| Comment Number: | OL-10506749 |
| Received: | 3/12/2005 8:08:50 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 Subpart A, section 9901.103, Rating of Record, you state that a rating of record can be given to an employee as needed to reflect a substantial and sustained change in the employee's performance since the last rating of record. Under current regulations, an employee must be under performance objectives (in some form) at least 120 days to be rated on those objectives. How will this 120 day period be affected by the above section? No indication has been made of what training managers will be given to evaluate employees and what safeguards will be implemented to ensure that favoritism and cronyism do not return to the federal workforce. Managers have had the means to withhold raises, punish under-performing employees, and shape their offices under the GS system, but failed to do so. How will the managers' skills be improved under NSPS to prove that they are capable of leading, of making difficult decisions, and doing hard work that they have shirked in the past under the GS system? Why should I have faith in managers under NSPS when they have failed to perform in the past? With the reduction of employee ability to combat the impact cronyism and favoristism under the NSPS coupled with an utter lack of description of how MANAGEMENT will be forced to improve, I fail to see how this will improve productivity for the federal workforce. While the current GS system encourages workers to share information and support one another knowing that it is in their best interest and assistance will have no punitive effect, (NEW FOUND TEAMWORK) the NSPS will encourage competition among employees that could actually hurt productivity. Why should anyone help a co-worker if offering help has the potential to reduce future raises? The potential to detrimentally impact morale and productivity has not been addressed. In short, the NSPS regulations are high in detail on how they will limit employee ability to counteract poor management, but low on detail as to how managers will be trained, how standards will be expressed, and how this will make people more productive. Page 7576 Section 9901.102(d) Eligibility and Coverage: If NSPS is so wonderful, why aren't the SES's paid by it? Shouldn't our leaders lead by example? Page 7562 Monitoring Performance and Providing Feedback: This idea of replacing the culture of pay-for-longevity with pay-for-results-driven performance allows managers who finally gave hard working women a pay raise because they were out of excuses with a whole new set of excuses of why women don't meet their performance standards. Page 7564 Workforce Shaping Subpart F: NSPS allows DOD to RIF by line(s) of business, product line(s), organizational unit(s), and funding line(s) and will place all career employees in the same performance group. This enables DOD to save money by moving all workers approaching retirement age into a line of business, product line, organizational unit or funding line that is unproductive and using that logic RIF them with only 60 days notice even when that person was previously a high performer in another product line or organizational unit. This leaves a career government worker with no guarantees of receiving a retirement--just like some of the unethical commercial companies we have experienced in recent years. This flexibility is a new way of leaving high performers destitute when they approach retirement age. I was hired under one set of rules and am now being switched to a new game mid-career with the same supervisors that don't have to live with what they've generated. What political appointees don't realize is that FERS is already getting rid of motivated government employees and if they want to get rid of the CSRS employees all they have to do is offer early outs with no penalties and that would enable them to reach their quotas without re-writing the personnel system.