| Comment Number: | OL-10509862 |
| Received: | 3/15/2005 7:48:34 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:
NFFE LOCAL 639 provides, as the “EMPLOYEE REPRESENTATIVES,” the following comments on the Proposed NSPS Regulations—RIN 3206–AK76/0790–AH82 - NFFE LOCAL 639 is of the opinion that, management has always had all the rights and tools to effect whatever changes in the workplace necessary, whether behavioral or performance based. However, while there are shortcomings from any personnel system, including the subject proposal, without more effort being spent by management, labor and the employees to, in effect, use the systems as they were intended to be used, the results will be the same, regardless of efforts to reform the system. A new personnel system will never address the needs of the current or future workforce without following the processes of the systems that are put in place, either old systems or completely new ones. For example, if the Army’s Performance Management System, TAPES was property embraced and utilized in our agency, we would not have some of the problems and very issues that these proposed regulations are intending to correct. The current systems for performance evaluation and discipline are adequate and workable to totally affect whatever changes management may need to make, but the systems and processes must be used to be effective. To that end, just as the proposed NSPS dictates, performance standards and performance objectives need to be in place, as well as be communicated and understood before evaluations can occur. Just as failure to follow the fundamental components of the current performance system has resulted in problems, the proposed NSPS will be equally problematic without the fundamental components of the entire NSPS system being in place. Therefore, we are unable to review fully the impact of implementation of NSPS on our employees. Again, in our view, typically management doesn't spend the time to do what the regulations require, doesn't follow the processes, and then ultimately the proposed action against an employee is overturned, stayed, or is otherwise hung up during adjudication, largely due to management’s failure to follow the processes or procedures. This, in turn causes the affected parties to litigate, leading often to more ambiguous rulings and guidance, not to mention the enormous amount of resources being expended, in the form of time, money, and human labor!