| Comment Number: | OL-10501761 |
| Received: | 2/27/2005 9:49:21 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. Adverse Actions---Subpart G, #2. Mandatory Removal Offenses. “These proposed mandatory removal offenses would be identified in advance and made known to all employees…DoD has not yet identified a proposed list of such offenses.” Comments: Without a list of offenses, it is hardly responsible (or ethical) to implement the NSPS until the DoD has identified such offenses. Also, the focus of MRO appears to be violations pertaining mainly to National Security issues; therefore, the vast numbers of employees who are performing unacceptably still may not be subject to removal, thus defeating one of the purposes of the NSPS—to retain employees who are acceptable workers. Poorly thought out. 2. Performance Management---Subpart D, “Performance and Behavior Accountability” “By the same token, supervisors and managers will be held accountable for clearly and effectively communicating expectations and providing timely feedback regarding behavior and performance.” Comments: The current Civil Servant supervisors and managers as a whole, have not proven competent in their fields and have not produced well-motivated employees. They are not properly trained and/or simply lack managerial skills to motivate employees without mainly rewarding with short-term monetary incentives. Monetary rewards they receive do not have a strong correlation to their abilities and results. Very little, if any, have been elaborated in this proposed NSPS document to demonstrate the success of the current management system and nothing has been established to specify what will constitute managerial and supervisory accountability. To whom are they held accountable and under what specific criteria? There are no Stockholders to be accountable to and no profit motives in government—the NSPS falsely emulates the corporate setting in this regard—something that can never be realized in government.In addition, the average DoD employee is now required to complete annual Ethics training and pass a test. The biggest violators of ethics in the government have been the top level, senior managers. Why are they not required to take more frequent Ethics training and given severe penalties for violations? The NSPS does not address this very important topic for managers and supervisors. Much of their forthcoming NSPS assessments of employees will have a lot to do with Ethical conduct. I have heard many employees say that government managers and supervisors have frequently used favoritism as a basis for rating employees in the existing Pay-for-Performance systems. Managers are not skilled enough to establish fair and objective standards of performance. How are they expected to change overnight under the NSPS system? 3. Local Market Supplements—paras 9901.331 and 9901.332 Comments: Under para 9901.332, section (c) (5) “Cost of living allowances and post differentials under 5 U.S.C. 5941;” It is not clear whether or not the COLA areas such as Hawaii, Alaska, Puerto Rico, Virgin Islands, and Guam will continue to be given their COLA’s. Also, will the COLA’s be considered as basic pay for retirement purposes? Will these COLA areas also be given local market supplements—since they don’t currently receive any Locality Pay? 4. General reference to NSPS document: Comments: It appears that one of the major focus of the NSPS is to motivate workers based mainly on monetary incentives. Most Most MBA graduates know from classical hygiene factors on human motivation theory that money is a short-term motivator and self-actualization is the highest and most long-term motivator for employees. This NSPS plan is doomed to failure if it is based mainly on the theory of motivating employees through monetary incentives/disincentives. How will the NSPS sustain and motivate the “best” of workers once they are hired? Not been addressed.