| Comment Number: | OL-10512104 |
| Received: | 3/16/2005 9:23:16 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:
I disagree with the premise for the "National Security Personnel System". Good managers manage well under any personnel system. If the current system isn't working well it is because our top managers, including the President within the Executive Branch, have not hired and invested in the best available talent. The proposed NSPS does nothing to alter that conclusion. If anything it introduces a vague personnel system which introduces whimsey (AKA "Flexibility) as a critical management skill. We've seen the dark side of vague "results oriented" management controls in the behavior of federal military employees and contractors in Iraq's prisons. Should we perpetuate the same here? The 15 step pay scale was introduced because of abuses such as unearned and rapid pay advances for relatives and political supporters or those who paid kickbacks. The new system of pay banding reintroduces the potential risks of the old patronage system. I've seen it happen with office affairs and relatives of managers but at least it was moderated by time-in-grade and step-increase rules. Within the Defense Department, the largest Federal employer, NSPS will make it extremely likely that retiring military officers will join the workforce, regardless of skill or merit, at higher levels of pay and will advance rapidly because of the military culture and their membership in the "old boys club". If you want to promote performance based on merit, this trend, furthered by the elimination of the "double dip" penalty, will have to be managed better. Further, as orgnizational budgets tighten, it is extremely likely that awards money will go towards balancing agency budgets as they have in recent years when training and awards have been curtailed or eliminated. If this system proceeds, financial controls will need to be proscribed to keep this from happening. I'm also concerned that the implementation will penalize older workers who are at higher steps, having forgone raises in years past in accepting the framework of the 10 step 15 grade system with the time in grade requirements. These older workers in higher steps or grades will be making more than younger workers, yet their performance will be rewarded less under a pay banding system which seeks to advance social goals such as "equal pay for equal work" . If both groups perform equally they should be rewarded equally each year, not rewarded disproportionately based on the delta in present salaries. Finally, the message in the NSPS seems to be that employees, and their unions, pose some threat to national security with their demands for fairness, dignity, and security in the workplace. That's the wrong message, and it has the same crude hateful tone that was evident in public debate before tragedies like the Oklahoma City bombing. Most Federal workers are loyal, hard-working exceptional people who give 120% every day, take home work and come in unpaid on weekends if that's what it takes to get the mission done. Let's not make their job harder or cause them to take their talents elsewhere.