| Comment Number: | EM-017589 |
| Received: | 3/12/2005 3:09:28 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:
March 12, 2005 DoD NSPS Comments , DoD NSPS Comments: TO: THE HONORABLE EARL BLUMENAUER, PETER DEFAZIO, DARLENE HOOLEY, GORDON SMITH, GREG WALDEN, DAVID WU, RON WYDEN AND TO WHOM IT MAY CONCERN AT THE DEPARTMENT OF DEFENSE FROM: SUBJECT: Comments on Proposed NSPS Regulations--RIN 3206-AK76/0790-AH82 I am currently employed with the Department of Justice in the Bureau of Prisons (BOP) and I believe that the regulations being implemented in the Department of Defense (DOD) will soon be applied with whom I am employed with. This causes me great concern as I see some of the changes do not have the low level employees best interest in mind and give managers wide sweeping authority to rule as they see fit. While I do not disagree with all parts of the system some of the areas I do include: Pay for performance ? In my experience performance appraisals tend to be subjective in nature and not objective. The rating criteria in performance appraisals are often vague and nonspecific. This allows management to rate employees high or low without definable or measurable standards in either case. Also unless an employee works under direct line supervision, their performance appraisals are based on a minimal amount of manager observation. Some examples of this would include enforcement officers for the US Marshals, Border Patrol and Custody officers in the BOP (I imagine the DOD has similar positions). Often working in the field these officers only contact with management may be at the beginning or end of their shifts. Setting and communicating performance expectations ? While management may need to change performance expectations as the job requirements change, the rating criteria should remain stable from rating period to rating period. It concerns me that not only are the rating criteria vague and nonspecific but that under the new system managers could change them at a whim and with no warning or input from the affected employee. Challenging a rating ? As I have detailed above my concerns with the new pay system, it is baffling to me that employees will not even be allowed to file a grievance on their performance appraisals or have any form of redress on their pay adjustments. As it is a competitive pay system based on performance, employees should have the right to not only grieve pay related issues but also to have a open system where employees in like positions can see the specific justifications for someone being rated higher then another (full disclosure). RIF ? Since reduction in force is to be expanded and linked to employee performance, my concerns with the performance appraisals rating criteria and there application is only increased. Time frames ? I am uncertain how the new time frames for adverse actions will work but I wonder who is helped by limiting who an employee may use as their representative. In addition to the above noted issues I have seen that the new system will strip the related unions of their bargaining authority and essentially make the federal government a ?right to work? employer. I thank you for your time and consideration. Sincerely,