| Comment Number: | EM-022875 |
| Received: | 3/16/2005 3:35:55 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:
5 CFR Chapter XCIX and Part 9901 National Security Personnel System; Proposed Rule Comments: 1. Paragraph 9901.405 "Performance Management system requirements", sub-paragraph (c). Suggest the addition of (6) to read as follows: (6) Perform a yearly comparison across rating supervisors in similar technical areas (and pay bands) to ensure that employee performance rating are not subjectively inflated or depressed as a function of local management bias. Discussion of proposed change: At each geographic location within an agency, employee morale is negatively affected by significant disparities in performance evaluation within an organization (arbitrary and capricious differences). Top level management should be required to routinely look for mid-level managers who consistently rate above or below other managers within a similar (local) technical arena (pay band). While such a discrepancy is not a guarantee of bias, consistent differences in evaluation criteria within a pay band must be reviewed. 2. Paragraph 9901.406 "Setting and communicating performance expectations", suggest adding an additional sub-paragraph (f) to read as follows: (f) Supervisors and managers will themselves be evaluated based upon their ability to retain key technical employees. Performance evaluations of supervisors and managers will include a review of the number of employee transfers (excluding transfers for promotions and geographic relocation), and below average performance ratings. Patterns of excessive transfers and below average performance are considered an unsatisfactory reflection on the supervisor. Discussion of proposed change: Currently, while there are many excellent managers with DOD, there are also a few mid-level managers who are (bluntly) incompetent at supervising employees. These poor managers may be Doctorate level researchers who are excellent researchers. However, as part of their high grade level, they were assigned supervisory responsibilities for which they are incompetent. This fact must be recognized in the proposed rule and specifically addressed by DOD during the implementation of the rule. 3. General Comment: In implementing this rule, the DOD must not ignore the critical areas of logistics and configuration management (CM). Organizations typically deemphasize these areas during the design phase of critical military weapon systems, because of other pressing technical challenges. For example, if your tank cannon cannot meet its performance requirements, there is no point in spending money for writing repair procedures. Consequently, the pay bands or funding allocated for logistics and CM may suffer. This drives talented individuals out of those areas. Unfortunately, once fielded, the operation of the weapon system will suffer due to poor planning for maintenance and support. thank you for your consideration in this matter