| Comment Number: | OL-10505837 |
| Received: | 3/11/2005 9:00:27 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:
I have reviewed the proposed NSPS and have a number of comments/concerns. The details of the initial conversion are pretty sketchy. How will this conversion process work given the many demo projects, and the differences between them? What will happen to employees already in paybands who are at the top of the band? The probationary periods for employees - will all employees be under a probationary period upon conversion? It is not clear from the document! Having been under a payband demo for several years, I have seen that despite the best of intentions, the ratings are subjective and not objective (as is intended). Managers play favorites, and employees are graded on a curve. The RIF protections are not there in the current demo; the factors that count are dependent upon where you fall in your band, not how well you perform or how much you contributed to your organization. Also, under the current demo, whistle-blowers do get punished, and this proposed system gives them even less protection than the old system. The proposed NSPS makes me uncomfortable; an unethical manager (and there are unethical managers out there) can do serious damage to careers of employees who are trying to do the right thing. NSPS is trying to speed the process of getting rid of bad performers. It may also speed the process for an unethical manager to punish an employee they have a grudge against, with the employee having little chance to defend themself. This appears to be another instance of the current administrations' disdain for career civil servants. I could find little evidence of protections for employees actually written into the document. That in itself is worrying.