Comment Number: OL-10509172
Received: 3/15/2005 1:29:31 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:

Re: discussion of E.O. 12866, p. 7573: I believe the cost to implement the system is significantly understated, specifically with respect to the cost to train. As a long-time supervisor in the Civil Service, I believe it will be a significant cultural shift to get supervisors to take risks, to publicly identify better performers as well as those who are not good performers. For the system to work, employees will have to come to believe that performance decisions are reasonable and fair. This can be accomplished in part by training, but while the training can use existing infrastructure, it ought not to displace training resources intended to enhance mission delivery. Additional funds will be required for training, well beyond those specified in the Notice.