Comment Number: OL-10510921
Received: 3/16/2005 12:58:29 PM
Subject: Notice of Proposed Rulemaking, Request for Comment
Title: National Security Personnel System
CFR Citation: 5 CFR Chapter XCIX and Part 9901
Attachment: PERFORMANCE MANGEMENT.doc Download Adobe Reader

Comments:

PERFORMANCE MANGEMENT – SUBPART D Section on- Performance and Behavior Accountability - Comment: assessing behavior is very subjective unless that behavior affects performance other employees. Training must be mandatory for all Supervisors in this area of evaluation that has not been required in the past. Does behavior include manner of dress, looks, loudness, body smells, difficult personality, odd behavior, etc? I am sure this will include sexual harassment and age/race/religion discrimination behavioral problems. The possible malicious use and impacts of this would harm overall unit performance. Comment: It states ‘supervisors held accountable for communication and providing feedback’ but how is the supervisor, as an employee to his/her management above, evaluated on that objective? He can perform yearly feedback, as some currently do, but was it effective? See below for my recommendation. Section on- Setting and Communicating Performance Expectations – Comment: In order to evaluate ‘behavior’ the regulation states there is expectations of ‘manners’. Will strict guidance and supervision be provided to ‘supervisor or managers’ to ensure that arbitrary ‘manner expectations’ are not instituted? Will the current process of Senior Raters be used to review and approve a first line supervisor’s setting of employee Performance Expectations? Section on- Monitoring Performance and Providing Feedback Comment: A supervisor can provide feedback to an employee by referring to missed or late deadlines, poor workmanship, tardiness, etc. But evaluation of a first line Supervisor is not as straightforward on his performance of a ‘personnel manager’. The second line supervisor/manager can evaluate assigned work performance and tardiness but how does he evaluate management of those he is supervising. That first line supervisor can document that he ‘provides feedback at least once a evaluation period’ but how does he demonstrate setting good performance evaluations, providing ‘good’ guidance, and providing a good example of behavior to his employees. Especially how does he demonstrate that he is communicating effectively with his employees so that they can take the proper action to meet the expectations of the Second line supervisor? In other words a poor leader of employees can be on time and provide good workmanship products to the Manager but still be a ‘poor’ supervisor of employees. My recommendation as a previous Supervisor and a government employee of 28 years having had many Supervisors is that the NSPS establish ‘Employee Feedback to the Second Line Supervisor/Manager on the supervisory performance of the First Line Supervisor’ .i.e. 360 Degree Evaluation. Sure this could be subjective, just as employee behavior could be subjective and defensive, but the Second Line Supervisor/Manager can establish the ‘Employee Evaluation of Supervisor Performance’ objectives. Those objectives should be geared to evaluating quantifiable Supervisory Attributes such as Communication skills, Leadership skills, Oversight/Micromanaging levels, and Mentoring abilities. These attributes will not be apparent to the Second Line Supervisor/Manager who will be evaluating the performance of the First Line Supervisor but those attribute contribute greatly to the success of the unit as a whole in an organization.