| Comment Number: | OL-10507477 |
| Received: | 3/14/2005 11:28:57 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:
1. “Currently, pay and the movement of personnel are pegged to outdated, narrowly defined work definitions, hiring processes are cumbersome, high performers and low performers are paid alike, and the labor system encourages a dispute-oriented, adversarial relationship between management and labor. “ Yes, high performers and low performers are paid alike. But that also means that everyone is treated equally. Women are paid the same as men. Blacks are paid the same as whites and Hispanics. There is no discrimination of pay based upon race, creed, religion, or sex. Once supervisors can set pay scales, bias and prejudice will work their way into the pay system in some cases. No supervisor will ever admit to having a bias against an employee, but it can happen and the NSPS gives them the means to discriminate against the employee. This paragraph also states that, “hiring processes are cumbersome”. It later states, “The proposed regulations also address the need to compete for the best talent available by providing the Department with the ability to streamline and accelerate the recruitment process.” The NSPS also states the “hiring official will determine starting pay based on available labor market considerations; specific qualification requirements; scarcity of qualified applicants; program needs; education or experience of the candidate; and other criteria as appropriate.” Later it is stated that, “The proposed regulations eliminate the category of ‘‘career conditional employment;’’ under NSPS, those employees may be hired directly into the career service.” But there is nothing substantive that shows that the process of hiring an employee will in any way be quicker or more efficient. The employee can be paid more to begin with and be a career employee sooner, but that’s it. Until the cumbersome Civilian Personnel System is dismantled and brought back to the system of local civilian personnel offices that handles all phases of hiring a government employee at the place where he will be working, hiring a government employee will be a long, drawn out process. Under the current system, applications are sent off to a regional Civilian Personnel Operations Center (CPOC) where applications are computer scanned for referral and then sent back to the local Civilian Personnel Advisory Center (CPAC) for referral to the command for selection. The concept of regional personnel operations centers may have increased somebody’s efficiency but it has not helped future and present government employees or the management trying to hire and manage those employees. 2. The NSPS states, “…supervisors and managers will be held accountable for clearly and effectively communicating expectations and providing timely feedback regarding behavior and performance. The document does not state how this will occur. Although it does say, “DoD is committed to providing its employees, supervisors, and managers with extensive training on the new performance management system and its relationship to other HR policies and programs.” My personal experience (25 years of government service) has shown me that training is a great thing, but if there is not an enforcement mechanism behind it, all the training in the world will not matter. 3. The NSPS states, “Further, supervisors and managers will have a broad range of options for dealing with unacceptable performance. These include but are not limited to remedial training, an improvement period, a reassignment, an oral warning, a letter of counseling, a written reprimand, or adverse action defined in subpart G of these proposed regulations, including a reduction in rate of basic pay or pay band.” Within the context of dealing with unacceptable performance, a reassignment is a BAD idea. Reassigning someone to another job does not solve a problem, it only passes it along to someone else. Now a new office is affected by an individual who was, in essence, fired from their previous job.