| Comment Number: | OL-10505033 |
| Received: | 3/10/2005 2:30:15 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 Commentary.doc Download Adobe Reader |
Comments:
This document is not transparent – i.e., it is not clear as to its intent nor is its content easily understood. It is, at best, a very misleading document. Employees were led to believe they would be commenting on the proposed regulations outlining the specifics of how NSPS would be implemented – not the type of regulations being proposed to outline/record those specifics. They were also led to believe what they had to say would influence the nature of those specifics – not the type of proposed regulations. There is tremendous disappointment, disgruntlement – and, to a large extent, a general feeling of betrayal and resentment – at the “semantic” gamesmanship employed by both OPM and DoD. As a result of this tactic, both OPM and DoD have spread a rug of distrust – if not mistrust – in the intent and benefit of the NSPS to employees. If they were up to bat in a baseball game, they’d already have a called strike; from a(n) fan’s (employee’s) perspective, they never got their bat off their shoulder. Also, this document is contrary to one of the intents of Paperwork Reduction Act – i.e., to eliminate or reduce non-value added government regulations, their attendant administrative processes (development, coordination, approval and implementation), and the costs related to the latter. This is a document that does no more than tell employees, their representatives and the public that they’re going to get regulations. They already knew that! Where are the regulations? This ploy is analogous to hiring someone to build you a house (i.e., have it up, ready to occupy and use, at the end of six months) and all you get delivered is a complex plan – a document saying they intend – to do so. From a performance management standpoint – the crux of the NSPS – this is purely and simply “unacceptable performance”. To drive this home, perhaps it would be appropriate for OPM & DoD managers at the highest levels (especially at the SES level) to be the first to be affected by maximum application of provision 9901.343 – Pay reduction (of 10%) based on unacceptable performance or conduct.” This document, from a taxpayer’s – and a DoD employee’s – perspective, has worsened, and not lessened, the already suspect credibility of both OPM and DoD regarding NSPS. The “success” of NSPS lies squarely on the shoulders, and in the hearts and minds, of DoD’s supervisors and managers. The same supervisors and managers whose inability to use – and ability to abuse (principally through inaction) – the performance management provisions and tools of the current Federal personnel system is at the root of the remedies NSPS is purporting to provide. The majority of this group has never truly supervised or managed – yet are getting paid as if they have. Speaking of “unacceptable performance”! How both OPM and DoD portend to change this ineffective group into an effective group – short of removing and replacing them – is beyond comprehension. What’s potentially more disturbing is the real probability that this was just a smoke screen – i.e., an exercise in futility. It is very real to all DoD employees (and their representatives, when appropriate) that neither OPM nor DoD had any real intention of paying any heed to, or acting with integrity, regarding any comments received. Assuming this document is to/must be retained – See Attachment!