| Comment Number: | OL-10511032 |
| Received: | 3/16/2005 1:43:10 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:
Like any personnel system, NSPS will work only if there is trust, fairness and predictability between those whose performance is evaluated and those doing the evaluations. Most DoD employees, from GS to SES, work hard and are committed. Justifications from advocates of the NSPS seem to attack that premise, often drawing from the same limited pool of talking points, citing the need for flexibility in the GWOT to asserting that pay hard more to do with showing up to work than for performance -- mostly not true in my experience. Neither the old system nor the NSPS address the issue of accountability and responsibility of the supervisor/manager. Managers should be held responsible for conducting reviews with employees. Supervisers and managers, including political appointees who exercise authority over career employees, should be subject to evaluation themselves by peers and subordinates for their managerial responsibilities. What will protect career employees from politically motivated actions of their superiors? In DoD, some political appointees moved aside some career officials to backwater positions because of their service to DoD in prior administrations. Secretary England's response to a question on this issue in a 2/10/05 DoD Press Conference, in effect, that the numbers of such cases is low, missed the point of trust and fairness, especially during a wartime period when careerists are committed to the fight also. Career officials moved aside in this manner stand little chance for a positive performance review, much less a bonus (important for assessing sunsequent raises), since all these must be approved by non-career officials. The NSPS will strengthen the ability of non-careerists to exercise such authority over careerists, the relation of which to strengthening our national security posture is unclear. Once again, NSPS works if those subject to it perceive it to be imbued with trust and fairness. A Partial Solution: As a start, the DoD implementing rules should include a statement of principle that partisan political perogatives have no place in performance evaluations and other actions under the NSPS. Also, DoD implementing rules, so important to understand how the NSPS will unfold, should be made available for comment, although some NSPS people have indicated there may not be time given the July 2005 rollout objective. But why is that more important than clarity, openness, fairness as attributes that will make of break NSPS? It is important that the implementing rules be subject to review and comment also by the general employee population, not solely through the small committee structure.