| Comment Number: | OL-10509844 |
| Received: | 3/15/2005 7:19:47 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:
As a participant in a DoD Lab Demonstration project for merit-based performance payouts for the past several years, I offer the following observations regarding the proposed NSPS plan: 1. Ensure that the lessons learned in the Demonstration projects are incorporated in the new system—DoD has already paid to learn those lessons at least once, and sometimes more than once. 2. Lessons learned: highly skilled and educated personnel do not fit a bell curve and deeply resent performance evaluations that sound like grades (1-5 is certainly an improvement over A, B, C and F but the correlation will still be drawn). Supervisors are more likely to use the full scoring range if they have the opportunity to provide some merit increase to those at the upper end of a range. Therefore, in Table 2, a score of “2” may rarely be used without an unwritten agreement that everyone takes a turn for the 0 and 8 shares on an equal basis, thereby defeating the system. The China Lake project learned a long time ago that there is value in a half-share. However, the range of shares for scores of 3,4 or 5 is an improvement, as it presumably gives supervisors more flexibility in balancing the needs of satisfying good performers without wreaking havoc on the budget over time. I say “presumably” because if shares are earned based on a specific score (i.e. 6 shares for 90 out of 100 points nad 7 shares for 92 of 100), expect arguments from personnel over why they didn’t get the extra point or two. As a supervisor and manager, I’d prefer to be able to offer strong performers a package they like, comprising money and/or time off for some and job security during a RIF for others. It is my experience that each person has a strong preference for one of the three, and the preference changes with time. Linking the performance score to job retention during a RIF appears logical and obvious, but puts pressure on raters to score employees higher to avoid losing them in a RIF, especially as raters don’t know in advance what the overall paypool average will be. There was increased buy-in during the conversion from GS to merit pay by leaving the General Increase intact for all but those getting an “F” grade. Merit pay increases average 1% per share as a result, and top performers do not advance as quickly as they might, but there was much less fear and resistance to the conversion after that change, brought about after a Town hall meeting with the local Congressional representative. Putting too many GS levels into one payband can create morale problems (e.g. Microbiologist GS 5-12) where the desired start pay is at the GS5 step 1 for a Masters level professional. This has been overcome in recent years but initially required extra paperwork. A payband that initially looked good was the merging of GS13/14 to eliminate the need for Factor IVs and authorizations. However, this led to disagreements whether GS12-equivalents seeking promotion to GS13/14 should be functioning at the 13 or 14 level. Rapid progression through the payband by 13s moving to 14 also contributed to loss of morale by GS14s who were promoted to that level. I like the concept of a control point between the two to reassess the employees before they move to the higher part of the payband. 3. It is hard to write comments on important sections that are “to be determined” in the Federal Register and the website. Examples include p7565 (Mandatory Removal Offenses), the lack of criteria for ratings, rating forms, paybands, and methodology for payouts. Hopefully these will be open for comments before they are implemented. 4. Section 9901.409: Only one rating of record is used for RIFs? Supervisors can manipulate this easily to change the deciding factor to longevity if they want, as RIFs rarely occur without some notice.