| Comment Number: | EM-022940 |
| Received: | 3/16/2005 3:41:08 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 16, 2005 DoD NSPS Comments , DoD NSPS Comments: I have worked for DOD for 30 years. I would like to comment on one aspect of the proposed NSPS Regulations - RIF retention rules. (The deadline for comments is here, so I apologize, if my understanding is incorrect about this subject.). I understand that NSPS RIF retention will be based mainly on the most recent performance appraisal. Under NSPS, as I understand it, seniority is always subordinate to the performance appraisal group. I think this should be adjusted so that seniority is the major factor except for the people in the lowest and highest performance groups. In addition, the highest performance group should be refined to include more than one performance appraisal. The percentages in the highest and lowest groups should be about 5%. Perfomance appraisals are a problem because they tend to be inflated and subjective. These limitations are acceptable when it comes to handing out bonuses, but they are not acceptable for RIF retention purposes. The use of one performance appraisal is much too subjective as the criteria for RIF retention. Here are some reasons why: 1. Jobs that are harder to measure tend to get higher performance appraisals, because the rater has nothing concrete to justify a lower rating than what the worker desires. 2. People doing performance appraisals naturally will apply the same standards in different ways. For whatever reason, some will be more generous than others. 3. Standards that try to eliminate the subjectivity by counting mistakes tend to suppress people, because they don't want to make a mistake. When mistakes do happen, it becomes important to assess blame. (When you are downsizing, a lot could rest on who gets the blame). 4. Some performance appraisals, like it or not, will be affected by personal issues. Having said all this, I have found that appraisals as a whole tend to be fair. The same people tend to be rated highly regardless of who is doing the ratings. However, ratings can easily go up or down one level depending on who is doing the rating in a given year. To summarize, performance should not be used as the major RIF retention criteria except for the very highest and lowest performers. It should not be used for the high performers either, if this group is inflated or defined based on too little input. Sincerely,