| Comment Number: | OL-10503727 |
| Received: | 3/7/2005 1:37:28 PM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| Attachment: | NSPS Comments.txt Download Adobe Reader |
Comments:
RE: National Security Personnel System. I must first say I expected far more "hard info" from the regulations released on 14 Feb 05. DoD has had plenty time from when the intent for the NSPS was published in the Federal Register in 2003 to Feb 05 to decide on some concrete ways to implement the NSPS; unfortunately, the information published on 14 Feb 05 is more vague than the proposal from 2003. It is hard to prepare an informed comment to the proposed regulation without have a document which sufficiently describes what the regulation is. The lack of details have caused a great deal of stress in the workforce. As far as the labor relations aspects of the NSPS and the procedures for dealing with poorly performing employees, I support them. My concerns are focused on two areas: Performance evaluations and premium pay. 1. A "pay for performance" system would idealy reward employees who outperform/exceed stated expectations. The increase in pay would be provided as an incentive for increased performance. On the face of it, this is a "good thing". However, this concept has been borrowed from the business world. The business world's only concern is making money, either in profit or increased shareholder value. All employee activities in a business are judged in light of how they effect the bottom line. Functions that do not contribute to the bottom line, and the employees that perform them, are eliminated. Almost all businesses use objective, measureable metrics to judge employee (and hence business) performance. An assembly line worker may be judged on how fast he bolts on a particular part, or the number of assembly errors he makes. A salesman may be judged on the amount of product he sells, the value or number of sales contracts, etc. The problem in universally applying this particular business practice to the governmentis that many aspects of government service have no objective, measureable metrics that an employee can influence. I am a criminal investigator (GS-1811) for a military criminal investigation orgainzation. There are NO objective, measureable metrics with which a supervisor can fairly evaluate my performance. I cannot be fairly evaluated based on how many cases I open or closed, as I do not decide if a case is opened or closed, my supervisor does that. I cannot be fairly evaluated based on how many cases I solve, as I do not decide if a case is solved, my supervisor does that. I cannot be fairly evaluated based on how many cases are accepted for prosecution, the US Attorney or other prosecutive authority does that. I cannot be fairly evaluated based on how many cases are successfuly prosecuted, that's up to the prosecutor, judge and jury. I cannot be fairly evaluated based on how much money is recovered from convicted subjects, the jury and judge decide that. There is nothing else that I do that involves a documented, quantative measure. My supervisor decides what cases I work on, what I need to do on a case, and when I am done with it. The degree to which a criminal investigation is successful is not proportional to the amount of work performed by or the skill of the investigator. Some cases are "slam dunks", that just fall in your lap; others are "whodunits" that Sherlock Holmes could not solve. One investigator could work himself to death 20 hours a day for months and never make headway on a case, while a collegue could have a multi-million, multiple subject case basically just handed to him by a source. Also, an investigation is just as successful if it is determined no crime occurred or the Government was at fault as it would be if a crime was identified and subjects titled in a report; however, those kind of statistics are not as "sexy" as the others, and hence are given less weight in the subjective determination of "success". (see attached document for my full comments)