| Comment Number: | OL-10501020 |
| Received: | 2/23/2005 9:13:54 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:
GENERAL - This switch to a new personel system is just a lame excuse to revert back to a personnel system that was replaced by the existing system. Although this new system is couched in flexibility in hiring and allowing for workforce shaping, it is no more than fostering the patronage system. GENERAL - The overall tone of the enabling rules is negative. It implies that there is no way to rid the inefficient or badly performing emplyees, but if one wishes to this can be done under the present system. It does take a lot of work but maybe that is not so bad. If managers were to use the present system the way it is supposed to be used, they could effect the same results athey expect from the new system. The present system has a similar evaluative process i.e. performance appraisal that if one does not meet the minimum numbers, they will not get an annual increase. If one gets continually low ratings there is a process in place where the manager can instigate a removal action. This action requires precise documentation and counseling and may take 2 -3 years. But it can be done. People are not just promoted because of longevity as has been stated in justifications for implementing this system. If someone is not fully satisfactory, then they don't get the next step increase. Page 7553, 1st Para. - What kind of word is "operationalized"? Page 7553 1st Para. - The terms "inflexible" and "one size fits all" are used to describe the existing system. There is no corrobaration for this description. It states further that high performers and low performers are paid alike. That is not true. If you get a high rating you get a higher percentage of the award either money or time off. As you drop in the ratings you get less. Hmmm, sounds like the system suggested in Table 2. Subpart D - This states that the current system is "burdesome" and "inflexible". This is only a perception of the supervisors who choose not to use the system in the area of performance ratings and evetually removing unproductive workers. Subpart F - This section speaks to a rationalization for doing a Reduction in Force action by using performance in lieu of lenghth of service. Is there a problem with personnel who have been in the service for any lenghth of time? Maybe if you can get rid of them you won't have to pay any annuity if they ever reach retirement age. I think that this may be the thrust of this regulation. Remove people before they reach retirement age and you minimize your payout. Brilliant!!!! Part 9901 - General - The overall thrust of the regulation will foment a return to the patronage system and encourage employee self aggrandizement and self promotion at the expense of their colleagues.