Comment Number: OL-10510670
Received: 3/16/2005 11:12:53 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 today to express my regrets about the proposals to change the work rules for DOD employees known as NSPS. As a life long employee of the DOD both Military and civilian, I feel as if the new proposals look at DOD workers as the enemy. The flood of changes that come in daily affect the work force in ways that is demoralizing and unpatriotic. Gone are the days when the military took care of it’s own. The new law of the land is to take care of the big corporations and the crooked CEO’s whose only real goal is to line their own pockets. Forget about loyalty and pride in work that’s been commonplace for decades in the DOD. It will be replaced by mistrust and favoritism if the language in NSPS goes through. SUBPART B – Classification How will the pay bands compare to current GS pay schedule now? One can only assume where they will fall given the vague description of the pay bands. Will equal pay for equal value level the playing field across differing agencies whereas one agency may currently be paying an employee GS-11 while another agency pays GS-09 for the same job? SUBPART C – Pay and Pay Administration Setting and Adjusting Rate Ranges Under the current system an employee knows when to expect a pay raise. Under the new system if you haven’t reached your final step prior to 2008 it looks as if you will actually lose pay beyond that. Where are the minimum and maximum pay scales going to be set? Pay for Performance Or “friend of the supervisor” pay plan. This pay system will not be equitable across differing agencies. Some agencies will hold the pay down while others will bring it up as fast as they can. Some managers will be more aggressive than others in rewarding their workers. Others will not want to be bothered with the extra time it will take to fairly evaluate the work force. Some will not want the burden or the perception of favoring some workers over others. And abusive managers will enjoy the power this will give them over their work force. If the current pay system doesn’t work (seniority) then it’s the fault of managers. How will managers be trusted to administer the new system? Rating Methodology: DOD Numbers in a rating system need to be justified especially at a top or bottom rating. A written justification needs to be required for all ratings Performance Pay Pools Sounds like managers will get to swim in the pool and the workers will drown. Are managers in the same pay pool as workers? What prevents management from keeping the worker pay down and their own pay inflated? As in the past with managers getting the bulk of the performance awards. Will labor have representation on the pay pool? Performance Payout Will labor work in concert with management in recognizing top performers? SUBPART D – Performance Management Performance and Behavior Accountability Teamwork is great and one of those words thrown around another partnering session when everyone is singing kum baya. What about those workers who are excellent workers “in the box” and keep to themselves, they have a job to do and get it done. Are they punished because the perception is they are not a “team player”? I believe some workers like to think they are team players by getting involved in everything and never really getting anything significant accomplished. The proposals specified in this section give managers great power to adjust or make workers submit. Again I do not feel confident that current management have the resources to fairly treat employees across differing agencies. Some may get it right other agencies will be known as brutal to their work force and will not attract the best workers. Why will there be behavioral expectations specifically related to a local organization? How will this be interpreted? DOD is putting a huge amount of trust and faith in their managers and supervisors in the range of adverse actions that are given to them including the ability to move workers into a lower pay band with up to a ten percent loss in pay. How will this be fair and equitable? Will managers be programmed to think alike? Not likely! Some workers will benefit, most will suffer. Subpart F – Workforce shaping Giving preference in a RIF retention to performance vice length of service opens the door for age discrimination. If the older persons work philosophy aren’t in line with a young managers way of thinking it will be simple to mark that person down and retain the younger worker in a RIF situation. Is this how DOD plans to thank it’s aging work force for years of dedication? Subpart G Adverse Actions Due process and fairness demand that the independent body reviewing major suspensions and terminations be allowed to alter the proposed penalty if it deems the penalty unreasonable. The current standard approved by the courts to guide such bodies should continue.