| Comment Number: | OL-10510104 |
| Received: | 3/16/2005 3:39:48 AM |
| 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:
After reading the Federal Register on the proposed NSPS system I have many concerns. My primary concern is there not enough specific guidelines for managers to follow. The sections of concern are: 1. “management may establish pay at any rate up to the maximum of the pay band in accordance with implementing issuances. The hiring official will determine starting pay based on available labor market considerations; specific qualification requirements; scarcity of qualified applicants; program needs; education or experience of the candidate, and other criteria as appropriate.” There is absolutely too much opportunity to make up the rules as you go along, and/or opportunity for the rules to become fluid. This is particularly true in the military portion of the Federal system, where the management is constantly changing. In this environment the “good old boy network” is alive and strong. There currently is much more consideration given to those who are prior military and/or a family member of a military, resulting in people holding positions who are really not qualified to do the work. There is also an “all knowing” attitude, simply based on rank. A good example of this in my current work place is a recent vacancy was announced with a requirement for fluency in a specific language. In the last 7 years that I have been here, this position never has had that requirement and to this day that skill has never been utilized. However, the position was consequently filled with a family member of person who was a friend with another person in the organization who is in the position to influence hiring actions. This section just encourages more of this type of unjust behavior from management officials. Where are the checks and balances? 2. “If the move is involuntary due to unacceptable performance and/or conduct, there may be a reduction in basic pay of up to 10 percent as provided in these proposed regulations and in DoD implementing issuances.” This again provides too much opportunity for abuse in fluid environments. In my current workplace, this very thing happened without following the establish rules to manage performance. A co-worker suddenly became inept in the eyes of a new military manager who rotated in. This manager made life unbearable for the person, and forced the individual into moving to another lower grade position at another organization. Where are the checks and balances? 3. “DoD has determined that conduct and behavior affecting performance outcomes (actions, attitude, manner of completion, and/or conduct or professional demeanor) should be a tracked and measured aspect of employee’s performance.” This again provides an opportunity for abuse. This is very subjective, and there are no guidelines for measuring these elements. Of particular concern is “attitude”, which can be very much perceived rather than reality. This goes back to the “all knowing” attitude (there is that word), that doesn’t necessarily coincide with reality. Typically this type of manager doesn’t want to be wrong, even when it directly affects the service provided to the customer, because it is much more important to be right than to do the right thing. 4. “The proposed regulations eliminates the requirement for a formal, set period for an employee to improve performance before the management may take an adverse action.” This again sets the stage for abuse in fluid management environments, by allowing the rules to be made up to fit the need. There is a system in place to deal with performance problems that does work. I have been a manager, and successfully used this system to improve employee performance. It is my experience that many management officials have not educated themselves in the protocol and they fail to document appropriately, counsel the employee and provide guidance for improvement, thereby, failing to achieve the ultimate goal of performance improvement. This simply sets the stage to “throw away” a poor performer, rather than improve the person. This also makes it easier to implement the “network of friends” into desirable positions. This concerns I stated above are only a few. The bottom line is, no where in this regulation does it state any checks and balances to prevent abuse of the system. It seems that this is a full circle. The reason that the current civilian service system was put in place was to eliminate the abuse of the system that was occurring. There was also reference to the Town Hall Meetings that was held, stating it was an out reach to the employees. Well I attended one of those meetings, and it was not at all informative. The presenters were very vague about the system, and no details or specifics were provided. During the questions/answer period the majority of the responses to questions were “I don’t know.” or “That has not been determined yet.” Implementation of this system is a huge mistake. The best way to improve the current system is to educate management in appropriate protocol and adhere to the existing rules of conduct.