Comment Number: OL-10500893
Received: 2/22/2005 1:34:49 PM
Subject: Notice of Proposed Rulemaking, Request for Comment
Title: National Security Personnel System
CFR Citation: 5 CFR Chapter XCIX and Part 9901
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Comments:

Reference Subpart D / 9901.409. NSPS creates a multi-level performance rating system. Several years ago Air Force abolished a multi-level system and went with a pass-fail system to, among other things, counteract the Lake Woebegone effect (everybody is above average) that had resulted in about 99% of employees being given the highest ratings. NSPS will have to try to avoid that with a multi-level system. One way would be to use quotas, but no doubt that will be at least officially discouraged. Another way may be to have supervisors rate the complexity of employees' assignments, as a separate rating from the employees' performance. The rationale is that a wide range of assignment complexities will result from lumping what had been several grade levels under GS or FWS into one pay band. A reasonable case can be made that an employee who performs at an Excellent level (the next level down from the top in this example) while on one of the most difficult, complex assignments in the pay band, has contributed to the overall mission accomplishment at least as much if not more so than the employee who may have performed at an Outstanding level (the top rating in this example) while on an assignment that would be characterized as routine for that pay band. Such a rating could take the form of: Difficult/Most Complex, 7-9 points assigned; Routine/Difficult, 4-6 points; and Introductory/Routine, 1-3 points, with this rating being factored in with the employee's performance rating to determine performance pay. There are probably simpler methods of rating employees' assignments, but if NSPS does not have something like this employees will be increasingly unwilling to take on more difficult, challenging assignments.