| Comment Number: | OL-10508706 |
| Received: | 3/15/2005 10:12:26 AM |
| 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:
Rule #1 - DoD does not to take such great adminstrative measures to provide more benefits to their workforce. In fact, there are some ambiguous wording in this proposal, and will be to the detriment of the workforce. The follow excerpts are taken from the NSPS fact sheet. Item #1 - The annual January pay increase, as we know it now, will change. The proposed pay rules provide for periodic “rate range” adjustments, to adjust the minimum and/or maximum rate of a pay band. When a minimum rate of a pay band is adjusted upward, employees will receive an equivalent increase. There are no “steps,” similar to the GS system, in a pay banding system. Instead, pay increases and/or performance bonuses are based primarily on your performance rating. Unacceptable performers are not eligible for pay increases under the proposed system. Comment - These minimal annual adjustments are based on cost of living increases (inflation), versus performance. To change this pay adjustment based on peformance is a falicy. And, will the regulations change as to what bonus amounts may be given? At the end of the day, the most I can pay a GREAT employee is a small percentage of their salary. NSPS does not necessarily open the door to giving bonuses and awards that are equitable to the private sector. Item #2 - Supervisors and managers will have an important role in determining performance-based pay increases. The flexibilities proposed in the NSPS regulations bring with them an increased need for accountability. This includes employee accountability for performance, as well as supervisory and managerial accountability for the proper exercise of the authorities of NSPS. Extensive training will be given to supervisors and managers, both military and civilian. Training will focus on improving skills needed for effective performance management: setting clear expectations; communicating with employees; and linking individual expectations to the goals and objectives of the organization. Supervisors and managers will be held accountable for how effectively they use the tools provided by NSPS. They will also be subject to the pay and performance provisions of the system, and their pay will be affected by how well they perform their duties as supervisors and managers. Comment - DoD does not have the money to fund this training. We in DoD support the Warfighter and they don't even have the protective gear that they need. Does anybody remember Rumsfeld's answer to that Iraqui Soldier when asked about hardened SUVs? We, as civilians, are crazy to think that the funding will be there for extensive training. Item #3 - DoD is developing a process that will allow employees to request reconsideration of their rating to a higher authority. This process will apply to all employees under NSPS. Under current law, employees in the same organization are often subject to different procedures and avenues when challenging performance ratings. This sometimes results in inconsistent decisions. Because of the importance of the performance rating process and its impact on pay, DoD will ensure that every employee has the same opportunity to seek appropriate redress. Comment - if DoD is currently developing a grievance process, but they are fielding the NSPS program, they have the cart before the horse. That business practice is hard to change in this bureaucracy. We need to be wary and all have a good lawyer on retainer.