| Comment Number: | EM-022863 |
| Received: | 3/17/2005 8:06:02 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:
5 CFR Chapter XCIX and Part 9901 RIN 3206-AK76/0790-AH82 National Security Personnel System GENERAL Frankly, I strongly suspect that these comments are irrelevant. DoD has decided to "WalMartize" its personnel management system--what could be a more "contemporary" and "performance-based" system?--regardless of the views of DoD employees, supervisors, and managers. DoD never made even a pretense of involving employees or their union representatives in designing this sytem. The "focus groups" DoD held last summer were, at best, a sham. DoD never published the results of the "focus groups" and certainly failed to include the recommendations of the employee focus groups held at Rock Island Arsenal. Nevertheless, I feel bound to offer what I consider constructive suggestions to improve the proposed NSPS regulations. Pay and Administration--Subpart C In a "performance-based" pay system, I believe that all employees who receive "acceptable" performance ratings (and I expect that about 95% of employees [both non-supervisors and supervisors] perform "acceptable" work) legitimately deserve to receive the basic annual percentage pay increase that Congress legislates and the President approves each year. The 5% of employees who are truly extraordinary performers--or miserable failures--deserve higher rewards and punishments--and DoD should have ample money to pay out increases to base pay and bonuses. I also contend that the minimum and maximum pay range in each pay band should automatically increase each year by the percentage authorized by Congress and the President. Performance Management - Subpart D The performance management and payout system must be wholly transparent to convince employees that it is fair, equitable, and actually based on real performance, rather than favoritism or cronyism. To ensure transparency, the agency must publish the performance ratings and payouts for all employees. Setting and Communicating Performance Expectations/Monitoring Performance and Providing Feedback Supervisors will need to improve by a quantum leap to make these nice phrases a reality. Under the Army's current TAPES system supervisors routinely fail to provide employees with timely standards or performance reviews--and standards for "senior system" employees (GS 9-12) are often pathetically inept. Supervisors will require extensive and intensive training and oversight by HR to become even minimally proficient in setting standards, evaluating employee performance, and COMMUNICATING! One feature of TAPES that I like--even though it is probably rarely used--is that standard setting should be a "collaborative" enterprise between the supervisor and employee. I am pleased to see that NSPS will include such "collaborative" employee involvement, but believe that it needs strengthening.