| Comment Number: | OL-10502937 |
| Received: | 3/3/2005 1:44:33 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:
Despite directions to provide comments about specific sections, below are a few general remarks based on my personal experience with the Chicago District, US Army Corps of Engineers. I was fortunate to get my job. As a general rule, Chicago people hire Chicago people. The Pendleton Act and civil service system, however flawed, provide a measure to avoid a patronage system. The NSPS proposal returns federal employees to a system that was unfair and didn't work. I have no doubts that this proposal will not work and in a few years, we will return---at great expense---back to something similar to the current civil service system. The system needs to be tweaked, not changed. The proposed pay-for-performance enhances the current "good old boy" system. I have seen nothing in the NSPS to reflect managerial accountability. There are so many bad, unaccountable decisions being made by my organization, I am embarrassed to tell people where I work. I don't want to work somewhere where I can be suspected for 14 days and have no grievance rights or protection. The Federal Civil Service Reform Act of 1978 protects my fundamental rights; the NSPS does not. If I perform poorly, I agree that (at some point) I should be terminated. At the Chicago District, however, the poor performers seem to be promoted or become managers. Where, though, in the NSPS are there quantifiable, objective standards for performance? If I have an unsatisfactory performance now, my protection/remedies are Performance Assistance Plans (PAPs) and Performance Improvement Plans (PIPs). The NSPS eliminates those protections. One strike and you're out is blatantly bad policy. Management at the Chicago District does not possess the discretion to administer the proposed non-objective standards in a fair and equitable fashion. I also strenuously object to the automatic denial of annual pay adjustments, without being applied in a consistent fashion. Management in the Chicago District bases its inconsistent decisions on...who knows? Since Colonels come and go every 2-3 years, is there probably going to be consistency in the Colonels? No. Salaries and bonuses being funded by the Department of Defense is also another bad idea. At the Chicago District, we spend tens of thousands of dollars meeting to establish yearly goals to establish year-end bonuses. When we see we aren't going to reach the goals, we give ourselves points anyway or say "we meant to do it" so the miniscule DoD bonuses can be given. Relying on specific monies that can be appropriated elsewhere in the DoD is a slippery slope toward civilian employees. The proposal states that DoD managers will no longer be required to establish and communicate performance expectations through written performance elements and standards set at the beginning of the appraisal period. How can an employee effectively meet performance expectations when it will be optional for supervisors to communicate those expectations? That is like Animal House's DOUBLE SECRET PROBATION. A lot of work on NSPS is still needed.