| Comment Number: | OL-10509836 |
| Received: | 3/15/2005 7:07:59 PM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| Attachment: | nsps%20concerns.doc Download Adobe Reader |
Comments:
I would like to address these concerns with NSPS: GENERAL: Without detail on how some of the proposed concepts will be implemented, it’s difficult to foresee the effect they will have on the average employee; however, here are some potential concerns. SUBPART B - PAY BANDING: It’s difficult to comment on a concept that hasn’t been finalized; however my concern at my level is that the banding will be set up by the top levels (DOD or military service) with the perception that a current GS-13 at DOD or DA or AF has more responsibility and should get more pay than a GS-13 at a MACOM, MSC or installation. Speaking from one of those “lower” levels, I don’t buy that – those of us at the “lower” rungs of the ladder are the ones that answer all the questions those higher level people ask. The proposed regulation proposes a separate pay band for “Managerial work whose primary purpose is to direct key DoD/Component scientific, medical, legal, administrative, or other programs”, which leads me to believe this kind of pay band breakout will be implemented. Another statement from the proposed regulation, “with appropriate consideration of both national and local rates paid by employers in the private sector”, makes it clear that while I may be doing the same level and quality of work as someone in Ft. Belvoir, VA, I will likely not receive the same level of pay. And yet, I promise you, I will work just as hard as that person in Ft. Belvoir! SUBPART C- PAY AND PAY ADMINISTRATION: Performance Payouts: An obvious concern here is that, while the concept of rewarding managers and employees based on performance is a sound one, implementing it FAIRLY within the federal government will be impossible. One reason for this is the obvious limited funding that will be available to reward personnel – our salaries are paid through funding appropriations, so there is only so much set aside for pay and there will be a limit to the amount available to reward personnel. Since the funding flows from the top down, each level from DOD down to military service down to MACOM, etc., will keep what they perceive as a “fair” amount of the available payout funds. I believe some NASA SES personnel have recently aired their dissatisfaction with this type of system (reference Washington Post article, “Complaints about NASA Raises Follow Switch to Performance-Based System”). Another reason this system will fail is that, instead of promoting teamwork, it will pit (some) co-workers against each other and create a somewhat hostile work environment where some employees may be unwilling to help/teach others in hopes it will make those employees appear incompetent. This will detract from getting the mission done. A third problem with the proposed system is the problem when an employee is at the top of their pay band, is still performing at an exceptional level, but can only receive a “bonus” rather than an increase to their basic pay. Personnel at the FAA have already expressed their discontent with not getting regular raises that will count towards retirement and other benefits. SUBPART D – PERFORMANCE MANAGEMENT: One of the hardest tasks for any supervisor in a professional field is to set quantifiable, measurable performance objectives and then OBJECTIVELY assess their employees’ performance. We all know of cases within and outside of government where it’s not what you know or how you perform, but rather who you know. You’re now proposing to take away the employee’s right to have an outside arbitrator (union) support their challenge of a performance rating. SUBPART F – WORKFORCE SHAPING I’m concerned about the limitations being placed on competitive areas for RIF purposes. It seems that management will now be allowed to target specific jobs. SUBPARTS G, H and I: Although I know that the unions can sometimes go overboard protecting employees that don’t warrant protection based on their behavior or performance, I do believe that employees should have union representation. These subparts impose severe curtailment of union ability to protect employees and negotiate with management – it doesn’t seem warranted by “security concerns”.