| Comment Number: | OL-10502914 |
| Received: | 3/3/2005 12:29:49 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:
There exists a serious conflict between one of the seven NSPS Guiding Principles; Ensuring accountability at all levels, and using active duty military personnel to supervise civilian employees. Currently there are thousands of civilian employees in DoD who are supervised and evaluated by both noncommissioned and commissioned active duty personnel. One key to accountability and fairness that is promoted as a check and balance in NSPS is for a supervisor’s own evaluation to be influenced by their ability to accurately and fairly evaluate their subordinates. These military supervisors are not evaluated under current law and their performance will not be evaluated using the NSPS laws and regulations. Any lack of quality or timeliness effecting civilian evaluations on the part of military supervisors will not cause these military supervisors a cut in pay, nor will it affect their time-in-grade pay raises if performance requirements of NSPS are not met. Since the laws of NSPS do not apply to military supervisors, there will be no real supervisory accountability for inaccurate or untimely completion of civilian performance evaluations. The current Federal HR system insures that an employee is normally granted a Within Grade Increase on a specific anniversary date that does not correspond to the timely submittal of a performance evaluation. NSPS will tie performance evaluations directly to performance pay, and the timely submission of performance evaluations will be critical for pay pool managers to make final decisions on the distribution of monies in pay pools. Under NSPS this has the potential to cause a huge disparity between employees that are rated by civilians and those that are rated by military personnel.