| Comment Number: | OL-10507227 |
| Received: | 3/14/2005 9:31:02 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:
The proposal claims it is a performance-based pay system, yet it limits increases in the rate of basic pay regardless of performance. 9901.342, d(3). And, pay reduction for substandard performance is also limited to 10% unless changed to a lower pay band. 9901.343 So, it is really a pay for performance up to a maximum amount; after that, any additional performance remains unrewarded, and any substandard performance below a minimum amount remains rewarded. This system appears to be nothing other than a rewrite of the current system that has some small element of pay for performance; however, in the federal government, it will quickly degenerate into pay for toadies. Those who ensure their supervisors are aware of all they do and curry favor will receive pay raises, while those who work hard but are not on the radar screen of the supervisor will not. The system is the first and only one in the DOD; it obviously has not been proposed or accepted for the military, who are paid by rank and years of service. If it is acceptable for some, why not for all? Is there a concern that civilian employees are somehow more underpaid than their military counterparts? If so, perhaps a system similar to the military's would suffice. This system is easy to implement when the worker's productivity is measurable in discrete, fungible outputs, but when the work is not so measurable, as in the case of reviewing regulations, how is a supervisor to develop a fair and measurable reviewing system? Is one detailed discrimination case defended at the MSPB and on appeal the same as five simple cases settled? How can an outside observer (or the employees) be assured that the supervisor who rates one above the other has a fair and objective rating system? Under the current system, the rating has less effect on the pay, and affects only an annual additional bonus pay. However, under this proposed system, the rating is the basis for the pay amount. How does one balance the difference between raters when two individuals have the same job requirements but different raters, who provide different ratings? How will raters, who have little training in evaluating and counseling workers, clearly communicate the employee's requirements and steps necessary to maximize pay? What happens to an employee who, due to no fault of his own, has several supervisors during a rating period, none of whom give the employee the overall rating he deserves for the entire period? A good goal, but a means to the goal that falls way short, and actually opens the agency and the employees to more uncertainty in rating, performance, and pay. I predict that there will be employees who would otherwise provide good performance who will leave rather than face this uncertainty that is unparalleled in any other government service.