Comment Number: OL-10509712
Received: 3/15/2005 5:16:40 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:

(From the Merit Systems Protection Board website): Drawing Distinctions in Performance and Rewards The under-utilization of General Schedule authorities demonstrates lessons to be learned as we move toward pay for performance. WHAT'S INSIDE While many Federal agencies are clamoring for the flexibility of performance-based pay plans, authorities currently available within the traditional General Schedule (GS) appear to be under-utilized. Since pay for performance places more responsibility on supervisors for using cash to differentiate between different levels of performance, agencies should explore why these existing tools have not been used more frequently. Determining what hurdles need to be overcome and how to address them should help supervisors become more comfortable making performance distinctions and appropriately rewarding performance – regardless of the pay system within which they operate. Patterns of performance appraisal ratings show supervisors typically rate less than 1% of Federal employees as below the “fully successful” level. Is the Federal workforce truly this good? Or have supervisors devalued the term “fully successful” through reluctance to document performance deficiencies and discuss them with under performing employees? Likewise, within-grade increases (WGIs), which are contingent upon satisfactory performance, are very rarely denied. In fact, in FY 2003, supervisors denied WGIs to only 0.09% of employees (that’s 9 out of every 10,000). Interestingly, this appears to represent a growing trend as WGI denial has gradually and consistently decreased government-wide in the past 6 years. At the opposite end of the rating spectrum, the quality step increase (QSI) serves as another tool at supervisors’ disposal to recognize sustained high performance. However, its use is relatively limited. Less than 5% of employees received one last year. Given that over 40% of employees in a five level performance appraisal system were rated “outstanding” according to recent data (Central Personnel Data File, March 2003), perhaps more employees should have received QSIs. Many of these employees may have received cash awards, but with current awards budgets hovering around 1-2%, it appears unlikely that the monetary value of these awards would provide substantial motivation. This is especially true when rating a substantial percentage of the workforce in the top level means that the money will have to be spread very thinly. These low rates for denying within-grade increases and granting quality step increases, combined with the notable positive skew in performance ratings, suggests supervisors find the performance evaluation and awards process to be challenging. However, failure to differentiate between individuals (or teams or organizations, depending upon the reward system) seriously undermines many of the goals of a pay system. Since history shows that failure to distinguish between levels of performance and reward employees accordingly has caused dissatisfaction with both the General Schedule and past pay for performance initiatives, it appears that the transition to performance-based pay systems won’t be easy or quick. Agencies must understand these issues and correct them before attempting to implement pay for performance within the Federal Government. Otherwise, agencies risk exchanging one pay system for another without correcting the root of the problem.