| Comment Number: | OL-10503184 |
| Received: | 3/4/2005 10:43:43 AM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| Attachment: | NSPS.DOC Download Adobe Reader |
Comments:
Implementation of NSPS in Department of Defense (DoD) should be delayed until an independent review of the classification of current DoD positions is performed by the Office of Personnel Management (OPM). Corrective action should be taken on those positions found to be misclassified. The corrective action being to assign positions the appropriate level of work that supports the assigned grade prior to conversion to the DoD pay banding classification system. This will ensure optimum efficiency and use of taxpayer funds and support the “equal pay should be provided for work of equal value” concept, prior to conversion to NSPS. There should be a provision for DoD departments to correct current problems in the misclassification of positions under the current General Schedule (GS), or Wage Grade (WG) system. Moving misclassified positions into a pay banding system, immediately corrupts the soundness of the pay band system. DoD should not be left to it’s own means to correct current positions that are misclassified. An efficient system of checks and balances requires that the Office of Personnel Management or another independent body oversee any effort to review and direct correction of misclassified positions. Once corrective actions occur then DoD should move to pay banding. There do not appear to be any internal controls built into the NSPS rules to identify penalties for willful misuse and abuse of the system for the personal gain of self or others. I recommend establishment and publication of such penalties. Misuse/abuse of the new system should be established as a mandatory removal offense. I recommend that to gather trust in the fairness of the system, data on the past years ratings of employees under current systems be marketed/shared during the “training” of employees. This data would show the factual percentages of various levels of performance ratings given in the past to employees. The point being that the factual information will hopefully show that supervisors have fairly evaluated employees in the past, and that is expected to continue. After implementation of NSPS pay for performance rules, any trends which show a major deviation from past results should be reviewed. Supervisors at all levels will need assistance in the administration/implementation of NSPS. Support positions should be structured and filled by OPM that have specific responsibilities for assisting supervisors in the efficient implementation of NSPS. Delegating those responsibilities to departments within DoD, or to Human Resources Offices within DoD will not bring about consistency in the application/implementation of NSPS. Pay for performance does relate to employees getting the opportunity to demonstrate their value to an organization. Supervisors should be held accountable for ensuring equity of assignments are made available to employees in the same work unit. Otherwise there may be limited opportunities for some employees to succeed or to perform those tasks deemed worthy of performance based financial rewards. Funneling of opportunities to only a few select employees within the same work unit would be a discriminatory practice. The lack of specificity in some parts of the proposed rules, for example, 9901.211 Classification Structure, has obviously been a practice people normally are not used to when seeing new rules. This method assumes that the rule makers will “do the right thing” and those being impacted should just trust the rule makers. With the rules having major impact, DoD should provide a process for any final rules to be further reviewed and allow for modifications.