| Comment Number: | OL-10506003 |
| Received: | 3/11/2005 10:18:56 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:
E.O. 12866, Regulatory Review "NSPS design requirements is to build a system... competitive, cost effective, and fiscally sound...also being flexible, credible, and trusted."..."expected that actual payroll costs under this system will be constrained by the amount budgeted for overall DoD payroll expenditures" Trust is mentioned several times in the document, and the NSPS framers recognize it as a core issue for success. Unfortunately, the NSPS is starting out in a hole with trust and credibility (a concern voiced in the majority of the website comments). Morale has already been lowered because of this lack of trust. Great emphasis needs to be placed on quickly developing and disseminating clear, concrete proposals that will gain this trust and credibility, not on optimistic euphemisms that throw up a red flag for most DoD employees. I'm not a disgruntled employee with mediocre ratings who should fear a performance based system on that basis alone. I'm a proud and dedicated DoD employee (seven years service) with a commited desire to work my whole career in DoD. I came in on a competitive fast track program, and consistently received very high ratings throughout my career. I'm fortunate I have an excellent and fair supervisor. In my department, all of my fellow workers are also excellent in their performance. Though this limits my annual performance bonus, since the GS system is a reasonable compromise (it does not always fairly reward but it also does not unfairly and subjectively punish), it hasn't really bothered me. I should be delighted with the chance for additional compensation for my performance. I fear, however, that the NSPS as proposed will inject so much subjectivity that many people will unfairly be punished or rewarded. The NSPS assumes that the overwhelming majority of supervisors are objective and fair (or perhaps will be through training?), but I seriously doubt this is the case. I'm clearly not alone in this observation. Without objective fairness, the NSPS will surely fail to achieve its objectives (and probably will be less effective than the current system). The NSPS admits that the total DoD civilian payroll will remain limited, so unfair reviews become a double edged sword...every dollar given away unfairly to one employee (one wrong) will also be unfairly taken away from another (another wrong). Yes, there are stated ways to protest an unfair rating, but for many people, that is a last-resort nuclear option. They may win for the short term, but the long term ill will it creates could come back to haunt them for years to come. Just because its stated in the regs doesn't mean it works in the real world. Although I'm not concerned about my supervisor's objectivity, I think my NSPS pay over time will be less. My department is only one part of my organization's "pay pool," My supervisor will be limited and unable to significantly increase my or my colleages' pay; just like our bonuses are now. Moreover, since the total DoD civpay is limited, the attempt to pay more for some career field (to attract and retain) would lower the amount available for other "pay pools," limiting their ability to fairly compensate. I know comparable people in non-DoD organizations are right now making more than me, and but I just don't think that the NSPS system will translate it to my pay. At this point, even though I'm a high performer, I trust the GS system more than the NSPS as proposed. SUGGESTION: Rather than pay band, retain GS system and use step increases as a means to reward or punish employees. Tie step increases to performance. Likewise, encourage and make it easier for supervisors to reward employees with advanced step increases (a tool which is available now, but not widely used). ADVANTAGE: DoD employees will more readily accept and trust a modification to an existing system while DoD supervisors will be better able to reward and punish employees.