| Comment Number: | OL-10500130 |
| Received: | 2/15/2005 10:56:10 AM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| Attachment: | Comments to NSPS.doc Download Adobe Reader |
Comments:
Performance Management—Subpart D The current performance management system is burdensome because of its actual and/or perceived inflexibility and strict adherence to written elements and standards established at the beginning of a rating cycle. Supervisors feel restricted in making any mid-course corrections or modifications to a performance plan, resulting in a final assessment that does not meet their needs. These static standards make it difficult for managers to adjust performance requirements and expectations in response to the Department’s rapidly changing work environment, hold individual employees accountable for those general and/or assignment-specific work requirements and expectations, and make meaningful distinctions in employee performance as they accomplish those assignments. The proposed regulations are designed to address these deficiencies. DoD has decided to waive the provisions of chapter 43 of title 5, U.S. Code, in order to design a performance management system that will complement and support the Department’s proposed performance based pay system described above. The proposed system will also ensure greater employee and supervisor accountability with respect to individual performance expectations, as well as organizational results. The proposed system builds in the flexibility to modify, amend, and change performance and behavioral expectations during the course of a performance year, subject to employees being advised of, and involved in to the maximum feasible extent, the adjusted expectations. For example, supervisors have the option of establishing and communicating performance expectations during the course of the appraisal period through specific work assignments or other means. These other means may include standard operating procedures, organizational directives, manuals, and other generally established job requirements that apply to employees in a particular occupation and/or unit. From the NSPS Website Questions and Comments: How will supervisors be accountable for exercising their responsibilities under NSPS? The flexibilities proposed in the NSPS regulations bring with them an increased need for accountability. This includes employee accountability for performance, as well as supervisory and managerial accountability for the proper exercise of the authorities in NSPS. Extensive training will be given to supervisors and managers, with a focus on improving skills needed for effective performance management, such as setting clear expectations, communicating with employees, and linking individual expectations to the goals and objectives of the organization. Supervisors and managers will be held accountable for how effectively they use the tools provided by NSPS. They will also be subject to the pay and performance provisions of the system, and their pay will be affected by how well they perform their duties as supervisors and managers. My Comment: Unless all of DoD, to include military personnel, fall under the NSPS, recommend DoD and/or OPM ensure ONLY civilian managers supervise civilian employees. At military installations, civilians are commonly supervised by military personnel. Civilians cannot hold military personnel accountable – only their military superiors and/or Congress can. Military personnel get promoted by testing, performance evaluations, and percentage of allowable promotions for each rank. Congress and the President set uniform pay increases for the military as part of the national budget distributed every January, regardless of rank or performance. This proposed system is creating two standards within DoD.