| Comment Number: | OL-10510776 |
| Received: | 3/16/2005 11:56:45 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:
BENEFITS - Proposed changes to how competitive areas are defined, veterans preference can be severely, if not totally, wiped out. With the new NSPS, traditional bump and retreat rights can be limited to a specific organization, funding, etc. Even with veteran preference, you cannot displace someone outside of this narrowly defined group, even though they may be in your same series/function and have no vets preference at all. DoD is not being completely honest in this matter. NSPS will not eliminate jobs. It will speed up the ability to eliminate jobs. Under the proposed management rights, management has the right to make determinations in the matter of, among other things, contracting out. Couple that with the less intrusive RIF capabilities that agencies will have and it becomes apparent that transitioning jobs from the government to the private sector becomes much easier. PAY- Any “buy-in” will be at the sole, exclusive discretion of the Secretary. It may happen, then again, it may not. Locality adjustments will be determined at the Secretary’s sole and exclusive discretion, based upon various factors to include “available funds”. If the Secretary determines that the money can be better spent in supporting the mission of the Department, funds may not be available for locality adjustments. The Secretary also will determine when and if a locality adjustment will be applied. Also, any such adjustments are subject to the rating you receive by your management. Your rating is not subject to be grieved under any negotiated grievance procedure. It may be challenged by a process yet to be determined! The annual January pay increase, as we know it now, will change. The proposed pay rules provide for periodic “rate range” adjustments, to adjust the minimum or maximum rate of a pay band. When a minimum rate of a pay band is adjusted upward, employees will receive an equivalent increase. There are no “steps,” similar to the GS system, in a pay banding system. Instead, pay increases and performance bonuses are based primarily on your performance rating. Unacceptable performers are not eligible for pay increases under the proposed system. The Department of Defense currently has not demonstrated a truly fair and effective performance rating system. Add to that the fact that now personal conduct, a purely subjective measurement, will be added to your performance indicators and you have a system that is doomed to fail. Its success will be in the fact that the ratings will not be subject to a negotiated grievance process and that the pay out cannot be challenged at all. DoD is committed to ensuring civilian compensation is protected? In fact, the law requires that the aggregate amount of money allocated for civilian compensation for organizations under NSPS cannot be less than the amount that would have been allocated under the existing system. Under NSPS, the overall amount of money that would have been used for the annual January pay adjustment, within grade increases, quality step increases, and similar payments, will be used for civilian pay, and those funds will be protected. However, the proposed NSPS pay system will distribute those funds based primarily on performance. Let’s look at this closely. “the aggregate amount of money allocated for ….cannot be less that the amount allocated under the current system”. What this is saying is that there is a fixed pot of money for pay and that the overall pot will be the same under NSPS as would be if we were to have remained under the current system. Now, utilizing basic math, if someone gets significantly more money under NSPS, that means it would have to be taken from someone else. Since DoD wants to be salary competitive with private industry for the young college grads, if they get larger salaries as an incentive to join civil service, that means that the money must be taken from someplace else…our former WIGIs or COLAs! IT'S A BAD PROPOSAL FOR DOD AND FOR THE USA .