| Comment Number: | OL-10511050 |
| Received: | 3/16/2005 1:50:01 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:
I read with much interest the proposed NSPS regulations; I offer the following general comments for you consideration. First, I am concerned about the several details that have yet to be resolved despite a looming implementation date (Spiral 1 Jul05). The proposed regulations identify these as “to be determined”. I submit changes of this magnitude should not be implemented until all the specific “How to” details are fully resolved. I’m beginning to believe DOD’s intent is to implement a fundamentally new Civil Service Program by figuring out the details on the fly and “hoping for the best”. If so, I assert this concept is flawed and will likely result in failure. Second, I’m concerned with the proposed procedures for determining pay and evaluating performance. These procedures simply define a concept, the specifics of which are apparently left to individual organizations to determine. In my opinion, pay for performance will only work if all involved embrace the system as fair and equitable. To do so, measurable and observable standards must be clearly articulated from supervisor to employee through formal counseling’s (not through various unit SOPs as proposed). Supervisors (both military and civilian) must be trained in all facets of the evaluation and pay for performance process BEFORE implementation to promote equity and commonality. The intent should be that Supervisor A is evaluating the same as Supervisor B in terms of degree of difficulty, etc. In other words, the system should design a process such that an evaluation rating of “2” at Fort Bliss for example means the same thing as a “2” earned at Fort Belvoir. Furthermore, if based upon this rating the employee at Fort Bliss earns a 5% pay increase, so too should the employee at Fort Belvoir. An additional point; despite privacy concerns, pay pool managers should make ratings public. Doing so is the only way to avoid the perception of potential abuses and “deals made behind close doors”. In other words, how can I be assured that my pay determination was truly based upon my performance if I cannot compare my performance with others? Finally, over the weekend I conducted a personal, informal analysis of all feedback posted to date (I’m a statistician). Of the 3000+ postings, over 90% were negative in nature. The overarching point appeared to be concern over the notion of basic fairness (more precisely the lack thereof). Two themes were most pronounced, a general concern with potential abuses of the system (aka the effect of the old boy network upon pay, evaluations, etc) and a general distrust of a new system the details of which have yet to be provided (“specifically how will this effect me day to day”). The bottom line is employees are simply not buying into the concept; this suggests implementation as written will face a difficult, uphill struggle. I’m curious to know if DOD will decide to push through the proposed regulations as written despite such overwhelmingly negative feedback. I suspect time will tell.