| Comment Number: | OL-10501360 |
| Received: | 2/24/2005 4:53:06 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:
All comments are directed to the unique nature of federal service, which is not structured around maximizing profits or free enterprise. Federal employees are expected to provide essential value to the country, supporting work that can not be conducted, for many reasons, by for-profit entities. Hence, judging value in federal service is challenging, since there is not an equivalent, easy-to-define, yearend earnings. It has been my experience, after twenty-two years of federal service, that this difficulty in judging value subsequentially results in difficulties in measuring the performance of federal service managers - from first line supervisors and beyond. Given this, that there lacks any significant, tangibly, means or methods to evaluate the performance of the management chain, it is worrisome to grant additional controls and authorities to federal service managers. Performance, Workforce Shaping, and Labor Management Relations all are specific sections of the NSPS that would grant additional power to federal managers. It is unlikely that a creditable and independent governing organization could be established to measure, and specifically quantify, the value of federal service. Even if such an organization could be created, could they then root-out and deal with poor performing federal management? The only monitoring organization now in place are federal unions, which do help to maintain checks and balances. The changes that NSPS would bring are a reduction in bargaining rights for federal employees and a significant increase in the authority of federal service managers – without any verification that such changes would be effective. Hence, I am opposed to implementing the National Security Personnel System.