| Comment Number: | OL-10508118 |
| Received: | 3/14/2005 6:10:42 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 fundamental (and fatal) flaw with Pay for Performance is the lack of metrics by which to measure performance. With no true and meaningful metrics to use as guides, how can my performance be judged? It falls back to the cult of personality and patronage system that was in existence before the civil service system replaced it. Managers would have unreasonable power to dole out pay raises and promotions. Such decisions would be at the sole discretion of the manager. (A part of my job is problem solving. Two problems may look alike on the surface but can have dramatically different solutions. One solution can be relatively simple; the other can be quite complex. I currently have managers who only can see the surface issues.) Another flaw in the system is the proposed lack of any neutral third party oversight for pay and promotion related disputes. Short of an EEO complaint, there is no local process in place to address labor grievances of any sort. How can it be in the national security interests to do away with lawful protections of individuals in the workplace? This is counterproductive to the core values of our great nation. The notion of pay banding is absurd when there is a perfectly good system of civil service pay in place already. Providing a clear path for advancement and promotions can only help motivate people to do their best to achieve the clearly stated goals. Flexibility in assigning workload cannot be a problem. Executive Orders can be used to move civil servants as required. Processes are currently in place to require overtime and extra days to be worked as necessary. Flexibility in rewarding outstanding performers is already possible through promotions, Quality Step Increases, and special act awards. Processes are also currently in place to weed out extreme under-achievers also. Unfortunately, the managers that NSPS wants to give full pay and promotion power to are the same managers that have not used their current powers to rid civil service of poor performers. If the managers cannot manage under the old rules, what makes us think that they can manage any better under new rules? The major difference is that under the old rules there were protections and due process for the individual civil servant. With the new set of rules any managerial accountability seems to be missing. The vision of the government and civil service should be long-term. Decisions made today will affect the freedom and prosperity of each and every American citizen for decades to come. We cannot apply the short-term, maximize-profit-at-any-and-all-costs model as seems to be the vision of corporate America.