| Comment Number: | OL-10508206 |
| Received: | 3/14/2005 8:57:34 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:
As a manager in DoD, I would welcome pay for performance, accountability, and flexibility in hiring and simplified termination of non-performing employees. However, I don’t see those opportunities present in the proposed regulations. The current merit system has the tools needed, but in this litigious society where supervisors are rarely supported up the line, weak supervisors and managers have given up on their jobs of people and work management. This regulation would only work if management, to the top, support mid-level managers as they try to do their jobs. A change in the system will not change the human element involved. The systematic process under the proposed regulation does little to effect an attitude of accountability. While I applaud a “pay for performance” statement, I have concerns of this model. The dollar allocations and the distribution reminds of the “spoils” and the “good ole boy” system. Without factors of measurement, this arbitrary distribution favors the, excuse the expression, ass kissers. Additionally, in the DoD team approach, many poor or marginal performers are carried by team members and their lack of accomplishment disguised by the overall success of the team. Lastly, the phrase “available labor market considerations” are pie in the sky at best. DoD work is difficult to gage against the private sector. The current WG system, using DOL wage surveys as a base is obvious in its unrealistic measurements. I would also wonder what DoD would do when it finds local pay scales in excess of current GS salaries. Raises? I doubt it. While I think certain segments of this regulation deserve consideration, as published it is so badly written that adoption would serve to put in place a workforce counter to the objective. One of the few perks left in government service is stability of a job. Other than that, we have little to offer the “brightest and the best.” Take that away, and we cannot and will not compete with the private sector for those people.