| Comment Number: | OL-10510709 |
| Received: | 3/16/2005 11:29:31 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:
It is claimed that, “NSPS will create a new framework of rules, regulations, and processes — rooted in the principles of flexibility and fairness — that govern the way civilians are hired, compensated, promoted, and disciplined in DoD.” I can see the flexibility for hiring and firing is needed since the process is too long. But where does the fairness come into play? It appears that this system will unfortunately fall back into the good old boys club again. The Case for Action: “*** a future force that is defined less by size and more by mobility and swiftness, one that is easier to deploy ..” Does this mean that the civilian workforce will step in a military position so that the military member can be deployed or is the civilian going to be deployed as well under the meaning of reassignment? The older workforce did not sign up to be deployed, I’m sure that many would volunteer but I don’t think that we should be forced. Here is where the employee will suffer reprisals in the evaluation process. Performance Pay Pools: Quality Step Increases were implemented to reward that outstanding employee. Even now Quality Step Increases are far between for the simple fact that it is always claimed that funds are short. In 20 years service I have seen two and been submitted for more by my supervisor but denied by management because there were no funds available. Where is the guarantee of funds availability for pay increases, that the Pool Manager hasn’t promised it to another organization? One of the provisions replaces seniority with performance-based criteria. Again, older employees will not be favored with increases since the supervisor/manager want a younger work force they will make it difficult for the older employee to succeed. It allots no protection to the older workforce in a RIF. Agreed current job descriptions are vague but the NSPS is allowing too much power to change or create a performance plan in the hands of the few. The manager can create a performance plan for his favored inefficient employee to allow them to exceed. What happened to other duties as assigned for flexibility? It doesn’t explain in what manner supervisors and managers will be accountable. There are supervisors and managers that have their favorites, where the employee is incompetent but very well protected. This system will continue protecting the incompetent if they are favored within the organization by the higher echelon. At least the excellent older worker could count on the yearly cost of living and step increases; now this is being taken away. There is no specific scope on Pay Banding. Rumor has it that GS-5 will be lumped in with GS-7 thru GS-11. What incentive is there for the GS-11 to exceed all the time if there are no raises after reaching the maximum limit of the pay banding since I’m sure that there are no promotion possibilities into the next band without an opening. Bonuses are mentioned but it does not count towards retirement pay. Would an employee be told that a promotion is not possible because the next salary band is 20% percent above the maximum 5% cap? Agreed that the current way of hiring, firing and disciplining poor performers needs to change, but leave the current pay system alone. Yes, you may want to provide an incentive in recruitment to hire a person at a higher rate but our current system allows this, it’s just not publicized or practiced. This new system is too subjective and will be prejudicial to those that actually work but are not esteemed by their manager. I don’t see how this is going to protect an employee against reprisals, again it all comes down to who is liked and not. This new system will be detrimental to morale since it provides no incentive to help a coworker if I’m in competition for a raise. Many States are turning away from Pay Banding they recruit excellent people but cannot retain due no funds for promotions, raises and bonuses.