Comment Number: OL-10511551
Received: 3/16/2005 4:00:44 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:

NSPS eliminates cost of living increases as enacted by law. I have a couple of issues with this. First, cost of living and pay for performance are two fundamentally different concepts. Cost of living is an increase in pay recognizing that with inflation and other factors actual cost of living increases from year to year. I don't recall actual cost of living ever decreasing. Second, Congress supports pay parity between civilian and military. Under NSPS there would no longer be the ability to maintain parity. Military pay would continue to be set by law and Civilian pay would be determine by DOD. Third, is a question. Why can't NSPS support cost of living increases and pay for performance? NSPS is proceeding with implementation without having complete documentation available to employees. During a recent town hall meeting the presenter mentioned that a goal of designers was to build a credible system that civilian employees can trust. Without further documentation and training Civilian employees are being asked to have blind trust. I believe that goals of NSPS are generally good but good goals do not guarantee good implementation. It is my opinion that NSPS will be implemented and that it will end up hurting the civilian workforce because of the way it appears to be implemented. I think that an unwritten goal of NSPS should be to encourage good performing to perform better and not allow NSPS implementation to discourage them and affect their performance or cause them to look else where for employment. When I started my career with DoD, I entered under FERS because of the deadline enacted by law. That's okay and I accepted that as a condition of my employment. For people that were under CSRS they had a choice to stay under CSRS or switch to FERS. I am uncomfortable with the implementation of NSPS since I have no choice or little say in its designed or how it will be implemented. So where I am in my career I will need to wait and see how it turns out. The only real choice I have control over is if I continue my career with DoD or go else where. While NSPS may give DoD a flexible, responsive pay for performance system, if implemented poorly it may cause DoD to be in crisis as skilled knowledgeable civilians leave because private sector offers are equal or better. I believe that many career civilians will consider making a tough choice due to the lack of details on NSPS or poor implementation: stay in service to our country or switch to the private sector. I don't think that NSPS had a goal of driving out good performers. How NSPS is implemented will have a big impact. I appreciate the opportunity to provide comments. I considered not providing comments because I did not think that they would make a difference. But then I consider that it is similar to our freedom to vote for elected officials. If I don't vote I can't complain because of the outcome because I did not exercise my freedom to vote. If DoD provides an opportunity to comment and I don't take it I shouldn't complain since I did not take the opportunity to comment. thanks