| Comment Number: | OL-10511047 |
| Received: | 3/16/2005 1:48:53 PM |
| 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:
"Pay and Pay Administration-Subpart C": DOD has demonstrated time and time again that they cannot develop and adhere to a budget. Currently DOD cannot decide how many ships to buy, if they have enough armor, bombs, flack jackets, airborne refuelers, etc., etc.. But we are going to allow them control of the workforce compensation funds. This will permit allocation of workforce compensation to pay the costs of their failed procurements and continued lining of the pockets of their favorite contractors at the expense of the workforce. DOD has repeatedly diverted workforce slated funds to pay for their failed management practices in the past, every time there's budget constraints the first things cut are training, travel and award funds. These are shortsighted decisions that have direct adverse impact on the overall proficiencies of the workforce, but are and have been the first and sometimes the only actions taken by DOD Component Activities for as long as I have been in Govt service, over 20 years. Linking pay to performance is a great idea, long overdue, but placing the process development, and full control of funds in the hands of the temporary caretakers of DOD (periods of four years at a time), invites the diversion of funds intended to attract skilled, talented, and motivated people, while also retaining and improving the skills of the existing workforce. This is contrary to the rational used to justify these significant changes. Many of today’s DOD component Activities have gone to a performance evaluation system of pass or fail, why? Because they could not manage a fair, unbiased system in the past. Now we expect they can implement and manage an evaluation system that determines how much pay an employee will receive? The Pay and Pay Administration regulation proposal is full of "to the maximum extent practicable, and overall budgetary constraints", escape clauses that will permit DOD and their component Activities to divert funds for short term gains at the expense of overall, long term DOD workforce capabilities and performance. The majority of DOD's workforce is in place at the beginning of an Administrations stewardship and at the end of their stewardship, these proposed regulations do nothing to ensure enhanced National Security capabilities, but give the in place Administration the opportunity to spend funds on programs and people of their choice for their time in office, vice the overall long term benefit and improved performance of the DOD workforce. "Employees may receive pay adjustments as a result of a rate range adjustment", what does may mean? Under these proposed requirements employees can actually loose pay while performing satisfactorily, as medical insurance, life insurance, taxes etc rise in cost, yet no funds are provided for civilian compensation, no minimum rate increases, or the entire amount is distributed to, say the top 5% in the pay band. The proposed Pay regulations open the door for increased abuse of the system not the rewarding and advancing personnel as stated.