| Comment Number: | OL-10511769 |
| Received: | 3/16/2005 5:15:58 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:
Section 9901.105 subpart (a) (f) and Section 9901.342: The process authorized by these sections create an enormous potential for inequities across DOD with respect to classification. OPM has always functioned as a "Check and Balance" with respect to classification to ensure equity across the government. The new requirement would only dictate that the Secretary inform OPM of a pending Implementing Issuances and provide for a comment period. The Secretary has no obligation to OPM to act on comments. One of the cornerstones of our entire government includes “Checks and Balances”. The executive, legislative and judicial branches function this way. Even though it can be slower and more costly, “Checks and Balances” are used in many processes to ensure equity, predictability and provide for consistant outcomes. I 'm sure our entire government would be more efficient if we just appointed a dictator. It would streamline government “decision making” and create huge “efficiencies” to all government processes and provide more flexibilities. That is the direction NSPS is taking us. Section 9901.342: As indicated above NSPS removes checks and balances. Ensuring pay for performance equitably between Services, Commands and geographic locations will be impossible if the local managers have as much influence as proposed. It is not that locality pay adjustments can’t be applied. That is already done under our current system. My concern goes like this: Example 1: Employee “A” works for a relatively liberal supervisor in a Naval research environment and performs his/her duties at an above average level. The area of the country where he/she works is more urban/suburban and culturally more liberal. Example 2: Employee “B” works for an Army Maintenance Depot that is under the Army Working Capital Fund and competition for work is more competitive than in example 1. He/she works for a more conservative supervisor. The employee performs his/her duties at an above average level. The area of the country where he/she works is more rural and the local culture is significantly more conservative and frugal. In examples 1 and 2 above I can guarantee that Employee “A” will consistently receive higher pay raises than employee “B” even though their performance is the same. I have worked in both examples 1 and 2 and can tell you without any doubt that huge inequities will occur over time if this “NSPS pay for performance plan” is implemented.