| Comment Number: | EM-023011 |
| Received: | 3/16/2005 12:43:27 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:
SUPPLEMENTARY INFORMATION: The Case for Action: The current workforce, uniformed and civilian, already works as "one cohesive unit" toward the same goal and DoD civilians "complement and support the military around the world in every time zone, everyday." A new personnel system is not required for these purposes. The current system is not broken - the way it is managed is broken. The current system allows pay-for-performance through awards, but is not used correctly. Cash awards are typically across-the-board, or not at all, rather than targeted to high performers. The new system will likely be managed the same way. And, opportunities for career growth and mobility exist within the current system. Pay and Pay Administration--Subpart C Performance-Based Pay: It is likely that annual performance-based payouts will be figured on fund availability, rather than performance, in the same manner by which annual pay increases are currently determined. And, much more responsibility and burden is placed on managers, who don't have enough time to properly manage the current system. Performance Management--Subpart D Supervisors and managers are accountable for communicating expectations and providing feedback regarding behavior and performance under the current system. This is not being done well under the current system. Often, mid-point reviews are not conducted and performance appraisals are handed to employees for signature without comment. It is not uncommon for all (or most) employees within an organization to receive the same high rating. This will likely not change much under the proposed new system. Workforce Shaping--Subpart F: The order of the retention list for RIF purposes is not consistent with the pay-for-performance system. It places veterans' preference ahead of performance rating. Labor-Management Relations--Subpart I 7. Management Rights: "...it must be able to develop and rapidly deploy resources..." - unilaterally deploying civilians should not be permissible. Civilians did not join the uniformed services, they are here to support those troops. With current technologies, the need for co-location is not as great as in the past. The vast majority of support functions can be easily managed from a distance. "...the right to hire, assign and direct employees, and contract out." & "make determinations with respect to contracting out..." - What happens to A-76? The list of procedures for which bargaining is prohibited is too broad and extensive (i.e. tour of duty, assignment of employees to meet any operational demand, and whatever other actions may be necessary to carry out the Department's mission). All that said, the idea of a pay-for-performance system is a good one. However, the proposed rules and procedures are much too broad and will likely cause mass confusion and conflict. What is the rush?