| Comment Number: | OL-10501497 |
| Received: | 2/25/2005 1:22:29 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:
To Whom It May Concern: Following are my formal comments to the National Security Personnel System (NSPS) Proposed Rule, as published in the Federal Register, 14 Feb 05. The parenthetical cites refer to page numbers and headings found in that document. (Page 7553, The Case for Action). Most civilians, I feel, have had many opportunities to be flexible during their careers; they do not require NSPS to enforce that imperative. That ability to learn new skills was in place prior to September 11, 2001. Regarding risk-taking, many employees have received enough punishment for minor nonsuccesses that the needed cultural change will be hard in coming - particularly with the six-sigma perfection goals management seems to have – for their subordinates. (Page 7553/4, Authority to Establish a New HR System). I am very concerned about the tenuous connection the authors make between NSPS and national security throughout the document. If the change in Federal HR structure is so beneficial FOR ALL, it should stand on its own merits; its sale should not be tied to fear. (Page 7554, Authority to Establish a New HR System). As regards veterans’ preference, I believe our vets are owed preferential treatment in hiring for the sacrifices they have made in the defense of our country. Once, however, they are in the DoD civilian workforce, their performance should be measured exactly the same as that of non-veteran civilians. Not calling for this change along with all the others implicit in NSPS reduces the credibility of the new HR system. (Page 7555, Guiding Principles and Key Performance Parameters). Within an agile and responsive workforce, it must be remembered that civilian employees have not enlisted in the Armed Services. As such we are not deployable in the military sense. The civilian workforce provides process stability necessary for the smooth operation of Warfighter support functions. (Page 7561, Performance Management – Subpart D). The paragraph describing a need for performance plan flexibility (making mid-course corrections desired by management) essentially mandates chaos in requiring employees to continuously hit continually moving performance targets. This idea for continual reappraisals during the established appraisal period (constant jeopardy) features throughout this document. Reactive behaviors will be based on paranoia, and will be counterproductive to national defense. (Page 7562, Performance and Behavior Accountability). It is frightening to think of one’s behavior being “…tracked and measured…” under any circumstance, but especially when there appears to be no requirement under NSPS for precise guidance to be established and communicated by management on an ordered, regular basis. If sycophancy is the desired outcome, this policy may succeed; but risk-taking and innovation will not be outcomes. (Page 7565, Single Process and Standard for Action for Unacceptable Performance and Misconduct). The NSPS regulations will eliminate protection for employees to have set periods to improve performance before receiving an adverse action, apparently because management selects employees for their positions because the employees are well qualified. As I have said before, most civilian employees are already flexible, and have performed many different tasks. With every new task comes a learning curve, which must be recognized and accepted by management. (Page 7570, Management Rights). If there is no need to notify the union and complete negotiation before making workplace changes, this is a removal of employee rights and bargaining power, as well as a compromise of current proper due process. (Page 7577, 9901.103 Definitions). If unacceptable performance means the failure to meet one or more performance expectations, who will protect the employee from the arbitrary and capricious establishment of unreasonable performance expectations? And again, how often will the target be allowed to move? It would be very easy for management to prevent employee success regardless of employee action. Thank you for considering my input, A Concerned Civil Servant