Comment Number: OL-10503712
Received: 3/7/2005 1:25:22 PM
Subject: Notice of Proposed Rulemaking, Request for Comment
Title: National Security Personnel System
CFR Citation: 5 CFR Chapter XCIX and Part 9901
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Comments:

Thank you for the opportunity to provide comments, ask questions, and request information. A written response to each question would be greatly appreciated. 1. How is the NSPS performance management system linked to the DoN’s strategic plans, related goals and desired outcomes? (part 2) How does the NSPS performance management system result in meaningful distinctions in an individual employees performance? This should include considerations of critical competencies and concrete results? 2. How has the DoN involved employees, their representatives, and other stakeholders in the design of the system, including having employees involved in validating any competencies, as appropriate? 3. How has the DoN assured that certain pre-decisional safeguards exist to help achieve the consistency, equity, non-discrimination, and non politicization of the performance management process (e.g. independent reasonableness reviews by Human Capital Offices, and/or Offices of Opportunity and Inclusiveness or their equivalent in connection with the establishment and implementation of a performance appraisal system, as well as reviews of performance rating decisions, pay determinations, and promotion actions before they are finalized to ensure they are merit-based; internal grievance processes to address employee complaints; and pay panels whose membership is predominately made up of career officials who would consider the results of the performance appraisal process and other information in connection with final pay decisions). 4. How has the DoN assured there are reasonable transparency and appropriate accountability mechanisms in connection with the results of the performance management process (e.g. publish overall results of performance management and pay decisions while protecting individual confidentiality, and report periodically on internal assessments and employee survey results). 5. Is the proposed performance evaluation process a 360-degree evaluation, where peers, management, and subordinates rate an individual? A 360-degree evaluation system would more fairly recognize who is performing, rather than relying on one data point -- a supervisor's opinion. 6. Regarding union representation - although the Union will still exist, NSPS regulations provides no means to force management to abide by any contract except in court, which is costly. Many small unions will not be able to support lengthy litigations. Regarding these concerns, how can smaller unions enforce worker management agreements under the impending NSPS regulations without prohibitive court costs being incurred? 7. Will pay increases vary by individual? Will there be a maximum award and a minimal award? Will the supervisor be forced to evenly distribute pay increases or rewards? 8. What will fund the training this new system?