| Comment Number: | OL-10502980 |
| Received: | 3/3/2005 3:36:38 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:
I have over 25 years experience in the Federal Service, in both Defense and non-Defense agencies. I have served in personnel, organization management, and productivity areas, so I believe I have some relevant background on the implications of changing the current personnel management system. I believe the changes proposed will likely cause more harm than good. In contrast, there are other personnel policy changes that can and should be made that would do more to improve operations. First, change policies to make the DOD civilian workforce more mobile. Other federal agencies have highly mobile civilian workforces, but, simply as a matter of tradition, DOD has not required civilians to move - "only military move". This can and should change. Second, civilian career paths and ladders are poorly managed in DOD as opposed to many other federal agencies, and particularly when compared to military personnel. Much more can and should be done to develop effective, experienced, and motivated civilian employees. Third, and related to the second point, DOD civilians need more and better access to training, although the training situation has improved in recent years with use of, for example, Acq Corps training directives and modules. Last – if you really want to do something useful, address the looming “personnel train wreck” – a uniformly aging DOD civilian workforce that’s rapidly approaching mass retirement. Establishing good metrics is essential to systematically and objectively improving organization performance - "if you don't measure it, you don't mean it”. However, in my personal experience, when we, as productivity professionals, bring our knowledge, skills, and abilities to bear on a situation, and have a willing functional partner, we can usually develop reasonable metrics – but it takes effective professional guidance, focus, managers who are motivated to do “right things right”. Getting those components at one place at the same time is not an easy phenomenon to arrange. Even more rare is developing metrics (again, in a non-profit context) that are sustainable – clear and firm, but also flexible over time, suitable to serve as the long-term basis for meaningful change. Consider that profit organizations have accountants who undergo literally years of training to become proficient in measuring performance in terms of simple, objective, discrete, dollars and cents in the form of profit. Add to that layers of outside auditors, SEC accounting regulations, professional accounting standards boards, and public law, extensive potential criminal and financial penalties, and you STILL get serious people who will “game the system” and skew, even wholly falsify, performance results. Can you measure performance in non-profit organizations? Yes. Is likely that good performance measures will be developed on a widespread and consistent basis in DOD? Absolutely not, and to maintain otherwise simply blinks at reality, and ignores extensive academic and professional literature on the subject. What is probable is we’ll get some very smart and motivated managers who will develop ways to “game” the performance system to their narrow advantage, at the literal and figurative expense of the government and agency as a whole, the agency’s customers (in DOD’s case, fighting soldiers in the field), and (relevant to this commentary) the agency’s employees. Barring investing in employee training and development comparable to uniformed military (and even they have the UCMJ, and a rich tradition and culture of Duty, Honor, Country), effective, broad-based performance measurement and management in the non-profit sector is unrealistic. As much as we’d like to develop and implement a “Management Driven Performance Based Personnel System” that will improve organization performance, I don’t believe that in a non-profit organization the size and scope of DOD such a system can be developed and promulgated with good results.