costs. It is most definitely not a raise and has nothing to do with performance. The NSPS system as it currently reads ensures that civilian pay will not keep up with inflation because we will not receive any kind of annual cost of living adjustment. Thus, the system ensures that even adequately performing employees may incur what is really a pay decrease. Additionally, if the new system isn't adequately funded at the Congressional level, you can be sure that funding will not adequatley filter down to the installation level. Thus, even employees who are performing exceptionally, will be denied increases, because the funding won't be there. Subpart I Labor-Management Relations - 9901.901 to 9901.929 I personally do not know of anyone who has had any kind of input to this new system. Where is the voice of the employee? I believe it is imperative that employees retain all of their current collective bargaining and grievance rights. To eliminate any of these rights is taking a step backward. A full collective bargaining process, involving unions and employees, should be included in designing the new personnel system. In short, much work needs to be done on this new system, BEFORE, it is implemented.