| Comment Number: | OL-10511808 |
| Received: | 3/16/2005 5:28:32 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:
This plan does not contain enough details to properly evaluate all the sections, only projected yet unsubstantiated benefits. I base my comments on the plan as a whole. The plan is not about national security. I have worked for the Federal Government for 25 years and have never seen an instance where we were not able to rise up to any threat to our freedom. I know there are people waiting in line to help in all national emergencies, whether they are military, security, or natural disaster. There is no problem, and you should not use 9/11 as a ploy to develop a plan that gives managers carte blanche to manage without regard to employees. The system will develop employees that use each job as stepping stones so local knowledge is lost on a regular basis, people stay in positions long enough to disrupt processes with fad technologies and processes, and continuity of personnel will be non-existent. You can not efficiently and successfully execute long-term projects without that continuity. This system will not attract the best and brightest, unless on a temporary basis. People will be reluctant to join an organization where the work force is transient in nature and there is no potential for long-term stability. Mobility reassignments are emphasized in this new plan, but the argument is the proposal is no different than what is already in place. If that is the case, why is there a need to reestablish this managment tool? This may be a great way to handle active military personnel, but not civilians who want to serve their country but still maintain community roots. Will reassignments include paying for moving, access to acceptable schools, transfer of medical records and access to adequate medical care? I can't imagine this is cheaper and more efficient than the current system. There is genuine concern about pay loss. Though this may not occur during transition, it is possible that employees will lose pay based on performance issues even though those employees may historically be good performers. I know supervisors that never give employees exceptional ratings, while others give out too many. Some of these employees will be considered poor performers as part of a group and can be denied a pay raise. There is no way to equitably compare employees performing in similar functions for different supervisors. There is no guarantee funds will ever be available for pay increases, only for transition. This will be another issue for Federal Employees to confront every January as well as every performance rating. There are no guarantees beyond transition! This system strips the rights of employees to fair treatment and protection from poor management and will subject them to cronyism, favoritism, and other "good-ol-boy" practices that the Civil Service system has tried to eliminate over the years. The problem with this system is it is based on a false premise about national security, it provides best-case-scenario rhetoric on its benefits, and makes assumptions about the good intentions of managements. There are no details about how the system will be implemented, no details about how pay-for-performance will be enacted, what will constitute a poor performer, where funds will come from, how local market supplements will be determined, how pay-band ranges will be adjusted, and how managers will be prepared to implement the system. This system is a knee-jerk reaction to problems that do not exist. It has the potential to drive away good employees, provide attractive stepping stones to well-marketed yet unproven individuals, create an itinerant work force, destroy local historical knowledge, eliminate sense of local ownership and pride, and reduce Civil Servants to a "survival of the fittest" mentality that will set each employee against others in the pursuit of annual increases, promotions, and protections. These provisions will not only diminish the work force but will diminish communities as well.