| Comment Number: | OL-10508180 |
| Received: | 3/14/2005 8:09:07 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:
For a system that intends be based on performance, NSPS’s current lack of a proposed performance evaluation model is a monumental shortcoming. The proposed NSPS regulations need to address, in detail, the assessable levels and areas of employee performance, and the objective standards by which a supervisor will be required to differentiate between those levels of employee performance. The overarching NSPS performance levels and areas need not (and should not) be unique to a particular occupational specialty, but should exist to provide a common framework for objective evaluation of all NSPS employees, perhaps in a fashion similar to officer and enlisted performance evaluations, while adding additional performance assessment categories related to the individual career field occupational specialties and grade level (for which common definite evaluation criteria should be established). NSPS will not have the metric “teeth” to improve anything unless it takes the lead and publishes a proposed meaningful performance evaluation standard for comment up front. My command, the largest employer of civilians in the Navy, effectively “gave up” on a five-category (unacceptable to outstanding) performance evaluation system some eight years ago in favor of a two level (pass-fail) approach, because supervisors were deemed generally incapable (across the board) of meaningfully addressing the varying degrees of employee performance since they elected to rate most employees in the top two (of five) categories. In practice, evaluations remain largely based on the employee “input” rather than any thoughtful critical analysis by supervisor. Arguably, the current performance evaluation system offers supervisors as much opportunity to reward high-performing employees as it does to hold all employees accountable. However, it is obviously much more pleasant for supervisors to reward employees for positive performance, than it is to counsel, admonish or hold employees accountable for less than adequate performance. That supervisors may have chosen to avoid confronting the accountability of under-performing employees essentially reflects significantly on their own lack of accountability but also on the evaluation measurement tools. Clearly, supervisors themselves need better direction and tools to evaluate employees. NSPS needs to exercise the leadership NOW to set performance evaluations on a proper and common course, and not delegate this responsibility to be defined at the local levels. Therefore, the NSPS changes being contemplated must serve to provide supervisors with the specific tools and professional courage to make the right call (favorable or unfavorable) on employee performance evaluations. The NSPS proposed regulation currently falls far short in this area.