| Comment Number: | OL-10509681 |
| Received: | 3/15/2005 4:58:40 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:
NSPS performance system seems driven to benefit managers and supervisors. How are bad apple supervisors/managers, who abuse their power and authority over their subordinates going to be controlled? Too often people in positions of authority are poorly trained and create havoc for the people who work under them. The new system certainly encourages the good ole boy system to prevail (that could set back federal efforts to hire more women, minorities, people with disabilities and encourage diversity). Some upper level supervisors and managers do not have a clue when subordinate managers are abusing their authority since these bad apples will do their best shine to those above and deride those below. To compound the problem, this would not alleviate the lack of willingness of management to get away from the politics and do the honest and right thing. The only new bearing is that under the “new system” the performance is elevated to encompass the employee's entire salary. This will benefit those who are perceived to be good performers and/or take credit of others hard efforts while the humble can expect to receive very little in salary increases. To have a truly objective performance system, a 360 performance review process should be adopted where all (managers, supervisors and employees) are subject to performance evaluation by each other. This would equalize the playing field among all who “contribute for the good of the organization and its national security mission” as NSPS states as its primary rationale for dumping the old system for the new system. This 360 review is used by the private sector. If the new system is adopted without a 360 review, it may ruin the valuable asset of a dedicated civilian support force. Also, since most federal agencies operate with some sort of teams and some matrixed teams, as a result of reduced workforce e.g., baby boomer attrition, A-76 studies, BRAC, etc., it is not clear how teams will be evaluated/rewarded under NSPS. Regarding Standards for Unacceptable Performance and Appeals, this does not provide enough checks and balances. If managers have more authority to hire and fire, then there needs be a check and balance to have an independent third party review in place to act as an employee representative. The legal standards for discipline and removal actions need to be specific with disclosed procedures for addressing employees viewed as poor performers. It does not seem evident how NSPS is going to be a more cost effective system if there are potential for more lawsuits to follow.