| Comment Number: | OL-10508086 |
| Received: | 3/14/2005 5:43:15 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:
The primary concern being expressed over the implementation of the new NSPS system seems to be the issue of fairness, specifically, will each employee be rated fairly by his/her supervisor with respect to other employees within the same pay pool. This is a valid concern, since the current proposed system does not contain any provision to address this concern. I believe that if this issue was addressed, there would be no other significant objections to the new system. It would be in everyone’s best interest to insure that the new system is perceived by all to be fair and equitable. It is understood that the current proposed system has in place a means of appealing a supervisor’s rating, as compared to performance criteria established prior to one’s rating, but that still does not address the concern of whether or not the supervisor is rating each of his/her employees fairly as compared to each other. There must be some form of “check and balance” included into the new system that would lessen the possibility of an unethical supervisor rating an employee unfairly as compared to others. This provision is essential if the new system is to be readily acceptable to all employees. I can offer some recommendations that could lead to a possible solution or at least serve as a basis for some other provision worked out later, but it is essential that some form of “check and balance” be included in the new NSPS system that addresses the above concern. A possible solution would be to allow every employee within a pay pool, rated by the same supervisor, performing similar duties to know what rating the supervisor gave to others in this group. This proposal is reasonable since employees working together in the same area doing similar duties have a reasonably good idea of each employee’s work ethic, knowledge and productivity. It’s common knowledge within a particular working group the approximate rating each employee should receive. A disparate rating of one employee as compared to others would be very apparent to the group. This provision would immediately reduce the likelihood of a supervisor giving a disparate rating knowing that others would see and challenge his rating. If the supervisor was confident in his/her rating then he/she would have no difficulty in justifying that rating to the others in the group. Secondly, if a challenge was made by an employee who perceived that a supervisor favored another employee with a higher than justified rating, then the supervisor would be required to explain his/her justification for assigning that rating. If the explanation was unsatisfactory, then the dissatisfied employee could have the matter reviewed by an independent panel to determine if the supervisor’s rating was assigned fairly to each of the employees in the group. Some would make the claim that employees having knowledge of another employee’s performance rating would violate privacy rules. This is a valid concern, but I would suggest that taxpayer money being paid to Government employees should be closely monitored and should be considered public information. It is especially important that others within the same working group have this knowledge since it directly affects the amount of money available to them for salary increases and bonuses which are the basis of future pension and TSP payments. This ultimately determines one’s standard of living for the rest of their career and through retirement. I believe these issues underscore the importance of fairness and outweigh any concern over privacy. I believe that even a basic provision such as this, would be sufficient to calm the fears of those who perceive the new system as unfair.