Comment Number: OL-10500036
Received: 2/14/2005 5:00:46 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:

I am a senior employee within the Dept of Defense, in a professional series, and in a managerial/supervisory function within a primarily professional setting. I agree wholeheartedly that the existing TAPES (Army) performance evaluation system is in need of reform, and I agree that many of the tenants of NSPS are commendable. However, replacing the GS system with NSPS will not meet the stated NSPS goals – to the contrary. The current Army performance evaluation system allows for pay advancement for higher performers and is pay punitive to substandard workers. The system significantly promotes performance based worker retention during a RIF action (Subpart F). What Army TAPES does not do is provide adequate accounting and identification of purpose – employee evaluations are prone to supervisory abuse. Too often people do not get ahead by merit, but by serving their rater in less honorable ways. Providing reform and uniformity of that system would be the best approach and would provide for NSPS goals. The best approach would be for a performance based revision of the GS system. The departure from the GS system will create several problems (Subpart B). Many DoD employees have been employed by other government agencies. Leaving OPM structure will limit the ability of the DoD, and the federal government, to base their employment on talent as it is derived through the Merit System (this is not addressed in the Proposed Rules). The idea of replacing pay grade/step structure with shares in a pay pool (Subpart C) is flawed as it does not recognize organizations of excellence and is punitive to persons of excellence within such an organization. Workforce Shaping (Subpart F) is likewise flawed as it fails to recognize merit as a key indicator for job retention. The most disturbing concept of the Proposed Rules is Subpart D. There is little that can be done with accounting systems that cannot be overcome by raters who use their authority/power to unfairly manipulate their subordinates. As a manager/supervisor/rater of many years standing, the lack of institutional control over persons in superior positions has been most alarming. This is witnessed by supervisors who enforce both their professional and personal, even political opinions, by the power of their position. From there it gets worse – various forms of harassment to include sexual, gender and religious bias. These human predators will exploit the NSPS system. Do you really want to increase institutional power given managers/supervisors over people’s livelihoods? The safeguards stated in Subpart’s D,G, and H are a step backwards. DoD missions will suffer because superior employees are not going to be retained in inferior work places. The authors of NSPS have developed what they consider a good direction for managing the DoD Civilian workforce. Superficially, it may seem so. For those of us who are intimately involved in the daily campaign to employ the best, organize for the mission, and produce components essential for the best fighting force in the world, NSPS is naive. Why have people who are “experts” in human resources forgotten the most basic of tenants? Not much rigor in the formulation of NSPS. They needed to consult with the people who make things go before they tell them how to make it go. Careless. The private sector learned this lesson thirty-years ago. Change is needed, but NSPS is not. I hope that reevaluation will be in order, and before making personnel management changes to this great a degree, a more base-level approach must be put in place. Develop an approach that engages DoD civilian managers/supervisors in a forum where they will identify how to make personnel management reform workable. Again, the best approach would be for a performance based revision of the GS system with one of the components being this kind of forum.