Comment Number: OL-10510489
Received: 3/16/2005 10:03:17 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 write to express my concerns about changes to work rules in the Department of Defense (DoD). The proposed regulations, known as the National Security Personnel System (NSPS), were printed in the Federal Register on February 14, 2005. Many aspects of the NSPS seem counterproductive to me. I have highlighted some of my concerns below. Pay and pay administration - Subpart C Under the subsection, Adjusting rates and Local Market Supplements, the new system allows the DoD to determine rate range adjustments and local supplements based on several conditions. Included in these conditions is the availability of funds. This is counterproductive. The locality adjustments were designed to make the government pay more competitive. Allowing this to be adjusted by the DoD separately from other Federal agencies could mean that in tight budget times, employees pay suffers. This unpredictability would not provide for good motivation. The locality adjustment should also be part of the employees pay irrespective of his performance. It anyway is based on the employee working in an area (hence the name locality pay/adjustment) and not a performance pay. There is also no need for the DoD to duplicate what OPM is doing in setting rate adjustments. This is a waste of resources. There is no detail given about the formation of pay pools. This could result in unfairness in handing out bonuses and payouts if employees with different job functions are in the same pools. There is also a possibility of including managers making the payout decision in the same pool with the subordinates they are making the decision on. This will cause an obvious conflict of interest. Performance Management – Subpart D To ensure fairness and accuracy, Defense Department employees should be able to appeal any performance rating to an independent grievance and arbitration process as they can do now. There is also no guarantee that managers will be competent. Having an incompetent manager determine performance without any recourse for the employee is not fair. In conclusion, while the motivations for a new personnel system are sound, the proposed system falls short in many ways, some of which I have highlighted. It should be noted that these regulations as proposed would make for a disgruntled workforce. This should not be allowed as the mission of the DoD covers national security concerns.