| Comment Number: | OL-10510125 |
| Received: | 3/16/2005 5:29:21 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:
Seniority has never been the main reason for granting employees Within Grade Increases. Rather, receipt of a Within Grade Increase requires prior endorsement by management that the employee's performance was rated at the 'Fully Successful' level or higher. In other words, the current Within Grade Increase feature of the GS system has always been designed to function as a 'pay for performance' system. And, if it hasn't been used as such, than clearly the crux of the issue is whether or not managers are performing their jobs effectively. A within grade step increase is to be awarded only if performance is up to par. Since managers haven't properly utilized the 'pay for performance' mechanism the GS structure has had in place for years, than how can they ever be expected to appropriately use- or manage- the new system? The Civil Service Reform Act of 1978 invoked job performance as a factor in all federal positions. The Civil Service Reform Act has been the law since 1978 and is an example of a performance tool that Government management has had at their disposal all along, yet blithely pushed aside. Management hasn't been held culpable for failure in utilizing the legal provisions therein. Managers who ignored the mechanisms embedded within the law should have been deemed incompetent and promptly removed. But since no one held management's feet to the fire, once again the line workers are being targeted as a result of a system breakdown brought on by inferior management practices. Will such weak managers be disciplined and removed under NSPS? I doubt it! As far as management being provided specialized training for implementation of NSPS, seldom-if ever- has training purged managers of favoring certain members of the workforce. Just because select employees enjoy such favored status-which usually translates to their being permitted to do less work- it certainly doesn't equate to being a top performer. The tendency often is to 'look the other way' while favored employees slack off, dump the bulk of the workload on those less favored, and get away with it. Management favorites are credited for work done by others and reap the bulk of the awards. What is the plan of action to ensure such commonly practiced favoritism is kept in check? Especially since employee rights to grieve will be diminished under NSPS? Where has pay banding yet demonstrated a solidly successful track record in federal service? Surveys, studies and information papers from agencies where similar pay systems have been in place for several years (e.g., FAA, some areas of DoD, Dept of Commerce, TSA) reveal they’re still grappling with a host of problems due to ineffectiveness of the system, with no solutions in sight. Can it honestly and confidently be stated that NSPS will be fair? After all, it has never been a fair or level playing field in most DoD offices where I've worked over the past 18 years. The supervisor's 'pets' are permitted to skate on all counts - for instance, constantly coming in late, taking 2 hour lunches (often with supervisors) not being charged for leave, and openly bullying and disrupting the office team by intimating co-workers with their 'closeness' to management- all of which is tolerated by their supervisory cronies. However, if anyone in the less favored group has even the most minor of missteps, e.g., arriving a few minutes late, or returning a few minutes late from lunch- they’re penalized, which often includes public admonishment in front of the whole office. How can a supervisor of that ilk possibly be made to change- or trained to modify- such deeply embedded behavior patterns? I've worked on key DoD projects at my office in the USA and during official travel overseas. In so doing, I've received numerous honorary awards, letters of commendation, etc. from various entities, all citing my outstanding work. This group included the Deputy Secretary of Defense, Army General Officers, Navy Admirals, NATO officials, and even a letter of commendation from the Vice President of the United States. Yet, when it came to performance appraisal time, my bosses still tried to give me an average ('Fully Successful') appraisal for the projects I worked! When I mentioned the numerous work-related citations I'd received over the past year- especially the letter from the Vice President, I was told that though nice to have, such kudos 'don't have any bearing or factor into’ job performance. Only what my supervisor thinks does! Of course, I was compelled to file a grievance. Thankfully the union intervened and I easily won my case. But it shouldn't have ever come to that. I can’t help but wonder what recourse I’d have minus appropriate union representation under NSPS!