| Comment Number: | OL-10510810 |
| Received: | 3/16/2005 12:10:06 PM |
| 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:
My single largest concern is that this system gives individual supervisors an inordinate amount of power, particularly in terms of being able to reduce pay and move an individual to a lower pay band. This system assumes that all supervisors are fair, honorable and capable. In my 33 year Federal career I have seen several instances where this is just not the case. The truth is there are supervisors who have personality conflicts with members of their staff. There are supervisors who choose favorites among their staff. There are supervisors who make value judgments on factors that have nothing to do with successful work output. There are supervisors who will rate poor staff highly just to avoid rocking the boat. There are Supervisors who will pay their staff higher because it gives them an inflated sense of their own importance and might help justify higher salaries for themselves. The system will not be consistent for all Federal employees. There are certainly poor workers in the Civil Service who would deserve the negative consequences this system could have on them. The current system makes hiring and firing difficult. However, there are also competent workers out there who can be abused by this new system and have very little redress. I see no checks and balances in this system. In the past if you had a poor supervisor, you could weather the storm because you knew at least things couldn’t get any worse. Under this system things can get much worse if you are unlucky enough to work for the wrong supervisor. Withholding a bonus is one thing. Reducing pay that you have earned is another. In the military, you cannot be reduced in rank without a judicial or Article 15 action. This system makes it a mere administrative action for civilians. That is inherently unfair and the opportunities for abuse are massive. If a person is not capable of doing the job they were hired to do they need training, counseling or dismissal. Reducing an employees current pay is no incentive to improve. This will only lead to anger and resentment. The pay reduction part of this proposal should be scrapped. As a minimum, the documentation and approval of this action should be higher than just the direct supervisor.