| Comment Number: | OL-10511653 |
| Received: | 3/16/2005 4:34:32 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:
For sure we are in need of reforms. With no significant changes since 1978 and using a rigid, rule-bound pay structure established in 1949, it is time for change. My concern is that NSPS may be taking change too far...too quickly. Throwing out the baby with the bathwater is no more acceptable than keeping the baby in the soiled bath water. We can't take something that is a deeply ingrained culture that has been in place for half a century, that directly affects the livelihood of almost a million people and roll it out over a couple of months. I have concerns about how the reform is being implemented and concerns about the reform itself. NSPS Preparation and Implementation. Given where we are in issuing the guidance, NSPS should not be deployed in Jul 05. DoD has conveyed the message that NSPS will not be held to a time line but will be event-driven—whatever that means. Still actions speak louder than words and there is nothing being released to OSD workers or management that suggests that NSPS will not deploy in Jul 05. Unofficially we hear experts close to the sources speculate that all of NSPS won’t be implemented in July. Yet, there is nothing official and the average worker, who is none the wiser, is getting pretty anxious thinking that on 1 July they will be vulnerable to all manner of horrible NSPS fallout. Absent hard facts and information the rumor mill has taken over and many think they are in store for dire consequences. No more within grade increases, no more annual pay adjustments, no pay raises at all, subject to being sent to the war, subject to being RIFd or fired without any real appeal rights, and no avenue of redress. If the 30/30/30 period holds, the earliest date for issuing final regulations would be mid-May--roughly one and a half months before a 1 Jul deployment. And this still does not address the many hugely important details on how DoD will implement NSPS since the implementing regulations probably won’t be released until the enabling regs are final. It is obvious to many that you can’t get there from here. You can’t or shouldn’t deploy NSPS in Jul 05 if the workforce and management teams have not been properly prepared. It would appear to be of greater benefit to go public and let everyone know that the roll out will be slipped to ensure we get it right. It becomes a credibility issue and right now NSPS has little credibility and is losing the little that it has. NSPS Program Management Funding. NSPS is being deployed using the Defense Acquisition Management model and has been compared to presenting as big a challenge as that of deploying a major weapon system. I know of no major weapon systems there were deployed without providing for re-training and sustainment costs? To successfully implement this totally overhauled personnel system, training and re-training are an absolute must. Yet, there is little to no training being developed in any kind of systematic manner. I’m told that training requirements have been loosely defined: change management, supervisor training, NSPS fundamental training, pay pool management, and so on. But there is no centrally developed or provided training and organizations are left to their own devises. In some cases, the PEO will train the trainers who can in turn train other trainers who will in turn cascade it to the workforce. 4 Concerns: 1) Impact of pulling people away from other full time jobs; 2) Finding the right people with the right skills who can commit to the time; 3) Not a one time training need--will be recurring over the next 5 years; 4) Requires a span of time to complete the cascading training sessions. This would be more acceptable if we had the training materials finalized and 6-12 months to do. Really don’t think we can do a creditable job and achieve a real knowledge base in the 1-2 months allowed. This is especially so since we still don’t have the final regulations, nor the implementing regs.