| Comment Number: | OL-10507766 |
| Received: | 3/14/2005 2:55:22 PM |
| 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:
Federal Register Vol 70, #29, 14Feb05, pg 7561 Performance Mgmt Subpart D: This paragraph indicates it is too difficult to modify standards during the appraisal year. Nothing could be easier; as long as the minimum time span remains, standards can be modified as needed. Para 9901.406, 407 Setting and communicating performance expectations, and Monitoring performance and providing feedback. The USMC has had regulations in place for a two-tier acceptable/ unacceptable performance appraisal since 1998. Prior to that, the USMC had regulations in place for a 3-5 tiers. Since 1998, my standards were set on time once, twice they were set at the end of the appraisal period, twice they were set seven months into the 12-month appraisal period, and twice 8.5 months into the appraisal period. During 1992 through 1998 (the last year of the 3-5 tier system), my standards were set once on time, 5 times at the end of the appraisal period, and once 8 months into the appraisal period. The regulations for performance appraisals (both 2 and 3-5 tiers) included a requirement for supervisors to be rated on their supervisory responsibilities. I must pause to note here that in spite of the poor supervisory performance, my performance was outstanding in every way. Clearly, from 1992 through 2004, civilian performance appraisals were deemed 'nonvalue added', and supervisors were excused from following those regulations. In fact, on one occasion I was accused of "disloyalty" because I would not falsify the appraisal of record by backdating my signature. There is nothing that indicates supervisors will be any more accountable under the new regulations. It is simply a new system with the same supervisors in place; training on the mechanics of the format will not change attitudes. I recommend DoD enforce the regulations currently in place, rather than implement a new system with the same personnel in place. 9901.409 Rating and rewarding performance. The USMC's history of minimizing the civilian performance appraisal system has implications for their award process also. In allowing supervisors to "get by" , they also encourage arbitrary award decisions, including "all 12's in a branch will get the same award amount" and of course, there is favoritism based upon who is in the "know", who is personally known by the person, or small group who divides up the award pot of money. Indeed, the proposed regulations will make the process worse by allowing an individual or small group of managers to determine whose job is more valuable than someone else's. Truly, some positions have no visible value, yet efforts which I have participated in to remedy the situation, to add value to those positions, have been given only token attention as supervisors prefer the 'status quo'. Also, there is a new threat to career civilians: the USMC department which I am a part of has made it an unofficial policy to only hire retired Marines into the high grades; making those career civilians in the GS12/13 range hit an arbitrary glass ceiling. Recommend the proposed regulations be delayed until the issue of supervisory accountability be strongly addressed in those regulations. Scattered throughout the proposed regulation are references to "DOD implementing issuances" yet to be written. It is inappropriate to begin a new system prior to completion of these policy documents. Recommend the proposed regulations be delayed pending completion of the policy documents followed by their public review.