| Comment Number: | OL-10508126 |
| Received: | 3/14/2005 6:23:19 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:
With my extremely diverse near 30-year federal career serving in a variety of staff, management and executive-level blue and white collar (WG/WL-10 and GS-09/11/12/13/14/15) positions with many federal agencies, including a 2-year appointment as a Presidential Management Fellow and multi-year tenures which have included DoD, NIH, Dept of VA, IRS and a recent return to DoD at the national, regional and local levels, I can honestly and confidently declare that I have seen the rare and exceptional genuine “world class” excellence that can and does exist in some federal organizations. But I must concede that I have also witnessed varying degrees of good, excessive examples of mediocrity and borderline failure, and far too many demonstrations of objective incompetence that is present, tolerated and perpetuated within far too many federal organizations. The lower tier federal organizations are typically overly insular, both in respect to their hiring practices, a process that defines organizational culture and values, as well as the general aversion to criticism from within, which oftentimes leads to the establishment and perpetuation of self-validating non-critical groupthink, and which in turn ultimately leads to further mediocrity. These lower caliber managed federal organizations typically maintain, perpetuate and rationalize a self-serving near 100% inbreeding hiring rate for current or prior agency staff in supervisory/managerial positions, acting as if excellence, true excellence existed only within itself. A truly preposterous proposition, a proposition that nevertheless is both accepted, valued and apparently perceived in the overly insular federal institutions. Another highly negative, mission accomplishment diminishing and self-defeating characteristic of such dreg order institutions rests with its groupthink mindset and culture, a culture that is objectively and manifestly intolerant of criticism or conflict from within, irrespective if the criticism and conflict is positive and/or is constructive in nature. Such third-tier organizations are not competently managed or lead by true visionaries, who know and understand that change rarely if ever occurs without conflict, and that conflict and change is oftentimes a highly constructive and value-added process that needs to be managed, not stifled or marginalized or ostracized or viewed as obstructive. Rather, managers in the third tier institutions are typically title-based managers, mere process and procedure managers, managers who are oftentimes one-agency careerists who hold limited experience by definition and as a result are overly sensitized to conflict and are overly sensitive to change emanating from outside of his/her zone of comfort and competence and/or “chain of command” and/or cadre of fellow internal like-minded managers. With this frame of reference, after reading of the proposed NSPS for DoD, I have developed a plethora of concerns. The principle concern is with the near “pollyannish” level of logic and reasoning that is replete within the draft NSPS language, language and proposed regulation that the NSPS itself conceded and affirmed was a near “cut and paste” drill from DHS’s recently implemented personnel system, a system that is presently under both Congressional scrutiny and judicial review and challenge. The first questionable premise, a premise that is THE underlying foundation of the NSPS, is the notion that DoD supervisors/management/managers have and will plan and execute personnel-related decisions solely in the interest of organizational and public good, and that these actions and decisions are based on (a) objective information, (b) are made for the ultimate benefit of the organization and the taxpayer, and (c) that parochial, personal and/or subjective factors and biases, including organizational pressures and culture, some of which may be inconsistent with sound public policy and wise stewardship taxpayer resources, is valid. I find that reasoning fatally flawed. As referenced and alluded to earlier, the unfortunate but truthful fact of the matter is that DoD supervisors/management/managers, as a general rule, although there are exceptions, are NOT included among the genuine first order federal managers. The vast majority of DoD is firmly among those federal agencies that maintain a near 100% internal/insider hiring rate for supervisors/management/managers irrespective of the excellence that exists in other federal agencies and the private sector. And that undesirable and indefensible hiring outcome was gained without the enhanced and near free wheeling DoD hiring authorities that DoD desires for itself within the NSPS. Similarly, the insular and overly sensitive to internal conflict/criticism organizational culture that is present in far too many DoD institutions as it relates to internal constructive criticism and feedback from staff, members of bargaining units, others, a culture that has at best marginalized and at worst targeted such staff by falsely labeling them so-called “non-team players,” will grow to unimaginable proportions under the proposed NSPS rules. If enacted as current written, the NSPS will formally institutionalize and legitimize the bad that is already present in far too many DoD offices and agencies. But further and more adversely, it will given DoD managers even more unchecked power to breed from within, to stifle and quash all internal criticism, to punish perceived so-called “non team players, and therefore further develop a near monolithic and groupthink founded organization that does not accomplish the overall objective - to better serve its customers and the United States taxpayers.