| Comment Number: | OL-10510115 |
| Received: | 3/16/2005 4:28:47 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:
Overall, I believe the NSPS is an ill conceived and poorly designed system that won't accomplish its stated purpose of rewarding employee performance with appropriate compensation. I also believe this system will deny DoD employees their rights for collective bargaining and rights under the statutory merit system principles. Subpart C – Pay and Pay Administration §§9901.341-342 – Performance payouts The use of performance shares will contribute to office politics and cronyism and establish a negative environment that isn’t conducive to cooperation and a team participation. Subpart D – Performance Management §§9901.405-406-Setting and communicating performance expectations The proposed standards seek to remove any defined measures of evaluating performance, allowing employee performance evaluations to be subject to the impulses of management. Performance expectations are essentially going to be a moving target of vague attributes, which will increase frustration and destroy morale. Hard working government employees that don’t cater to office politics will be forced out of the government. Performance ratings will become subject to management’s personal preferences and individual prejudices, setting up a worst environment of cronyism than exists currently. College graduates considering a career in government service will think long and hard about working under such a poorly defined system and will first seek out private sector options. A closer look at the criteria cited shows the planned system to be ill conceived and poorly designed as a vehicle to link pay with performance. How are government employees going to adopt work habits to achieve performance standards based on such opaque and nebulous criteria such as organizational performance or team performance. Even worst, how about behavior, attitude, professional demeanor and manner of completion as criteria? (While we’re at it, let’s add patriotism, loyalty and morality) How is any system going to measure and track such intangible aspects of a person’s performance? Essentially, the message comes across as management will define performance evaluation criteria however it wants it to be defined, whenever it wants to define it and change it whenever they want to change it. DoD should modify and fine-tune the existing system rather than starting from scratch. The new system doesn’t address the biggest problem with the current system, poor management. The inefficiencies and stagnation resulting from bad management far outweighs the problems NSPS is supposed to address. Because the NSPS puts far more responsibility and power in the hands of management, not only will it not address problems of bad management, it will further entrench and magnify its negative impact on the performance of DoD agencies. Subpart H-Appeals §§9901.805-808 DoD employees should be allowed to have the same protection under the MSPB as other government employees without the NSPS modifications. Subpart I-Labor–Management Relations §§9901.907-908 Rather than establishing another federal bureaucracy, the FLRA should continue to have the authority to decide collective bargaining issues for DoD unions.