| Comment Number: | OL-10511852 |
| Received: | 3/16/2005 5:46:29 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:
• The proposed rule states that one guiding principle is: “Respect for the individual-protect rights guaranteed by law”. This statement should be unqualified. “Guaranteed by law” does not protect fat white men or long haired men with pimples or warts who pick their nose. “Guaranteed by law”, fosters an aura of, “we don’t like you, go someplace else”, which is contrary to the whole team building atmosphere which we are supposed to be striving to achieve. • The present system was established in part to prevent elected officials from using the civil service positions as political spoils – new system removes the safeguards. With pay for performance being decided ultimately by the pay pool panel, which owes its own pay to the senior leadership, the new system becomes a tool for managing political correctness. • The new rules eliminate the requirement to advertise vacancies. They leave it as an option. At management discretion, new hires can be given the best job opportunities, short circuiting the options of long time civilians. With out job postings, who is tracking wage and position distribution among employees? • There is currently an under current of hiring of retired or ‘ex’ military for senior level civilian positions. Currently these new hires are limited with respect to the grade they are classified. Under the new rules these individuals can be brought in at any salary level limiting the prospects for long term civilian employees who lack military experience. • The lack of uniform standards will lead to non-uniform appraisals and the establishment of the “good-ole-boy” promotion system. It will re-establish the “insider’ vs “outsider” view of the pay scale and ultimately disrupt the team efforts the Services are also trying to foster. • Having a bad supervisor could mean loss of pay or potential for promotion. Supervisors can be jealous, petty , and vindictive in their treatment of subordinates. With no standards to compare to how will it ever be determined? Performance based on contribution to mission is totally subject to local perceptions. This measure tips the balance of performance awarded money overwhelmingly toward those individuals in direct warfighter jobs completely and ignores the contributions of those in critical non-combatant roles. • The system eliminates the requirement for Service wide recruitment for new hires. It closes the door on opportunities for individuals to apply for positions outside their immediate geographical area. With the current emphasis on broad career base in the promotion system this will severely limit career opportunities. It leaves open the entire process for making career broadening moves at the discretion of the employees and places it solely in the hands of management. If an employee thinks his current position is unduly career limiting there are currently no provisions to change jobs short of leaving federal service. The processes are all TBD. This makes the whole system hard to swallow. • The proposed guidelines for RIF action threaten to eliminate options for employees. The new rules give management sole discretion to isolate, “bad apples” into a single unit and RIF that specific unit or function – with limited competitive areas employees caught in such a RIF have no re-course. What is to prevent management from hand picking the employees that get to keep their jobs? • Under the old system promotions were announced, based on the promotion it could be determined approximately how much an individual was being paid, one could compare others to their own pay and make a determination of the fairness of the system. Under the new system one could be sitting next to someone who is at the complete other end of the pay band and doing the same job. It increases the speculation, if not the actuality, that the system is unfair. Both of these circumstances are damaging to the system as a whole