| Comment Number: | OL-10507816 |
| Received: | 3/14/2005 3:24:21 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:
Docket number (NSPS 2005-001) or RIN 3206-AK76/0790-AH82 EO 12866, Regulatory Review: “While these flexibilities will improve DoD’s ability to attract and retain a high-performing workforce, it is expected that actual payroll costs under this system will be constrained by the amount budgeted for overall DoD pay roll expenditures”. 1.Continual mention is made regarding DoD’s need to recruit and retain high performing employees. What kind of documentation and metrics will be established as part of the evaluation process to reflect the difference between current recruitment quality and recruitment quality under NSPS? What’s the difference? Just how poor and inflexible is the current workforce? Define flexibility and agility? If the answer is multi-functional versus stove piped in occupational series, then take advantage of this authority to do away with occupational series and focus in stead on a flexibile competency-based HR system. 2. Establish a civilian pay account that can only be used for civ pay, bonus, awards etc. 3 “In the areas of training and HR automated systems, the costs associated with implementing NSPS will not be extensive, since DoD has significant training and IT infrastructures….:" a.Issue: DoD must focus training on supervisors to ensure they have the training necessary to implemement a fair and equitable pay for performance system. That is going to be costly - or, DoD has always had the training but never held management accountable to either attend or to use the skills provided to fairly rate work and to identify poor performers. Focus in this regulation provides management with less oversight (and greater freedoms to manage their worker pools) but what guarantees does the taxpayer have that OSD and components will actually hold managers accountable now to coach, counsel and fairly rate employees performance.