| Comment Number: | OL-10500919 |
| Received: | 2/22/2005 3:19:38 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:
NSPS, the new system, requires Agencies/Depts to align their personnel system with overall strategic planning (5-10 year plans which then set annual programs, and must include metrics). This implies related systems will also link to NSPS. As a result: Will OSD require Army to integrate NSPS with it's Strategic Readiness System before it can field NSPS (same for Navy/Air Force)? Will objective (program results) data be required, as it should, when there are objective results (pay/performance/promotions) available? (bogus subjective data distorts the NSPS purpose) Will leadership and laity be measured with the same metrics? No one should mind (and frankly everyone should embrace) having performance based pay if it's aligned with Agency and leadership pay/results. Witness widespread waste (e.g., FBI's hundreds of millions misspent on an IT sytem that won't work -- and no one "responsible" has been impacted as far as I can see -- and no one is asking them to be), we must avoid more BS. I'd also give the AFGE/unions a role to participate in certifying/validating that these personnel performance systems work, or to be the employees' agent when they do not. Doing so would go a long way toward employee acceptance of this process as fair and equitable. Will variations/excuses for minority/women performance be allowed? I see no reason to do so at or above the journeyman level. Will distinctions be made for the decisions actually made by each ratee at the level they operate at? If workers award contracts quickly and correctly, then leaders shouldn't get credit. If the leaders really lead change, accounting for that improvement, accomplishing change that workers cannot without political support; then credit is also due those leaders. Will administrative staff be sucked dry for the benefit of engineers and scientists, as occurred in Personnel Demonstration projects? Will supervisors be allowed to hire folks at any pay level, allowing distortion in the pay system and creating a reason to work somewhere else for that reason alone (e.g., getting a bigger raise that way than through the annual evaluation system). I suggest the pay follow the individual DOD-wide as the control. Will the suggestion program really be made to work and make available to employees the value of good ideas, and a share in savings soon to be offerred Industry for perhaps an identical idea? I suggest an independant and powerful ombudsman, and a website to post employee complaints. Successful appeals to the ombusdman would double or triple the amount due the employee as a penalty for unfair/late evaluations. How would a program (Missile Defense) set accountibility if there's a contractor or system design failure? Would the civil servant who documents warning superiors a system is not ready, whose advice is not heeded, be able to replace those leaders who ignored his advice, and were rightly fired when they failed? Will the good ol boy colonel, who ignored advice from civil servants, leading to a symbolic blow-up (or a real one) get an SES position when he retires? What if Congress didn't authorize funds for a possible fix, that led to the failure? Will contractor performance on programs also be objectively evaluated and fed into the past performance data base in a useful way? Who will audit/decry bogus results like accomplishing a truly paperless contracting process, which is reported to be paperless but is not? Would we question as less than robust an intern program whose purpose is to attract and train future leaders, but is in fact closer to an upward mobility program with middle or elder aged employees? Should there be a way to transition military retirees to these positions (a great idea -- makes military jobs more attractive and we get sharp/experienced individuals).