| Comment Number: | OL-10507483 |
| Received: | 3/14/2005 11:32:14 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 writing to express my extreme opposition to the proposed NSPS regulations with regard to the pay-for-performance system. My organization implemented the pay-for-performance pay banding system more than 4 years ago as part of a demonstration program, so I have first-hand experience with how this program is being applied within our agency. Although I agree with the principles of the pay-for-performance system, to ”attract, develop, retain, and reward high-performing employees through appropriate compensation,” in practice this system has had the opposite effect. Senior management officials have determined that the distribution of performance scores within our agency should represent a bell-shaped curve, and scores are ‘assigned’ to individuals by immediate supervisors to fit this target range of scores. While our previous rating system was based on specific, easily measured aspects of performance, such as number of reports and publications, number and size of projects managed, public presentations, etc., in the pay-for-performance system, the basis for assignment of performance scores is totally subjective, arbitrary and inconsistent. Worse yet, the scores reported by immediate supervisors are often ‘adjusted’ at the upper management level, to increase consistency of scores within the agency. Because the scores are subjective, employees have little opportunity to challenge when they feel they have received an inappropriately low score. The end result of all this is that the performance scores received by an individual have no relationship to his/her level of performance. Moral has suffered, and this system offers little incentive or rewards to consistent high performers as it is purported to do. In my opinion, the pay-for-performance system, as it is currently being implemented, possesses all the worst features that the Civil Service Act was intended to protect against. To implement this kind of system DoD-wide, would be a grave mistake that would have far-ranging detrimental effects on our entire workforce.