Comment Number: OL-10509416
Received: 3/15/2005 3:12:56 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 am a DoD employee who will be part of the spiral 1 NSPS implementation in July. I believe the new system will spell nothing but trouble for the rank-and-file worker. Putting the power of setting pay into the hands of a low-level supervisor, via the employee performance appraisal, will create nothing but ill-will among the entire workforce. The system seeks to reward "performance" based on a faulty premise that it can be statistically measured in an objective manner. In today's workplace, individual employees perform a wide variety of tasks (often within the same job series) that are not easily quantified. In most instances, a supervisor has very little, if any, direct observation of an individual's performance and is too detached from knowing what is occurring on the floor or in the cubicles. Also, there are times where an employee works for number of supervisors within a year. Consequently, confusion sets in around appraisal time as to what supervisor will conduct evaluations. Thus, many times an employee appraisal is conducted by a supervisor who has had no opportunity to oversee the employee he/she is evaluating. I do not believe there are mechanisms today (or with NSPS) to objectively and accurately measure performance using the employee appraisal--at least not enough to determine something as important as pay. It is a subjective judgment that uses no verifiable measurement to properly gauge success. Therefore, basing pay on an highly undependable interpretation of "performance" is not a good idea. Basically with NSPS (with the absence of measurable performance indicators that can apply to all) an employee's pay will effectively depend on whether your supervisor personally likes you or not. I am afraid I don't have much faith in the effectiveness of "supervisor retraining" to combat the spectre of favoritism, harrassment, and other prohibited practices that NSPS will likely accelerate. NSPS was designed to weed out bad performers, however, these folks exist today under the GS only because supervisor's allow them to. A supervisor could get rid of a bum worker if he/she really wanted to. Today under GS, some federal employees know of those who win promotions under dubious circumstances. They tolerate it because at least their pay isn't subject to their supervisor's whims. NSPS changes that I'm afraid. Now a supervisor would be able to cross-index an employee's golf handicap to their eventual performance rating, thus securing large raises for abilities unrelated to actual work. That is if the boss was a big time golfer who needed a ringer for the next division golf tournament. NSPS seeks to reward good performance. However, we already have mechanisms for that under GS called cash awards. What's wrong with just tweaking the cash awards program? Top performers could be compensated accordingly and the rank-and-file employee wouldn't have to worry about having a boss who either has a personal grudge, or worse yet, has no idea who they are, determining their salary. In the case of bad performers, they should get no reward. Basing a federal employee's very livelihood on a single person's (supervisor) judgement, virtually unchecked, is fundamentally wrong. I feel lucky that my supervisor is fair. However, I HAVE MORE FAITH IN FAIR PROCESSES THAN FAIR INDIVIDUALS. I believe NSPS asks us to place more faith in the latter rather than the former. This is just my humble opinion, though. Signed, One Humble DoD Employee