| Comment Number: | OL-10502838 |
| Received: | 3/3/2005 8:28:35 AM |
| 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:
Why might a pay for performance program be unsuccessful? Pay for performance may not work for several reasons. Employees may not believe their performance will lead to payoffs, i.e. it may not be accurately evaluated, or it may not be connected to the performance targets (line of sight). Employees may decide that outstanding performance will reduce group cohesiveness, which may have a higher value. On the other hand, the program may not be adequately funded, so the amount paid out for performance may not be viewed as a sufficient return. The millions of dollars in training costs that will be expended to implement the NSPS could have produced the same desired increase in productivity under DOD’s current pay system. Employee performance is most affected by the employees’ perception of their value to the mission, their management, and their co-workers. Any supervisor-employee collaboration and training along the lines of better alignment between goals and performance standards and giving objective feedback would be beneficial under the current system. The pay grades or bands are of lesser importance in improving productivity. And changing the present system has risks. One risk involves unknown impacts to pay levels due to the local market effect and pay rates in different parts of the country. The proposal also states that compensation comparability will be met “to the maximum extent practicable” which seems to indicate there is no guarantee that pay levels will not be adversely impacted. Budget constraints and unrealized gains in efficiency could also negatively impact the funds available in the future. The proposed system also hinges on effective supervisor feedback to employees. For many supervisors and managers, due to their personality and inherent nature, giving objective feedback is embarrassing and virtually impossible to do. It is unknown how much training would be needed to change a person’s nature. Some supervisors will be impossible to change, and the NSPS pay for performance system will be unfair to those unfortunate employees. Another risk involves the placement of employees. One of the goals of the NSPS is to speed up and streamline the hiring process. Yet there does not appear to be any definitive statement as to how this streamlining would be enabled. The proposal is also unclear on exactly how employees would be able to challenge performance ratings, how it would speed up the bargaining process, or limit situations subject to bargaining. Some real examples of all of these would be helpful in understanding. The bottom line is the NSPS appears to offer more risks to employees and greater flexibility to management. The NSPS attempts to offer something magically new to fix old disputes that could be improved under the current system in an incremental approach. When it comes to the challenges of human resource management, there is no silver bullet.