| Comment Number: | OL-10510480 |
| Received: | 3/16/2005 9:57:55 AM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| Attachment: | Comments on Fed Register.doc Download Adobe Reader |
Comments:
Classification-Subpart B-DoD along with OPM will have the authority to establish qualifications for positions and to assign occupations and positions to broad occupational career groups and pay bands. Why reinvent the wheel when OPM has established qualifications that have been used for over 20 years with success and broad occupational career groups that work. DoD may state they do not work in today's society but they do if management and commanders would take the intitiative to update position descriptions, actually describing the jobs as to their actual duties. I work in personnel and one of the main problems with recruiting and filling positions is the position description. If you go to generic position descriptions, there must be something to use to pull referrals from a skill based RESUMIX system, either performance standards or functional statements as to what persons within the occupational group are doing. All work with DoD is not the same, a civil engineer for the COE can be three different types of civil engineer as well as be different from a civil engineer at any Deport, FORSCOM or TRADOC installation. Sometimes one suit does not fit all. Section National Security Compensation Comparability- To the maximum extent practicable, for fiscal years 2004 through 2008, the aggregate amount allocated for compensation of DoD civilian employees under NSPS will not be less than if they had not been converted to the NSPS. What happens after 2008 and what does the maximum extent practicable mean? Does that mean that if budget cuts come down, the DoD employee will suffer losses in pay that other civil service employees would not. Question: Will the general pay adjustment be paid every year if you have a satisfactory performance appraisal or will the general pay adjustment money be added into the pay out performance pay every year. Section Setting and Adjusting Rate Ranges - The minimum and maximum rate range will be based on labor market rates, recruitment and retention information, mission requirements, operational needs and overall budgetary constraints. DoD will also set local market supplements (a supplement to basic pay in lieu of locality pay) for rate ranges based on geographic and occupational factors. How much is this going to cost DoD to determine this information and is it going to be determined by a contractor. The rate range adjustments may be different for different pay schedules, career groups or pay band. We already have rate range adjustments for career groups such as hard to fill occupations, engineers, medical positions. Why not use the locality rate pay situation and premium pay/ special rates as studied by OPM every year? Another instance of reinventing the wheel with no gain and probably loss of pay. Performance-Based Pay- There is nothing of substance in this section. This will be a nightmare for the first line supervisory because they will have to make the final determination and actually rate employees by number. Based on the performance standards now, you would rate several employees at the 5 level but only be able to give one the highest share, although all were performing at the same level. This is demoralizing to the workforce. Not only is it demoralizing, it will not work because first line supervisors are not backed up by higher level officials or headquarters not in trying to discipline, demote or fire unproductive employees. That is why over 90% of employees in DOD receive an exceptional or above average performance appraisal. This situation is not going to change if the performance management system is not really tied to performance, success of team and mission, and professional attitude. Performance and Behavior Accountability - As stated above unless DoD Hdqtrs, Army Hdqtrs, higher level officials are ready to back up first line supervisors, this will be another fruitless exercise. First line supervisors will still have to document everything.