| Comment Number: | OL-10509944 |
| Received: | 3/15/2005 9:35:38 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:
Classification Subpart B, Performance Management Subpart D Labor-Mangement Relations Subpart I. Although the NSPS proposed regulations have some positive features, they also have some very negative features as well that are of grave concern. Before I go into both let me first say that I am a career civil servant with nearly 28 years of federal service, most of which has been in the field of Human Resources initially in non-DoD agencies but the last 16 in four DoD Components, Agencies, and an OSD Field Activity. Simplifying a definitely overly cumbersome and labor intensive classification system is definitely a positive as is the elimination of years of litigation with the unions when trying to introduce the most basic of work process improvements. But what is of the greatest concern to me is the proposed performance management system. Pay for performance certainly sounds like a laudable goal in theory. By providing supervisors and managers with realistic alternatives for setting employee expectations, DoD will be better able to hold employees accountable and recognize and reward those who excel. But the regulations are silent on what DoD is planning to put in place to hold supervisors and next higher level of managers accountable for equitable treatment of employees when it comes to salary increases. We are no longer talking about annual performance awards but about basic pay increases that normally would to some degree keep employee salaries up with inflation. The problem comes in what some call the “old boys network.” In one of the DoD agencies for which I worked, it was known as the “friends and family” program. If an employee was not a member of the “friends and family" group, the employee you could count on meager performance awards regardless of the high level of performance or mission contribution for the year. I was told, as were others, by the first line supervisor that higher recognition was never going to happen as long as the second level manager was in place. The second level manager (GS-15, later an SES member) needed to make friends in the workplace, needed someone to hang out and party with her on TDY, and share personal confidences. She rewarded those who were willing to classify positions at a higher grade than warranted so that she could gain favor with the agency executives, rewarded those who would place an applicant friend who she wanted to select for a position onto the best qualified list when the applicant had been ruled unqualified because she didn’t meet the basic qualifications for the position, and for those who arranged for her to select a friend of one of her daughters for a summer position who otherwise would not have been eligible for selection. Those who cooperated with this manager were rewarded, those who would not participate were not. From what I have seen in DoD organizations, this situation is one of the more serious. However, personal affinity rather than professional contribution and performance has proved to be the most powerful element in the performance reward system in two of the four DoD organizations that I have worked for. In situations with military supervisors, the "personal contribution” over the professional contribution can be even more of an issue. It creates a culture of going along to get along, certainly not one that necessarily puts the accomplishment of the DoD mission first. The proposed regulations state that, “A performance management system is only as effective as its implementation and administration.” I would add the element of design. Without a design feature to safeguard employees against being recognized for lower performance ratings than they have earned by those supervisors and managers who are dedicated to their own personal needs ambition over the mission of their organization, DoD employees cannot count on equitable treatment for basic pay increases. DoD's mission suffers.