Comment Number: 05-02582-EREG-238-d7391-c32385
Received: 3/16/2005 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:

The new regulation assumes that supervisors who will implement the new policy have sufficient formal training to perform the duties required. Supervisory training in the government is poor at best.

We have a current system in place to withhold step increases for non-performers, but the procedure to do so is rarely if ever initiated. We have performance evaluation system that is continually abused. Almost everyone gets exceptional ratings, to include non-performers. The new system will not correct that problem. We will have entire sections where everyone will be at the highest level possible because the supervisor is a friend to everyone and other areas where nobody will get increases because the supervisor has the power to do so...

Where is the system of checks and balances to ensure policy is implemented fairly and without favoritism. How do remove the obvious potential abuses of using the power given the usually inadequately trained supervisor to reward or punish employees.

Working in an area that always has severe budget shortfalls, I can see how limiting or withholding pay raises will be able to be used a tool to manage budget constraints, regardless of your performance.

I can also see much greater moral problems - especially if new hires are brought in at the same or higher pay rate of a person who has many years of service.

I don't believe I am exaggerating when I say increase workplace violence could result if supervisors exercise the authority to withhold salary increases from poor performers.

The problems that have existed with past systems will continue and I believe will be abused more with the new system because many people selected as supervisors should not be supervisor, the proper training of supervisors does not exist and there is not system of checks and balances to ensure supervisors/employees do not abuse the system.

I believe the system is completely open to far more corruption than the current system and will severely impact our ability to accomplish our mission. In the end the problems created will have a negative impact on those we serve - our soldiers - and that is unacceptable.