| Comment Number: | OL-10510895 |
| Received: | 3/16/2005 12:49:28 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:
Subpart D, Section 9901.409. This section gives the "rating official" power to determine our pay, our standing during a RIF, and vague other authority "DoD considers appropriate." I've been with the federal government for decades, working within DoD during the entire time but at more than 7 geographic locations. I've witnessed and experienced sexual harassment, sat on EEO committees that reviewed alleged discriminatory practices, and watched power-hungry men and women abuse promotional authority. I don't disagree that the current system needs overhauling; it does. But the overhaul should start with the qualifications of those given the authority to rate. Military officers and even enlisted personnel are transitory; some are good supervisors/raters while others are not. The same is true for civilian supervisors/raters, though they are less transitory. Too many current "rating" officials (1) have inadequate training/education, (2) lack interpersonal skills, (3) let power go to their heads, and/or (4) blatantly display favoritism. Perhaps what federal workers fear most under the proposed NSPS is the increased opportunity for rating officials to abuse their authority. I share that fear and am concerned that the proposed system will not improve the caliber of rating officials DoD-wide. Under the current acceptable/unacceptable rating system, a rating official must document and discuss unsatisfactory performance, provide a written plan of corrective steps, etc. With a multiple rating scale, biased or abusive rating officials get one more tool to take advantage of an employee they dislike. Again, I think federal employees would find NSPS more acceptable if concrete steps are taken to ensure that rating officials are under scrutiny to make accessments fair. Why not tie all rating officials' job performance to the RESOLUTION of low ratings? At the same time, there should be some type of random reviews conducted during the first 5-10 years to ensure ratings are unbiased. You have only to look at the various service academies and their lawsuits to know that military officers are not always fair, unbiased and/or above illegal activities. Ratings officials, civilian and military, must undergo appropriate training, retraining, and counseling - not voluntarily, but on a mandatory basis - no exceptions.