| Comment Number: | OL-10506367 |
| Received: | 3/11/2005 2:19:52 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:
In reading the proposed regulation I have mixed emotions. One major flaw from the old regulations that will still exist. That flaw is the unwillingness of civilian supervisors to outline in writing the performance deficiency, corrective action and a defined timeframe to correct the shortfall of an employee. The new regulation does not clearly require this step and even goes to the extreme of allowing “oral” warning (9901.408(b)(1)) etc. Once again you have given that weak leader the axe to eliminate a good employee by not requiring them to do the right thing. If the situation or behavior is truly a problem then the supervisor should effectively document the problem. But to deny a good employee who has a less than ideal relationships with their supervisors his / her pay increase by stating that “he or she was verbally counseled on the matter” is dead wrong. My reasoning on this issue is first hand experience. I am a retired senior Non-commissioned officer. Prior to my retirement from active duty I held numerous leadership positions for both soldiers and civilians. As an NCO I required myself and the NCO’s that worked for me to sit down with all employees and in writing counsel them on what the standards were both professionally and personally. We also outlined in writing what the person was doing well, what they needed improvement in, how they could improve and a defined period of time to correct any deficiency. Later as a senior NCO and working with our civilian workforce on numerous occasions I had civilian supervisors come to me regarding poor performance of thier subordinate civilian employees. At that point I would require them to provide me written counseling of the problem area and what attempts / methods were used to correct the poor performance prior to recommendation for any type of adverse action. It is at that point in time when the civilian supervisor stated they had no written documentation. The supervisor was then instructed to provide the written documentation in the future prior to any type of adverse action for a poor performer. And as a rule the employees poor performance continued because supervisors were reluctant to sit down face-to-face and in writing inform that person they were not meeting the standard. The proposed regulation is vague at best in clearly defining how standards and corrective action are to be communicated. Under the new proposed system raises several questions: o Will communication then gravitate to the point that items adverse in nature will create a trend towards “oral” communication because the supervisor is unwilling to document the item? o Will changes in job standards be communicated “orally” rather than in writing and later try to hold the employee to that standard creating again an uncertain work environment? o Will supervisors communicate “orally” to only one of several employees a new or revised standard and hold those that were not informed to that standard? This lack of clear, concise written communication creates a working environment that is short of chaos because no one knows what the standard is or that it may have changed. Some examples of the vague means of communication are as follows: § 9901.406 (b) Supervisors and managers will communicate performance expectations, including those that may affect an employee’s retention in the job. Setting and Communicating Performance Expectations - Supervisors and managers must establish performance expectations and communicate them to employees. I ask that before you institute a new system that we at least fix the problem from the last one. Hold our supervisors responsible to do the right thing and effectively communicate in writing standards for performance of duty and also clear guidance of communication. Do not create a system in which supervisors create an environment based on confusion and chaos and select few are given favoritism.