| Comment Number: | OL-10503344 |
| Received: | 3/5/2005 1:43:12 AM |
| 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:
The new NSPS system needs to be revised and modified before being implemented. It has too many negative aspects that need to be mitigated. I have been a loyal and dedicated Federal employee for more than 25 years. While there are some good intentions in the NSPS plan, the overall outcome will be a reduction of pay, benefits and protections for civil service workers, increasing the opportunities for favoritism to be a factor in evaluations and promotions, decreasing morale, while putting more strain on my agencies already stretched budget. Agency budgets are already strained. The implementation of NSPS will consume more funding from existing budgets. Where will the funding come from for the NSPS training and for the start up and operational costs? Will it come out of each agency’s or department’s existing budget? It is stated that everyone will be trained on NSPS, but I would doubt that adequate additional funds will be allocated for that training, considering the current state of our Country’s deficit. My agency will either not be able to provide adequate training due to a lack of funds, or it will have to rob other budgets to provide funding. Performance evaluations are not fair or accurate and the NSPS plan will make it more difficult for agencies to balance workloads by moving personnel. It will actually reduce our flexibility to manage workload. Currently in my agency, workers are regularly moved to match the workload needs, to different work sites, locations, jobs and groups. This causes us to change supervisors frequently, which results in having multiple supervisors during an evaluation period. This often leads to the evaluating supervisor not actually knowing the employees work/skills/performance well enough to honestly and properly evaluate his or her performance. Inaccurate evaluations will deny many deserving employees raises or promotions, and will lead to employees becoming unwilling to change supervisors. Forcing unwilling employees to change positions to manage workload will damage morale, and it is a well studied and time proven fact that unhappy employees do not perform well and productivity will decrease. This will hinder our flexibility to manage workload and lead to decrease efficiency. Unqualified supervisors will accomplish the performance evaluations, which will penalize deserving employees. The latest management philosophy in my agency is that you do not need to actually know or understand the work that your employees accomplish, to be a manager. All the manager allegedly needs is good people handling skills. This leads to many of our supervisors not being able to resolve technical issues, answer employee questions or be able to make the best decisions, due to a lack of experience in the areas that they manage. This in turn raises the question of how they are qualified to honestly evaluate an employees performance, when they do not know how to accomplish the work that their employees are assigned to perform. Favoritism will be a major factor deciding who gets raises, bonuses, and promotions. With the new NSPS system, pay raises and bonuses will mostly be determined by favoritism at many agencies. There will be a certain level of funds available for raises and bonuses at each agency. This limited funding will translate into a certain percentage of employees who can receive raises/bonuses/promotions each year. The outcome will be that only 10 to 15 percent of the highest rated people will be rewarded. Human nature dictates that the majority of the lucky recipients will be rewarded on the basis of favoritism. Here in my agency you can greatly improve your evaluations and advancement opportunities by learning to play golf or softball well, and joining the appropriate league, with the right people. However, it is also very beneficial in my department if you have the same religious affiliation as the person who has the final say on the departmental promotions. I am not exaggerating in any of this, I have worked for this agency for more than 25 years. I am sorry that I cannot give you my name or agency, but it is not worth the retaliation that I would be subjected to. The new performance based evaluations will cause intelligent people to not willingly change to a new position. You never receive a good rating in my agency for at least the first year of holding a new position, so you will at least sacrifice one year’s raise/bonus, and at the worst case, with the new disciplinary rules, you will risk a disciplinary reduction in pay with virtually no real means to appeal, if things do not go well in learning a new position. This will be a disincentive for employees to take on new positions and will also make it more difficult for management to manage workloads, since personnel will be less willing to move, change to an unknown supervisor, or learn a new position. This will not improve personnel systems. The limited Union protections that are already in place for Federal workers do not need to be reduced. This is a very negative consequence of the new NSPS system. This reduction of Union protections is proof to most employees that there is reason to fear implementation of the new NSPS system. Not reducing the already limited Union protections would go a long way to reassure civil service employees that NSPS may not be as negative as it appears. Why does the Administration fear or resent the limited Union protections that are currently in place?