| Comment Number: | OL-10500297 |
| Received: | 2/16/2005 9:40:54 AM |
| 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:
Page 7552, The Case for Action, last sentence of second full paragraph. "NSPS is essential to the Department's efforts to create an environment in which the total force, uniformed personnel and civilians, thinks and operates as one cohesive unit." With this said, DoD civilian pay raises should be identical to those proposed for the DoD military. This has always been a controversial subject with the President. BREAK Page 7553, The Case for Action, 4th full paragraph. "Currently, pay and the movement of personnel are pegged to outdated, narrowly defined work definitions, hiring processes are cumbersome, high performers and low performers are paid alike, and the labor system encourages a dispute-oriented, adversarial relationship between management and labor." I wouldn't say that the labor system "encourages" a dispute-oriented, adversarial relationship between management and labor. The labor system gives us an avenue to pursue when we feel our rights are being violated. BREAK Page 7553, The Case for Action, 7th full paragraph. "Despite the professionalism and dedication of DoD civilian employees, the limitations imposed by the current personnel system often prevent managers from using civilian employees effectively. The Department sometimes uses military personnel or contractors when civilian employees could have and should have been the right answer." It's always the system's fault, never the managers! At our installation, progression of veteran civilian employees has been stifled by management. They want new, young blood, preferably with college degrees or vocational technical training certifications. Vacant government positions are restructured to accomodate them. In addition, the workforce is supplemented by many, many contractor personnel. And, guess who gets to train the newcomers? We mentor these newcomers only to watch them receive the jobs/promotions; and, we have no choice but to stand by and watch. Don't say that the limitations are imposed by the current personnel system; it's the managers imposing the limitations! BREAK Page 7555, Guiding Principles and Key Performance Parameters, 2nd paragraph, 1st bullet. "High Performing: Employees/supervisors are compensated/retained based on performance/contribution to mission." This should say employees/supervisors are compensated/retained based on favoritism, your club/lodge affiliation, personal favors to the boss, etc. BREAK Page 7555, Guiding Principles and Key Performance Parameters, 2nd paragraph, 3rd bullet. "Credible and Trusted: System assures openness, clarity, accountability and merit principles." Who is going to monitor NSPS and hold people/management accountable for wrongdoings? It's just like every other system; there will be NO accountability. BREAK Page 7561, Performance Management - Subpart D, 1st paragraph. "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. ...The proposed regulations are designed to address these deficiencies." Again, the real problem is being overlooked. The problem does not lie with the current system, but with the managers/supervisors using the current system. I am in the TAPES Senior System. The Support Form is a working document. Organizational priorities and goals may change during the rating cycle; individual Objectives should change as well. As new Objectives are added or Objectives change, are deleted, or are accomplished, the Rater and the Ratee should document the Support Form accordingly. We have a mechanism in place. It is just not being used. BREAK