| Comment Number: | OL-10510691 |
| Received: | 3/16/2005 11:21:37 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:
One area of major concern that is relegated to the "to be developed by DoD" category are management safeguards. How can an employee be guaranteed that his or her performance rating will be completed in a timely manner? Various departments are notorious for greviously late performance evaluations. Making the employee responsible for having the evaluation done places him or her in a untenable position. This is especially true if the supervisor is geographically distant. How will DoD train supervisors so that evaluations actually reflect the true performance of employees? If a supervisor cannot effective mentor or write, the DoD is hamstrung in identifying developing and promoting talented individuals. Another management control that does not seem to be present is a centralized system for making the most use of employees with DoD specific skills. Certain areas such as acquistion, intelligence and operations demand a knowledge of DoD corporate mission, structure and culture that require actual experience. Effective employees cannot be immediately brought in from the private sector. It makes more sense to see if an effective employee can be used elsewhere rather than to lay him or her off. This is joined to the lack of a long term vision of labor requirements for DoD. Flexibility is mandatory yet defense is one of the primary responsibilities of government. The blunt reality is that you cannot "grow" a Colonel, a Chief Petty Officer or higher level DoD civilian servants in a few years. Nor can you import them from the civilian world. Operations since 11 Sep 2001 have repeatedly proven that flexibility must be complemented by experience and common sense. The National Security Personnel System must provide a greater degree of safeguards for employees. The SES and political appointees who are implementing this system MAY forget that their perspective is vastly different from most civil servants. Their jobs are secure. Their salary and connections provide a unique degree of security. Asking those who are paid far less to accept more risk may undercut the very purpose of NSPS. Do not take my word for it. Look at the recruiting figures for the National Guard and the Army Reserve. Why work for DoD if you can earn the same money with greater safeguards in another Federal agency? Finally, I do not sense any true enthusiasm for this system by the Secretary. If he lacks "fire in the belly" to preach and promote the changes to those he leads, then how the heck can he expect career employees do so given that he will almost certainly be gone in less than four years?