| Comment Number: | OL-10504474 |
| Received: | 3/9/2005 2:17:39 PM |
| 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 NSPS construct, concept of operations, and principles are commendable in theory but its success will hinge on the actual 'practices' of an organizations' leadership. I have a few observations and comments: - Recent complaints at NASA that the system unfairly rewarded the "inner circle" rather than apply and comply with a uniform performance criteria is a risk throughout all organizations. Creating a system that equitably rewards, recognizes, and awards deserving high-level performers will only be as effective as the collective ethics, integrity, and objectivity of key decision-makers. One tool that can be used is an electronic survey sent to all agency personnel that is outside of the Department (perhaps OPM) to provide anonymous collective input on key areas of that Dept and/or organizational unit. This will help mitigate fears of reprisal while providing input that can help better assess the culture and leadership, identify barriers to equitable implementation, and establish a followup mechanism for accountability. - The NSPS "rules" must be clearly understood by all and "opportunities" should be consistent and equal between peer groups and pay bands. For example, pre-positioning selected individuals into special or preferred positions, or non-competitive placements into positions that will be rewarded by year-end rankings as more mission critical or justified as "provided mission critical services' may be perceived as gaming the system. - Full and adequate disclosure to agency personnel should occur, to the maximum extent possible, on all decisions of extraordinary performance/pay/bonuses/awards. - Establish disincentives for gaming the system to discourage the abusive practices associated with assigning preferred positions or opportunities to favorites based on personality or bias rather than a record of performance and results. Unfairly weighting certain jobs or opportunities as more mission critical or justifying higher pay on nebulous justifications of services rendered. There are many other examples so the right incentives and disincentives should be established to mitigate such practices. - Any system will only be as effective and "good" as the integrity, ethics, fairness and objectivity of decision-makers who make pay decisions and determine or approve/change performance ratings and recommended bonuses/awards. - Clear understanding is needed on metrics and "rules" associated with agency contributions (services, products, outputs, results) to ensure fairness in ratings and shares. Defining and measuring 'quality' , timely, and 'impact' are also key factors to product or services. - Release and disclosure of any retention or ranking listings (competitive group retention list) by band or 'grade' that could be used in RIF or other purposes. Definition of tenure should include the factor of number of years in a grade rather than total years of service. For example, a manager with 30 years of service but only 1 year as a GS-14 manager should be lower on the tenure listing than another GS-14 manager with 5 years of experience but only 20 years of federal service, all other things being equal. Combining grades such as 14s and 15s into one pay band can blur or distort these type definitions and factors. Pay for performance and results is a logical byproduct of years of pushing GPRA and best business practices. Although the details of any NSPS pilot are important, the real challenge will be to instill the right incentives/disincentives to offset human nature and inherent risks associated with biased decisions, favoritism, 'good ole boy networks', and any potential gaming the rules for a select few to unfairly benefit.