| Comment Number: | OL-10511748 |
| Received: | 3/16/2005 5:09:19 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:
General Comments: The civil service system was originally established to stop the abuses that were taking place in the politically motivated patronage system in use at the time (late 19th century). Unqualified relatives and friends of elected officials wasted taxpayer money.Nepotism and fraud were rampant, and qualified public servants could be fired without just cause. As the current civil system was adopted and modified over the past 130 years, employee rights involving mediation, arbitration, fair pay, and safe and reasonable working conditions were added to the system, increasing employee morale and fostering teamwork. This team effort helped America succeed in World War II, Korea, Vietnam, and bring an end to the Cold War, as well as current conflicts, The response of DOD's civilian personnel during the recent conflicts was immediate, as opposed to the inefficient and unsuccessful responses of some of the contractors. No system is perfect, there are some flaws; but tossing a well-proved system to enact an unknown quantity (as the NSPS is) makes little or no sense at all. During a recent briefing given by the government's own representative to explain the NSPS, a number of very specific questions were asked regarding how the pay-for-performance system would be enacted, what performance criteria would be used, what our rights would for personnel action would be, etc. The rep's answers mainly were that "we haven't developed those regulations yet." Why, then, are we adopting a system where the rules would be made up as the gov't goes along? The military has a responsibility to this country to defend the rights of ALL of our citizens, yet the NSPS is structured to strip away rights of all Civil Servants! SPECIFIC COMMENTS: PAY-FOR-PERFORMANCE: This is a concept that has been used previously to determine performance awards. It was a failure. The very subjectivity of the employee ratings doomed it. Personnel prefences and prejudices of management and the "good-old-boy system" rewarded the "in" crowd and left outsiders out of the money. Even when specific objectives for each rating were developed, supposedly to take any subjectivity out of it, management was able to skew the ratings through their interpretations, which seemed to vary from individual to individual. No other management action killed employee morale than these ratings. In addtion, NSPS proposes to use this as a factor to determine RIF status. STREAMLINING THE MILITARY TO MAKE IT MORE EFFICIENT: Presumably this would include cost-efficient. How many millions, if not billions of dollars will it take to effect these changes-- new pay bands to be developed, new job descriptions, new implementation stategies, developing interpretaions for rules and regulations that have not even been developed yet?? This is a very problematic system that no one seems able to, or at least willing to explain. EMPLOYEE RIGHTS: For many years now, employee unions have served to represent the rights and interests of Federal employees, providing information and support in a way that an individual worker would not be able to do. They represent employee interests to Congress, and provide interpretation of rules and regulations, as well as representation in official and legal actions and appeals of decisions. Rights of appeal to a neutral arbitrator for fair resolutions of problems is a Federal employees hard-earned right. NSPS would destroy that right. Instead, a board selected by the government would hear appeals, and regardless of the outcome, it could be overturned by the Secretary of Defense. This is power that no one person should have, and is contrary to American principles of equality. PAY BANDING: This was tried before involving awards. In this case, it was pre-determined that only a certain percentage of people could receive awards, leaving others out, regardless of performance. This scenario may occur again when pay bands are defined. A real morale-buster.