Comment Number: OL-10509069
Received: 3/15/2005 12:32:01 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 have heard the NSPS alluded to as the new "spoils" system. I wholeheartedly agree with that comparison since favoritism and cronyism will run amok if the NSPS is implemented as envisioned. Imperfect as it may be, the present system insulates the employee to a certain extent against the vicissitudes and vagaries of management at all levels. Employees can voice their opinions even if they run contrary to those above them, which will not be the case when NSPS is implemented. The proposed system opens the flood gates to abuse through the use of ill-defined criteria such as contributions, competencies and performance that are subjective by their very nature and by the associated definitions in § 9901.103. Essentially, those in managerial positions can exercise their discretion in rewarding employees. Thus, those employees versed in impression management regardless of their substantive contributions can manipulate their supervisors when awards and compensation are dispensed. In theory, this system sounds good but in actuality, it undermines what it purports to impose - that is, a system that will reward the employee "fairly" for his performance. What needs to happen is for the subjectivity to be taken out of this planned approach. Employee activities and associated objectives must tie in to the stated goals of the organization if only in a nebulous way to show connectivity. Objectives must be "measurable," not "observable" as the definition states. Similarly, performance should not address the "demeanor" of the employee as that too is very subjective and difficult to evaluate at best. Any offhand negative comment about a work assignment would thus undermine one's potential for achieving an award or financial compensation regardless of whether the comment was meant in jest or otherwise. The bottom line on my part is that I have no issue with the pay-banding concept in terms of it providing greater flexibility to DOD in managing its workforce. Where I do take serious exception is to the potential for abuse under this system by placing an inordinate amount of power in the hands of first line supervisors for financial dispensation. Moreover, while I have not addressed this issue, the pool of available dollars will drive what people receive thus being driven "top down" rather than "bottom up" from the aggrandizement of earned based on the attainment of steps within grades. In short, you will pay people what you have available rather than having to pay them what they have earned based on longevity