Comment Number: OL-10510774
Received: 3/16/2005 11:56:11 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 am writing because of my concern about the National Security Personnel System (NSPS) scheduled for implementation for Department of Defense employees over the next year. NSPS was authorized under the 2004 Defense Authorization Act, passed by Congress in November 2003. However, I believe there is a significant difference between the initial intent of authorities Congress approved and the authorities that Secretary of Defense Donald Rumsfeld is now jamming down the throats of all Department of Defense employees. Yes, that is the way many of us feel this new system is being introduced. The Secretary asserted that the Pentagon's broad mission requires greater "flexibility" in hiring, disciplining, compensating and assigning civilian personnel. All this "flexibility" is a smoke screen for allowing the military "managers" within the different defense departments to systematically eliminate individuals that do not meet their ideas. It has less to do with national defense than it has with allowing these uniformed "managers" in creating a department that fits their ideas. No one will disagree with anything a member in uniform says out of fear of losing his or her job. In short, the Secretary is demanding the same "chain of command" authority over civilian personnel as he enjoys over uniformed military personnel. Throughout all this hardball selling of the NSPS, no one has provided concrete examples of how the current system has impinged on the Pentagon's mission. I also don’t appreciate the tactic of trying to “sell” the system as part of National Defense. Although Congress acceded to the broad requests lodged by the DOD, it attached certain strict conditions--including specific requirements that DOD observe legal requirements of labor relations statutes and that they involve duly elected unions in the development of the new system. I do not believe that the DOD has done either. Although DOD has convened "town hall" meetings to "brief incumbents", there has been no information sharing from DOD on exactly what problems management wishes to address with the adoption of NSPS. The town hall meetings to date have added more confusion and resentment. Every (and I do mean every) question has been answered with the canned phrase, “That is a good question and they are working that issue now.” The Pentagon's stated objective in advancing NSPS is to construct a "pay for performance" system. This is deceptive and misleading. This system has been tested for over 20 years and the results have indicated that majority of employees felt cheated by promotion and pay decisions which were based solely on the discretion of a "supervisor". The process is designed to reduce salaries; the ultimate results have been lost to non-existent morale. NSPS is an autocratic system that ultimately is designed to eliminate employee redress for decisions made on the basis of bias, not merit. While I do feel that some change is necessary and would be beneficial to the Department of Defense, I do not think the proposed NSPS is the answer. The system in place now has protected employees' rights from favoritism and bias. In an ideal working environment, the proposed system would benefit dedicated workers and not benefit those unfit for the job, but not everyone works in an ideal environment. Individuals that are not employed in ideal environments would be severely limited and impacted. I feel these issues need to be addressed before implementing the proposed system. Another broad issue, which isn’t being addressed, is the significant consequences NSPS will have on the civilian retirement system. The current FERS system has been touted as a model retirement system. With the restrictions on salaries that the NSPS will have, the retirement system will be largely impacted. Don’t believe for a minute we don’t recognize this blatant attempt to reduce salaries and retirement monies for federal workers. This is all going on while Congress continually raises their own pay and the higher echelon within the civilian pay system have realized large increases in salary due to NSPS You also can’t ignore the horror stories already realized by implementation of this system within Homeland Security itself. It is easy to see we are taking a step back to the “old days” of promoting your buddies and giving increases only to upper management. True performance rating doesn’t work for the military, and it didn’t work for the civilian workforce in past history. It doesn’t matter how much training you give supervisors, they have their own set ideals that they will use to make judgments. It has taken the civilian workforce a long time to get to the point of working as a team to meet mission requirements. This is due in part to the current knowledge that everyone is on an equal pay system. NSPS will cause an abrupt change in the entire working environment. We will digress back to the old cutthroat days. Everyone will be for themselves trying to “suck up” to the boss, promote themselves to be recognized, and caring only about their own advancement. For these reasons, I oppose the implementation of NSPS and I urge you to stop any further development or implementation of NSPS.