| Comment Number: | OL-10502550 |
| Received: | 3/2/2005 12:15:07 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:
The NSPS seems to be a system that is long overdue, and I’m all for it. However, as I’m sure you’re aware, there are considerable risks. To help mitigate these risks, I have 2 suggestions: (1) develop strong internal controls; and (2) aggressively followup implementation of your plan. 1. Internal controls. I strongly suggest that you add a robust system of internal controls to your plan. Specifically, institute a system of checks and balances that would deter and detect any abuses, most notably those involving unfair favoritism in handing out raises. In reading through the comments sent to you thus far, it’s plain to see that there is a great deal of angst about supervisors abusing the system to unfairly reward employees based on something other than outstanding performance. I think that a robust system of internal controls, aggressively implemented, could alleviate many of these concerns. A thorough risk analysis of what is most likely to go wrong could point you towards areas of the NSPS that would need especially robust controls to ensure success of the program. In addition to unfair favoritism in handing out raises, areas that seem to me to be most vulnerable are ensuring that there is adequate funding for raises, and ensuring that funding for raises is not diverted to some other endeavor. I’m sure that your risk analysis will point out other areas that are particularly vulnerable. 2. Followup the implementation. Any system, no matter how well planned and no matter how lofty its goals, is only as good as its implementation. In my career I’ve seen some very strong DoD endeavors go awry and almost crash and burn because their implementation wasn’t carefully scrutinized and followed up to ensure that the endeavor was meeting the intent of its creators. Three prime examples are the Government Purchase Card, the Government Travel Card, and the Army’s Installation Management Agency. All were great ideas, had the promise of good things to come, but stumbled and fell because lower echelon leaders either didn’t pay attention to what they were supposed to do, or sabotaged the programs by finding ways around the rules or loopholes in the internal controls systems - and top level officials failed to aggressively followup to ensure that lower echelons were implementing the programs the way they were intended. Please don’t allow this to happen again with NSPS - use the lessons learned from these other endeavors to enhance implementation of NSPS. If abuses in NSPS are tolerated or left undiscovered, it will surely put an undue strain on an already heavily taxed and perplexed workforce, not to mention the fallout from Congress and the press. You now have a great opportunity to avoid this problem by designing a robust system of internal controls, and by aggressively monitoring implementation of the program. Thank you for the opportunity to comment. Hope this helps.