| Comment Number: | OL-10503270 |
| Received: | 3/4/2005 3:12:00 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:
Section 9901.322: Rates of pay for pay bands should not be set initially at the top step of the existing grade level that forms the top of the pay band. Rather, they should be set with some overlap between the bands to allow for appropriate motivation and recognition of those who are currently at the top step of the existing grade. For example, if the top of a pay band is at GS-12 and the top of the pay band is set at the current maximum rate for GS-12, there will be insufficient flexibility to reward employees currently at GS-12 step 10. Building in an extra 10% or so would overcome this problem. Section 9901.409: Committing to the return to a multi-level appraisal system works against the objective of having a more streamlined and flexible civilian personnel system. Not only does this lock DoD into a particular type of system, thus limiting the flexibility to change, but also it brings back a much more complex, time-consuming system. One of benefits of the pass/fail system we have now is simplification of the appraisal process. Another benefit is that it limits competition among employees, thus helping to promote teamwork. Although a multi-tiered appraisal system may, in theory, allow supervisors to make better distinctions between employees and allow for better linkage to other personnel programs, supervisors have consistently demonstrated that they are unable to make these distinctions in a consistent, explainable manner. Quantitative standards or goals do not take normal process variation into account and often hold people accountable for outcomes that are beyond their control, so use of quantitative measures of performance is doomed to failure. Other types of standards are more subjective and thus subject to personal bias. Even when rating justifications contain obvious differences to support higher ratings, bias in assignment of work can account for the differences. Also, supervisors tended to assign inflated ratings under prior multi-tiered systems. It is unclear how the NSPS performance system will overcome these obstacles and succeed where other systems have failed. The performance system should also build in some checks and balances so supervisors don’t get superior ratings when all or most employees are satisfactory and organizational performance is mediocre. Secretary England was quoted in the Federal Times that the current civil service is outdated and needs to be replaced by a more modern system. Returning to the failed performance management concepts of the Civil Service Reform Act of 1978 will not accomplish that purpose.