| Comment Number: | OL-10507371 |
| Received: | 3/14/2005 10:36:02 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:
I would not approve until an outside independent agency conducts a review of defense civil servant systems to ensure strengths are retained, deficiencies are addressed and 2nd and 3rd order impacts are defined. The analysis team (page 7555) that created the NSPS are senior graded individuals are not in touch with issues at the “grass roots” level where most management takes place and most personnel interaction occurs. They did not substantiate the need for change nor develop a system that addresses the factors that will hinder NSPS implementation. Bottom line: a flawed plan based on skewed assessments in an attempt to change for change sake and not considering issues that made the old system cumbersome and will continue to plague the new system. The need for change unsubstantiated. Page 7553 cites the current system as “inflexible, one-size-fits-all” for “defining work, hiring staff, managing people, assessing and rewarding performance and advancing personnel. The claim that the current system has “inherent weakness” is not substantiated. All civil servants employed by any Government entity need to be flexible and adaptive? We all must have a commitment to the organization? Ask any DAC if they follow the guiding principles (page 7555) they would say yes and the current system IF APPLIED PROPERLY is sufficient. The team proposes a new system without considering the factors that plague the old system and remain unchanged. Soldiers do not know how to manage the civilians, never learned the OLD system and will never learn the new system relegating it to a sub-optimally managed program. Kenneth Blanchard states: “There is nothing so unequal as treating un-equals equally.” There is nothing in this plan that addresses the requirement of the military to learn and apply this new system. Without oversight AT ALL ECHELONS, the fears expressed by so many employees will be realized. What are the facts? Look at the number of military who attend ANY formal training on dealing with civilians. Less than 1% attend any of the formal or informal training. The military has never and will never emphasized that civilians are different. In the past several years, DA changed the civilian performance appraisal to mirror military appraisals. It was too difficult for soldiers to learn a new system so they made the forms look alike. We do not have a system that fosters employee growth and accurate performance assessments. Nothing in the new system will change this fact. The next issue comes with costs associated with implementation. Most career moves are done within the local commuting area to avoid having to pay relocation expenses. In my last computation, most DA organizations only pay relocation expenses for less than 10% of all positions (to include senior graded position). If this new system is implemented AS ADVERTISED the costs to implement the flexibility would be significantly higher than current. It is very easy to see a system implemented without the funding needed relegating the new system to failure but not resourcing a major premise. All services have made many personnel changes. DA regionalized support on a hub-and-spoke concept which (corroborated by others) created a less than functional personnel system with no uniform centralized management of training and development and poor training and development management . Look at the number of managers (military and civilian), Army wide, required to take the “Basic Supervisory” “LEAD” “OLE” and “PME.” We are not getting supervisors of civilians to training. This fatal flaw in the old system that, if corrected, would accomplish most of what is needed to meet the NSPS objectives. DA uses the “RESUMIX” system to select employees. All first line and mid-level managers acknowledge that it is not meeting our needs CHECK IT OUT! If the hiring system is fixed, another major goal of the NSPS could be met simply by working what already exists.