| Comment Number: | OL-10500781 |
| Received: | 2/21/2005 3:41:55 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:
- - Subpart C - Pay and Pay Administration – Performance-Based Pay – Rating Methodology - No rules are proposed pertaining to justification documentation required of raters. Requirements for very detailed written justification of rater determinations must be added to the proposed rules. Otherwise, raters will use subjective decision making methods that might be based upon bias, prejudice, nepotism, and/or favoritism. Discriminating rater decisions will minimize and adversely skew the mission oriented positive performance factors of “seemingly unpopular” individuals. Currently, at certain commands within DOD, there exists a strongly encouraged common practice among technical managers to take the significant accomplishments of technical subordinates and make them their own. Under the proposed Pay Banding Plan, morally offensive “politics” of that kind will become a major negative factor in the future success of lower level subordinate individuals as technical managers seek to justify a higher rating for themselves alone. Within a group, rater evaluations of lower level workers under his purview will then continue to be governed by mere “feelings and impressions” presented by the technical manager instead of by verifiable substance related to the performance of the technical subordinate. Detailed documented rationale for ratings that is based upon specific work assignments should be mandated as a duty of the rater to justify and substantiate why each and every individual within his group of ratees, including those at lower levels, is given a particular evaluation. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Subpart C - Pay and Pay Administration – Performance-Based Pay – Performance Pay Pools - No rules are presented in the proposed rules pertaining to documentation obligations of Pay Pool Managers. Requirements for very detailed written justification of Pay Pool Panel determinations pertaining to each individual employee must be added to the proposed rules. Otherwise, like performance raters, the Pay Pool Panel and Pay Pool Managers will use subjective decision making methods that are based upon “politics.” Such discriminating pay determinations will minimize and discount the mission oriented positive performance of individuals with unwarranted poor reputations. Without documented substantiation, morally offensive “politics” of that kind can become a major factor in pay determinations, and compensation decisions would then be governed by mere “feelings.” Detailed written records for justifying why an individual is not given the same raise that others are given must become the duty of the pay pool panel for purposes of fairness.