| Comment Number: | OL-10507155 |
| Received: | 3/14/2005 9:10:45 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 am concerned about provisions contained in 5 CFR Chapter XCIX and Part 9901. While as a concept, "pay for performance" has a certain appeal, my concerns are with its execution. I do not see this as a political, at least not in terms of "party politics". While it certainly could become an issue of "office politics", the real problem I foresee is in the area of performance management. In my 30+ years of federal service, to include 28 years a military officer, it is rare, particularly at senior levels, that supervisors fully understand the tasks performed by those they are rating. As a result it is not uncommon for those being rated at the begining of the period to write (or at least draft) their performance measures and then at the end of the rating period write (draft) their performance. Previously, where pay was not directly tied to performance (only perhaps to a bonus, which is now rarely forthcoming), this was a minor issue. However, where pay now is driven by performance this is far from trivial. Accordingly, absent the abilitiy of those being rated to provide comments concerning the performance measures and actual performance, it should be prohibited that personnel would write (or draft) either performance measures or actual performance. I suggest that supervsors or managers who do not understand (or care) what their personnel do sufficiently to adequately set expectations and monitor performance are failing in one (or more) of their own performance measures and ought to be so assessed in their pay-for-performance.