| Comment Number: | OL-10512024 |
| Received: | 3/16/2005 8:01:37 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:
Docket #NSPS-2005-001 (RIN 3206-AK76/0790-AH82, "Part II Dept of Defense OPM, 5 CFR Chptr XCIX andPart 9901 NSPS: Proposed Rule," dated Monday, Feb 14, 2005. 1. Section subtitled "The Case for Action." a. para 7. How, specifically, did "the attacks of Sept 11 make it clear that flexibility...is an absolute rqmt...of DoD civilian human resources mgmt?" In the entire history of the DoD civilian service, when have we not responded when there was a crisis? b. para 9. Here you state that the DoD sometimes uses contractors when it should use employees and vice versa. DoD execs are the ones formulating and executing the entire A-76 contracting out of federal jobs. If they are making bad decisions already, why should I feel confident that they have a clue what they are doing w/NSPS? c. para 9. The current system does not limit opps for civilians. We have unlimited opps in the DoD. If there is an administrative burden caused by the paperwork, perhaps it's because you've downsized most of the lower graded clerical employees out of existence! d. para 10. The collaborative process described here does not resemble any part of the process as you've implemented it. This commenting on the Fed Register is one of the most complicated I've ever had to use, and I'm a program analyst! My question is, was it designed to discourage comments from employees? It makes me think you really don't want our comments. e. para 10. The current system has provisions to reward employees who deserve rewards and deal with those who do not perform, BUT MANAGERS DON'T USE THEM NOW! WHAT MAKES YOU THINK THEY WILL USE THEM UNDER A NEW SYSTEM? f. para 10. How does NSPS "provide employees w/greater opps for career growth and mobility?" The opps are there now and mgmt won't pay to move people around. You don't adequately fund awards, or do much HR planning. You won't fill vacancies, and expect people to do more w/less, to the point that employees feel compelled resort to violence in the workplace just to be heard! 2. Section subtitled "Relationship to the Dept of Homeland Security." a. You are copying a system that has not yet been fully implemented, tested, or proved, and already speaking of it as if it were a great success. All you've done is created havoc and confusion in an arena that should be the most secure of all government's missions--the protection of its own soil and citizens! The reorganization that created DHS has done nothing more than severely hampered the performance of every employee in each organization swallowed by the bohemoth. It will probably take 10 years before everyone knows precisely who works for whom. b. You admit that the language in many cases is the same, but ask us not to "judge" DoD's new regs in comparison to DHS. Why not? 3. I am running out of space now so I'll wrap it up. a. You are making the same mistakes you've always made. You have assumed it is the employees who are at fault, when Deming taught us that 80 percent of problems are w/in MGMT's perview to change, not employees! Changing the game will not make the players play better. It's the managers who are responsible for the current state of the civilian DoD workforce. b. If you want people to be flexible and mobile and to volunteer to enter into harms way, that describes a military organization, not a civilian one. So why are you civilianizing military positions. Shouldn't you just spend the $ and authorize yourselves more military positions and leave alone the civilian service rules which do work when applied? c. Here's an example for you. One of my previous coworkers always coerced a performance award out of our previous manager by saying during his annual review that he'd file a greivance if he didn't get one. When he finally committed several acts for which he could have been outright fired, mgmt didn't have a leg to stand on. Your ambitious new system will change nothing. Thanks.