PUBLIC SUBMISSION | As of: February 08, 2009 Comments Due: March 22, 2004 |
Docket: DHS-2004-0001
Department of Homeland Security Human Resources Management System
Comment On: DHS-2004-0001-0001
Department of Homeland Security Human Resources Management System; Proposed Rule
Document: DHS-2004-0001-0243
Anonymous comment focusing on " New proposal creates feudal state for civil service employees replacing employee performance with pandering and favoritism hindering agency operational efficiency."
Regarding DHS-2004-001/RIN 3206-AK31, the thirty day review period is not sufficient for a proper perusal and the subject period should be extended to a minimum of ninety days to allow all interested and affected parties to comment. A quick review of the material available seems to rest more on the agency's intent than the specific actions or procedures the agency, represented by its management structure, will have available. In fact, the proposal seems to be nothing more that the the imposition of a draconian disciplinary system centered on the removal of employee protections under the law by invoking national security. It appears that DHS Secretary Tom Ridge and OPM Director Kay James enhanced system will produce a workforce more concerned with retaining their employment by pandering to managers (engendering favortism) instead of performing their jobs. A poor management decision considering that the repeatedly stated goal of the DHS is combating terrorism and securing the nation's borders.
Again, the time period provided is not sufficient for a proper review of the proposed regulations. Instead of reversing decades of legal change in the civil service system and the creating a feudal state that will be ran by a series of appointed party favorites, an independent review of the agency's "success" to date should be conducted by Congress. In addition, a critical assessment must be made of how these changes are to make the agency more operationally efficient and must include an understanding of how the proposed changes will create an intrenched system rife with abuse and favoritism undermining operational efficiency.