Comment Number: 05-02582-EREG-104-d7391-c32137
Received: 3/4/2005 8:00:00 AM
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:

Comment on Regulatory Text Subpart D 9901.406
Setting and Communicating Performance Expectations - page 7586

I am concerned that the Department is not planning adequately for a performance management system that could severely impact their employees lives. I am in the first spiral to be implemented in July. The organization seems interested only in meeting their deadlines, not in taking the time to make good decisions and plans to make sure that it will be successful.

In a January 2004 report titled HUMAN CAPITAL Implementing Pay for Performance at Selected Personnel Demonstration Projects the General Accounting Office informed Congress that more work is needed. Excerpts from their report follow:

We strongly support the need to expand pay for performance in the federal government. How it is done, when it is done, and the basis on which it is done can make all the difference in whether such efforts are successful. High-performing organizations continuously review and revise their performance management systems to achieve results, accelerate change, and facilitate two-way communication throughout the year so that discussions about individual and organizational performance are integrated and ongoing.

Additional work is needed to strengthen efforts to ensure that performance management systems are tools to help them manage on a day-to-day basis.In particular, there are opportunities to use organizationwide competencies to evaluate employee performance that reinforce behaviors and actions that support the organization's mission, translate employee performance so that managers make meaningful distinctions between top and poor performers with objective and fact-based information, and provide information to employees about the results of the performance appraisals and pay decisions to ensure reasonable transparency and appropriate accountability mechanisms are in place. 

Overall, while the demonstration projects made some distinctions among employees performance, the data and experience to date show that making such meaningful distinctions remains a work in progress.

My organization changed our performance standards several years ago to make them very generic. They did not provide any discriminators or descriptors for any of the elements. Examples of the elements are Technical Competence, Mission Accomplishment, Communication, etc. We do not have any guidance on what makes our performance in any elements exceptional or highly successful, etc. They also de-linked pay from performance in 1999 by eliminating performance awards. All awards in the organization are now tied to specific projects. This is in direct contrast with their plans now to tie our pay and retention to performance.

Our management also sets quotas on how many employees can get exceptional, etc. There is also a lot of nepotism and favoritism in the organization. The organization has been fairly stagnant for many years with no new hiring and few reassignments. Relationships have been built and opinions formed. This does not provide much hope that performance appraisals are done fairly based on organizational goals. More time is needed to prepare strict guidelines and accountability to ascertain that this does not adversely impact good employees under the new personnel system.

The Department of Defense needs to show enough respect for the employees that have dedicated many years of their lives by taking the time to create the system right. We should see the final regulations before being asked to comment on such sweeping changes that could mean the difference in not only our careers but also our retirement.