Comment Number: OL-10511196
Received: 3/16/2005 2:28:22 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:

Here are my concerns about NSPS: There are only certain sections of Title 5 that have been specifically waived by these new regulations, but there’s nothing to prevent the other sections from being changed at NSPS’s discretion. These other sections address alternative work schedules, leave, workman’s compensation, retirement, insurance, and other areas of importance. What will prevent the writers of NSPS from slipping in new rules on annual leave that will eliminate the increase in annual leave after 3 or 15 years of service? Will that benefit also be tied to “performance”? GS and WG are finite pay systems where people know exactly what they should be paid and how they will progress as they accumulate time. For the base rates, it makes no difference whether a civilian works in ND or NY, a GS 12/10 will have the same basic pay. With NSPS, their pay will be subject to the whimsy of their supervisors and their locality, and nothing will be automatic. This brings up questions for those who are in upward mobility positions, who do not have to recompete for their promotions. Since the interns have been brought in with the promise of automatic promotions to the 7/9/11 grades, the new plan would a breach in the government’s agreement with them. Under NSPS, there are no grade or step increases, so there is no incentive to keep working. How are we going to retain or hire new employees when they are not guaranteed any promotions? I fear that sick leave usage will again be used as a weapon to punish employees who have to use a great deal of sick leave. I remember when people got warning letters when they used too much sick leave - for any reason! Even though they might have a doctor’s excuse for their absence, they could still be penalized for using more than 45 hours in a quarter. What will prevent supervisors from allowing a person’s sick leave usage (even for surgery or maternity leave) as leverage to fire them or at least prevent them from getting raises? Cost of living raises should be given across the board, not tied to performance! With the rising costs of health insurance every year, there will be no opportunity for someone to get an increase in salary if they are not “favored” by their supervisors. The whole concept that promotions, step increases, awards, and training will be at the discretion of a supervisor is very unfair. This will lead to less motivation on the part of many people who refuse to “suck up” in order to get ahead. There are also some people who, no matter how hard they try, will never be one of the “favorites”. Therefore, why should they even bother to do more than a mediocre level of work? There should at least be an evaluation panel of 3-4 people, so that the decisions are not left solely to an individual supervisor. Human nature being what it is, NSPS will lead to more greed and discontent. The higher level employees will make sure that their bands get the majority of the money available for raises, and the lower bands will be left out in the cold. There will be a lot of bad feeling among employees who are at the same level of experience, but get paid differently. The institution of NSPS will push many people who are at retirement age to sign their retirement papers and get out while they are still getting raises. We will lose a great deal of knowledge and expertise when they retire. If there is no incentive for younger people to come into the government, what will happen to the workforce? We will be left with a lot of frustrated employees who don’t have enough years to retire and don’t have any motivation to work harder. If Congressmen and Senators had to be paid under Civil Service, I think there would be a lot of changes made to our system. Since that will never happen, we are at their mercy – but we can remember when elections come around. I think NSPS needs a lot more study and consideration before a massive change is made that affects our livelihoods.