Comment Number: OL-10505897
Received: 3/11/2005 9:30:09 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 concerns with the overall (proposed) system. It seems to me that there will be too much room for supervisors to abuse employee rights. I can say this as a former supervisor of 23 civil servants. Supervisors will be in a position to use the threat of no pay increase to force employees to perform duties outside of their training and experience. When the employees fail to meet the standard, possibly due to no fault of their own, supervisors can initiate adverse personnel actions. These expedited hiring and promotion procedures will be ripe with opportunities for "good old boy" preference. I realize the current system has its flaws, but I truly believe the new system will have an adverse effect on the sense of stability and reliance on annual pay increases for civil servants to maintain their standard of living. If supervisors' (raters) appraisals will dictate employee pay, and supervisors are forced to rate using a pyramid system, I see a problem. In my office, we have a number of personnel that are exceptional performers. Why should our supervisor have to be the bad guy and limit pay increases just to stay within the limits. You can say that won't happen, but it will. I could go on for hours, but will stop with one final thought. All the expedited procedures are meant to limit employee rights, plain and simple.