| Comment Number: | OL-10504284 |
| Received: | 3/9/2005 12:01:20 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 proposed rules look amazingly like existing systems that have not been made to work correctly, especially in the area of performance management. Managers have received extensive training on developing elements and standards with input from employees; coaching and periodic counseling; modification of elements as/when duties change; and objective application of the performance plans at the end of the rating cycle. Has it worked? Like windshield wipers on a goat's patootie! So what is planned in the new and improved processes to make such a system work? What safeguards to assure equity both within and between organizations and branches of service, especially since the performance appraisal will now be the end all for pay adjustments aside from COLAs? The proposed classification system is worse. There have been no exhaustive studies of systems that currently use grade banding that demonstrate improved economy or efficiency. In fact, costs have increased markedly in such systems, primarily because managers do not manage well. Is there any tool projected to assure that management will manage better in the new system? Aren't they the same managers who have applied the current systems? Does the new system calculate a given value for a given level of work, and does it encourage prudent management of resources (no, I won't use the term "position management" here because it is jaded and has given too many managers musk ox eyes over the years)? This new classification system will be applied in a mixed military-civilian environment. The military personnel system is primarily a "rank-in-person" system, which often, unhesitatingly assigns personnel to duties far below their status and pay level. By the same token, the military system occasionally assigns personnel to positions far above their status and pay level. DoD historically has had problems when military managers want to apply the same "rank-in-person" principle to the utilization of civilian employees in the current graded classification system, e.g., "Old Fred has slowed down. Let's just assign him to an admin assignment, but without changing his pay, so we can put a bright young engineer in Fred's position." The grade band system will certainly make it easier to disguise this type of poor management. In summary, the NSPS proposed system appears to be a knee-jerk reaction that really isn't implementing anything that hasn't been proposed or effectuated before, and it will replace a system that has never been forced to operate properly, including major changes of the past such as CSRA of 1978, FEPCA, etc. Further, the new system increasingly removes human resources from the management team and relegates it to an administrative support activity. Aside from these minor problems, I'm sure the system will work well. "Those who danced were thought to be quite insane by those who could not hear the music." -Angela Monet