| Comment Number: | OL-10509051 |
| Received: | 3/15/2005 12:21:36 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:
I can see potential for benefits from many of the proposed provisions of the NSPS. However, I believe its major weakness is its reliance on subjective performance appraisals with limited review and even more limited access to redress. Since the system is performance based, evaluation of performance is critical to the operation of the system. But that evaluation is essentially in the hands of each employee's immediate supervisor or manager. Any personnel evaluation is going to have some subjectivity as a factor. The difference is that the current system does everything possible to reduce that subjectivity while the NSPS does the opposite and maximizes the influence of the supervisors' and managers' subjective evaluation of their employees' performance. In the best case, that won't be such a bad thing. Good supervisors and managers will do their best to make fair and accurate evaluations. But in the worst case, things can get very bad indeed. There is tremendous potential in the NSPS for cronyism and politcal patronage, the very things for which the current civil service rules were created to eliminate. I don't doubt that the political appointees who instigated the NSPS think it is a great idea. It frees them to shape the DOD workforce to fit their ideological ideals. But for the people who actually perform the mission which the proponents of NSPS claim to care so much about, it is a step back a hundred and fifty years or more.