| Comment Number: | OL-10510989 |
| Received: | 3/16/2005 1:23:18 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:
The intent of the proposed regulations for the National Security Personnel System is to put the mission first with an emphasis on enhancing National Security. However, it is highly questionable whether National Security will actually be enhanced.. My concerns are as follows: - Successful implementation of “pay for performance” will be highly dependent on the technical/administrative competence of supervisors. The proposed regulations do not convincingly spell out how such competence will be developed when required. Civil Service protections provide some protection from supervisory incompetence under the present system. Scaling back such protections under the new system will be especially troubling unless ensuring supervisory competency is accomplished first. - The proposed regulations strongly emphasize the need for employees to demonstrate their contribution the mission. The proposed regulations also need to specify the need for management to do its part (in terms of obtaining resources, making agreements with outside organizations, etc.) to ensure successful mission accomplishment. Lack of such balance will result in a demoralizing work atmosphere. - Use of pay banding with pre-determined pay pools is of concern in the present era of civilian payroll shortfalls. What assurance do we have that, in the course of meeting pressure to reward stellar performers, payroll shortfalls will not be balanced on the backs of everyone else? - Under pay-banding, the need to demonstrate superior performance as compared to peers will pit employees against each other. Information sharing and synergistic team efforts will become relics of the past.