| Comment Number: | OL-10502922 |
| Received: | 3/3/2005 12:55:06 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:
Performance and Behavior Accountability - Seems like the regulation does not define or require a standard for "behavior or misconduct." This area is subjective and will cause conflict. Example: The acquisition specialist has to run by the FAR regulations. Many times management has mission needs that do not match the FAR requirements. So the specialist is between a rock and a hard place. Standards - Do not see any mentioned in reg. When evaluating contractor proposals, the law requires standards to be developed that anyone can pick up, read, and be able to perform the evaluation. Why not for federal employee performance. Without standards miscommunication/interpretation will occur and there will be difference of opinions on what is right and wrong. Standards need to be established that anyone can pick up and read and understand. This way both parties have a full understanding of the goals which prevents conflicts which can potentially have the supervisors spending more time with battling employees than accomplishing mission goals. Are the employees going to be held responsible for the action of others. Training - Quality/sufficient training for employees to understand this new personnel systems needs to be mandated so all understand how the game is to be played. Employee Rights - Employees should have the right to join the union of their choice, not dictated by social and educational levels as is the current practice with determining bargaining units. For maximim balance of power, union funding should be separate and not controlled by personnel departments. How long is an employee mandated to stay in a pay ban without management performing meaningfull development of the persons skill level. I believe the current regs say 15 yrs. Retention Standing - Ratings have to be fair if they are going to be used ahead of years in retention decisions. Age descrimination is going to occur. Example: Now we have to groups: Those older not in the DA intern program, and the younger ones that are. Who is currently getting the better opportunities to achieve and ratings? Will this be age descrimination. What about those without college degrees who have served the government for years? Mission Goals - Only usefull if organizations are required to develop yearly program plans. A team can be assigned to climb a mountain, but if each takes a different path, they are no longer a team. Reg needs to be simplified. Employees need standards, thresholds and objectives. Management needs a simple rating process that holds them responsible for employee performance and development. There needs to be a balance of power so that the organizations can manage the managers. Pay Bans - Should be included in the reg.