| Comment Number: | OL-10500577 |
| Received: | 2/18/2005 8:14:20 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:
Comment 1. §9901.910 Management rights. Paragraph (2) states that nothing in this subpart may affect the authority of any management official or supervisor of the Department……”…to assign work, make determinations with respect to contracting out,”….. HR 1588 – 230 Subtitle A – Department of Defense National Security Personnel System that authorizes the establishment of the National Security Personnel System (NSPS) does not provide any section pertaining to contracting out of personnel in determining how the departmental operations be conducted. This authority provides for the establishment of human resources management system, attracting highly qualified expert and special pay and benefits for certain employees outside the United States. Contracting out of certain portions of the DOD is part of meeting its mission and is necessary but I believe that NSPS provision should only be for transforming personnel system into pay for performance system and nothing else. Contracting out should be a separate issue. Comment 2. §5408 of H.R. 1588-254 “authorized appropriated funds to train supervisors, managers, and other individuals involved in the appraisal process on using performance management systems….” The proposed NSPS rules have a vast amount of articles that are vague and subject to implementation issuance of the department interpreting the NSPS rules. Does training of supervisors and managers regarding the implementation of NSPS has not been completed? §9901.408 (Developing performance and addressing poor performance), §9901.409 (Rating and rewarding performance), The development of appraisal standards and multi-level rating system will require a thorough understanding of multiple layers of duties and responsibilities and how it differs from each division within the department. In order to develop a fair and realistic appraisal standard takes a dedicated effort and not just crafted to satisfy new rules being implemented. If the goal of this rule is to adopt the changes in personnel system of the 21st century, and be fair across the board, a transitional appraisal and rating system should have been in place to adjust supervisors, managers and all the personnel within the system to the new system. This is to avoid the negative effects of the assessment cycle for the personnel on the Spiral 1 incremental cycle in case of application of vague rules that has not been tested was improperly applied. The affected employees cannot recover from inequities resulted from poor understanding of rules by everyone.