| Comment Number: | OL-10509338 |
| Received: | 3/15/2005 2:37:51 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:
My comments address the following sections: § 9901.406 Setting and communicating performance expectations § 9901.407 Monitoring performance and providing feedback § 9901.408 Developing performance and addressing poor performance § 9901.409 Rating and rewarding performance ---- I agree that changes are necessary to improve flexibility, reward high-performers, and weed-out poor performers more timely. I have concerns as a first-level supervisor about being able to define Performance Expectations that are objective, measurable, and realistic enough to make fine distinctions between employees when their pay and even their jobs are on the line. This is particularly tough with engineers and other professionals who work on long-term projects where the final results take years to achieve, and many of the factors of success are beyond their control. We have been through several iterations of Activities Based Costing/Management and other Re-engineering initiatives over the past several years and have yet to find any real relevant metrics for the work we do. I also have concerns, as an employee, that without relevant metrics and objective, measurable "Performance Expectations" for my own performance, I will have little recourse to challenge my rating by upper management who have historically been very reluctant to distribute cash awards. In our organization Quality Step Increases are almost unheard of. Some years we can give cash awards to maybe the top 10-20% of our employees, but most years nobody gets an award due to lack of funding. The best performers get an award about 1- 2 years out of 10. When more funding is available, the awards have to be spread around among the best performers so the same one or two don't always get the award. Meanwhile, I see other organizations that seem to pass out awards like candy and even set quotas, like one "on the spot" award every quarter in an office with 25 people. Ideally, the employee knows exactly what is expected of him and whether he has met the expectations before being told by the supervisor in a formal appraisal. This will be the case if the new system truly is "understandable, credible, responsive, and executable", and "ensures accountability at all levels" as stated in the Guiding Principles and Key Performance Parameters. The devil is in the details. Exactly how will these goals for NSPS be met? Two facts in creating any new system: 1. Some people will always try to "game" the system. 2. There are always unintended consequences. How will you anticipate such problems and deal with them?