| Comment Number: | OL-10504007 |
| Received: | 3/8/2005 10:28:46 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:
It does not appear that training is required/mandated - either during implementation or after. Training will be the key to ensuring the new system is administered fairly and openly. There will be a large "fear factor" within the Department from employees regarding their performance reviews. Training must be mandated and funded for supervisors on a frequent basis (yearly) to help ensure fairness in evaluating performance. Training budgets will need to be reviewed to ensure they are sufficient to maintain training opportunities related to skill, conduct, and interpersonal relations for all employees. Without mandatory training specifically on NSPS, prior to and during the implementation, there will be limited opportunity to minimize the fear related to this major change. Additionally, there does not seem to be provisions protecting from "nepotism" or "favoritism" and as such we seem to be moving back to what caused the creation of the current system. Human nature does not change and without effective consequenses there will be real and perceived violations of the spirit and letter of the NSPS. Congress will need to maintain oversight of the number of high grades - GS-14 and above that are created during the period from implementation until November 2009. Without significant oversight organizations will become top-heavy, ineffective, and very expensive. We (DoD) do not need to add to this current problem by implementing this system without the oversight in place.