| Comment Number: | OL-10511405 |
| Received: | 3/16/2005 3:19:51 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:
I believe that the proposed NSPS will undermine morale and negatively affect the DoD mission. Subpart C Pay - Sections 9901.301 to 9901.373: The employees in DoD should continue to receive the same annual cost of living increase that other Federal workers receive, otherwise, we are being penalized unfairly. Also, the individual pay increases for performance should include guaranteed percentages in the regulations so that it will be clear to employees how their job performance affects their pay under the NSPS system. Subpart D Performance Management - 9901.401 to 9901.409: In order to ensure fairness in the appraisal cycle, DoD employees should be able to appeal any performance rating through an independent grievance and arbitration process like they can do now. Subpart F Workforce Shaping - 9901.6012 to 9901.611: DoD should not change the current layoff/RIF rules which give balanced credit to performance and the employee's valuable years of committed service to DoD. Subpart G Adverse Actions - 9901.701 to 9901.810: Due process and fairness demand that the independent body reviewing a major suspension or termination be allowed to alter the proposed penalty if they deem it to be unreasonable. The current standards approved by the courts to guide such bodies should continue to be used. Subpart I Labor -Management Relations - 9901.901 to 9901.929: The labor management law that has governed the employee's right to organize and engage in collective bargaining has worked well since 1978. There is no compelling reason to take away most of the collective bargaining rights or grievance rights. DoD should not create a Company Dominated Dispute Board. Any dispute board must be Jointly Selected by management and the Union. General comments: Changing to a system that will affect employees' pay at the discretion of the supervisor, and without hard and fast rules on how the performance will be measured, will cause much more dissension among the workers than is happening now. It is hard now to appeal an appraisal that is not fair, and it will be much harder when giving the supervisor and the DoD so much unchecked power over employees. In Air Force contracting, the supervisor assigns the workload, which can have a significant impact on how hard your work is. Assigning easy workload to favorites and assigning harder workload to other employees has the potential to create a very hostile workplace under the NSPS. When it is up to the supervisor to decide how well you performed and where your co-workers will fail or succeed depending on how the work was assigned, job dissatisfaction will be high. In a perfect world NSPS might work wonderfully, but it is not a perfect world, and I can tell you that not all supervisors are fair.