Comment Number: OL-10500908
Received: 2/22/2005 2:44:12 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:

I do not find any reference to how pay will be set upon conversion other than to say no employee will lose pay. The workforce has a general assumption about that statement, and that is, no one loses pay on the day of conversion, but they start losing money from that day forward. One way to avoid this being a morale killer will be to show good faith and grandfather employees for the time they have accumulated towards their next step in the old system. If this isn't done, anyone with a significant amount of time accrued toward their next step will without a doubt strongly feel they have been cheated. Also, I may have overlooked it, but I do not see anything about annual cost of living raises. If they are to be part of the paypool and no longer granted to employees at the beginning of the calendar year it sends a very significant message to the workforce. I can't conceive of anything that will be more detrimental to the workforce's morale in general than taking away cost of living raises. My spouse worked under a payband system for the VA in St. Louis, MO, in the early 1990's. The VA incorporated annual costs of living into the payband process. She received no cost of living raise for four years in a row. While the cost of living was indeed going up, her pay was in reality of course going down considerably year by year. To make matters worse their pay band process did away with step increases and there were no provisions whatsover for annual appraisal awards/pay increases not coupled to promotion. The VA, by doing this, may well have made some budget goals, but the impact on the workforce was devastating and can not but helped to have had an impact on the quality of care those Veterans were receiving. The justification the VA gave? A pay panel saw no evidence that the cost of living had gone up in any of those four years. While the NSPS is not nearly so draconian since it allows for annual appraisals to impact bonuses and raises, doing away the cost of living raise is still not adviseable. On the other hand if the NSPS is designed to demoralize the federal workforce and allow for it to eventually be entirely contracted out, taking away annual "cost of living" (please think about what those three words mean) raises away from them will certainly speed along the process. Under Subpart D, 9901.401, Performance Management. My comment is this: As a supervisor and manager for the past 17 years, I welcome a change to the current process. It has been hardwired into something that looks like an Officer's Evaluation Report (OER) which is how military officers are rated. Officers in managerial positions over Civil Servants, want to be able to treat their civilians like they would junior officers. While this might be an idealistic goal, it is truly not practical with the civilian workforce. This is not because civilians are any less dedicated to the mission than officers are, but because the two systems are so vastly different with different objectives, career advancement structures and even different chains of command. Trying to "cookie cutter" a performance management system for one into something that works for the other is ingenuous at best. As part b. recommends, training for implementation will be critical as well as ongoing dialogue and feedback between management and the workforce on performance. If a reasonable, effective and practical system can be developed it will be a Godsend for everyone involved. On the other hand if an impractical, OER styled, system is forced "square peg into the round hole" fashion, it will probably not be much worse than the current system, but it will not be the tool needed to make "pay for performance" work.