Comment Number: OL-10510615
Received: 3/16/2005 10:46:56 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:

"Pay for performance" will be very difficult to execute - it is simply too subjective. We already have mechanisms to provide for "Pay for performance", and they are too often either not used, or used ineffectively. I've heard press reports that this matter will be addressed by providing extensive training to federal managers on how to do "Pay for performance". I have been around awhile. One phrase I have learned to look out for is "We'll do training - that will solve the problem". Too often the training too often simply consists of "Here's how to do it right - now go do it". The presumption is now the problem has been addressed. What nonsense. You cannot "train away" the problems inherent in an inherently poor process. Consider performance - in the private sector, performance is generally measured by profits. In order to track profits, we send fairly smart people to the equivelent of 3 full semesters of college level training (24 semester hours) to learn how to be accountants. In turn, they are overseen by senor accountants, overseen by CPA's, overseen by an extensive body of law, regulations, and industry standards. In the end, despite that infrastructure, we still see extensive abuse of "Pay for performance" in the private sector. The "training" infrstructure we'll see for our "Pay for performance" will pale in comparison, but this is what we're hanging our hat on. It won't work - it sounds good; "We're going to provide extensive training to make this work" - but you can't train away the fact that performance in most locations (sure, in an organization the size of DOD you can find selective examples where performance metrics can be made clear) in DOD is subjective. Compounding the subjectivity is the fact that in large organizations success often depends on the cooperation of other organizations, so to be fair performance factors will have to address how you cooperate with other organizations, and take into account they will not always cooperate with you, especially at the "super" performance level. Pay for performance in a non-profit organization is an inherently flawed concept, and no amount of training can change that. I retire in the next five years. I do great work, and I have no concerns I'll do well under "Pay for performance" - probably better than I do now. But I am concerned for those who will follow, and concerned about the degregation in overall DOD ability to execute missions when the inevitable failure of "Pay for performance" begins to eat away at our effectiveness and efficiency. Soldiers will not get the support they need. At the risk of sounding overdramatic, people will die when our ability to deliver the right material, to the right place, at the right time, degrades.