| Comment Number: | OL-10501340 |
| Received: | 2/24/2005 4:26:49 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:
1) Subpart C - Pay Adjustment: Regulation states Initial entry into NSPS will ensure that each employee is placed in the appropiate pay band without loss of pay. Regulation needs to address minimum period of time after inital entry before any action can be taken that would result in a loss of pay. Recommend that this period of time should be minimum of three years for tenured employees, before an adverse action can impact their pay. 2) Subpart D - Performance and Behavior Accountability: Proposed regulation states that behavior / conduct, along with performance, are criteria for favorable or adverse action. Performance objectives need to be measurable and documented at start of rating period. This ensures employee understands what is expected, and provides an objective means to measure performance. The inclusion of behavior / conduct should be deleted unless unacceptable behavior can be clearly defined. If not, then these are purley subjective, and open the door for abuse by managers seeking retribution for non-performance related reasons. A manger should be prohibited from citing conduct as a reason for adverse action unless that conduct is included in the documented definitions of unacceptable behavior. 3) Subpart F - Single process and Standard for Action for Unacceptable Perfformance. The proposed regulations eliminate the the requirement for a formal, set-period for an employee to improve performance before management may take an adverse action. removable of this set-peroid of time removes an important check and ballance needed to preclude abuse by bad managers. It is just plain good management practise to counsel employees an help them improve their performance. By deleting the requirement for a set-period of time, DOD is promoting poor mangement skills and removing an imprortant check and ballance to prevent abuse by poor managers.