| Comment Number: | OL-10509704 |
| Received: | 3/15/2005 5:11:17 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:
General: A lot of hard effort has been put into this initiative. There is a lot of merit in the improvements desired to the current system, but not everything with the current system is bad or obsolete. I have received an overview briefing from the local subject matter expert, read the proposed changes, and reviewed several of the comments already provided. This is a difficult document to sufficiently grasp (especailly due to the magnitude of the change) and it generates many questions of implementation and execution. Several of my questions have already been submitted through previous constructive feedback comments that I have reviewed. Some additional thoughts include: 1) have other government pay banding systems been reviewed for lessons learned? (the Defense National Geospatial Intelligence Agency operates under a pay banding system - what worked well, what needed improvement during the implementation?); 2) the current spiral schedule (USAF) indicates 6 months inbetween roll-outs and doesn't appear to allow sufficient time to address, and resolve, the challenges that are identified before the next spiral; 3) when, and what training specifically, will be given for everyone (ie. effective communications, goal setting, writing clear, concise performance expectations, etc.); 4) how does personal education / training already obtained fit into the new system (ie. college degrees, formal training)?; 5) Classification--Subpart B: the five bulleted levels of work should be depicted in the Table 1 concept for clear visual linkage; Table 1 is confusing when viewed and the supporting narrative read; 6) Pay and Pay Administration--Subpart C, Performance-Based Pay: the Rating Methodology section indicates that "at least three rating levels" and the Table 2 sample shows five - is three the minimum and five the maximum?; two or three various examples of how the rating levels and shares concept and how the associated pay would work would be beneficial; under the New Appointments/Reinstatements section, does "management may establish pay at any rate" mean someone being reinstated can loose pay?; under the Career-ladder Positions section, what does this paragraph exactly mean concerning the salary at the time of conversion? (an example would be beneficial); 7) Performance Management--Subpart D: under the new system, how will subordinates be allowed to provide formal feedback to their supervisor?; are new standard performance evaluation forms being created?; 8) Labor-Management Relations--Subpart I: under Management Rights, much additional thought needs to be employed concerning carte blanche over deploying civilians with the same authority as our military; has consideration to volunteer lists been given?; does this include supervisory personnel?; is there additional pay / compensation?; if required, depending on the geographic location and hostilities, what additional physical requirements and training must be considered?; if someone has physical limitations (retired or previous military, or a civilian) and cannot deploy for whatever reason, how is his or her performance rating effected (if NSPS allows for this, and you are not "world-wide qualified", how is the employee's rating impacted?; how long will the deployment or rotation be?; how will extended deployment periods be rated for performance purposes (just doing the job because NSPS allows it or count as a significant factor)?; Thank you for the opportunity to respond.