| Comment Number: | OL-10507647 |
| Received: | 3/14/2005 1:39:20 PM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| Attachment: | NSPS comment union performance rating.doc Download Adobe Reader |
Comments:
The subject of performance ratings for full or part time union representatives is not addressed under NSPS. Also, Mary Lacey indicated during her Washington Post interview (23 Feb 2005) that the NSPS creators are still looking for ideas on how to rate full time union officials under NSPS pay-for-performance, and that ideas should be submitted. Although the union to which I belong does not have full time officials, it does have part time union leaders who spend a significant amount of their regular work hours on official time for union duties. Problems arise when it comes time for supervisors to rate these union officials, due to lack of understanding of official time and lack of formal guidance or clear case law on the subject. Under NSPS, with annual cost-of-living increases, pay raises, and RIF retention status tied more strongly to performance ratings, a sub-par rating could now be devastating to an employee who wants to serve as a union representative. The attached document is a MOU that our union has submitted to our management. It contains language that may be helpful to the NSPS creators. Essentially, full time representatives should get the mode performance appraisal given to their peers.