Comment Number: OL-10511115
Received: 3/16/2005 2:05:21 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:

In addressing your case for action and adjusting rate range for new hires, and piecing these together with your local market supplement, it appears that you are planning to offer market salaries for specific expertise categories. You also expect to move employees to fill other more general duties as needed. How can you offer market salaries and predict performance on the other duties, simultaneously during your assessment of what salary the specialist should receive? Why aren't poor performers currently held accountable? Isn't this a supervisory duty under the current system? There is a process for this, I have seen poor performers fired or otherwise affected. Performance Management Subpart D: Employee and supervisory accountability with respect to individual performance expectations, as well as organizational results? Individual performance makes sense, but organizational results? You are discussing a factor outside the supervisor and employee's control. If something goes wrong, ie., because there are outside agency employees involved, should the employee and supervisor be penalized even though they did everything right individually? Please realize that this encourages everyone to stay with simple tasks and blow them out of proportion rather than to be innovative and risk takers in order to satisfy the customer and/or improve processes and performance of the office or agency. It is naive to believe that employees will do "a better job" if competing against each other for their pay raises. It is human nature to suck up to the decision-maker in such instances to hide mistakes, to blow easy low-risk tasks out of proportion in order to look good. How is this helping National Security? How do you expect to handle the human-nature responses and reactions related to jealousy over others getting paid a higher amount of money based solely on performance when there is no perceivable difference between the performance levels and contributions within the relevant time range? Is morale a factor in any of these decisions? I believe you need to employ human behavior specialists to determine how the proposed system will impact morale within the offices and the organization, and consider very carefully the insight and suggestions for changes to your proposal that are offered. Your proposal states that DoD can decrease the pay bands at any time. "Any time", at the very least needs to be qualified. Since the proposal's system is one that describes itself as compatible with attracting the best, is the assumption that any decreases would be decreases in market pay only for any given pay band when the market pay decreases? If the pay rates are decreased for any other reason, your purpose for establishing a new personnel system is voided out. Lastly, I appreciate the opportunity to provide comments. Your proposal is a 53-page document and you allotted each of us time to read the proposal and provide our comments. However, our unions represent each one of us and we expect our representatives to read the document, summarize to us, and collect and provide comments. We have provided our comments to the union. If we can't agree with the union, we have no problem providing our comments, singularly, through other channels. In addition, we were given the opportunity to singularly provide our comments officially through this web service. Many employees (incl. me) do not have time to sit back on their jobs and read a 53-page document in order to provide comments on such an important issue. Because of the above-described process of the information flow through the union, I believe that the union's comments should count as the number of people that particular union represents. Our comments, through our unions, are concerns that are major concerns about the proposed NSPS system and an additional concern is that they receive the weight that deserves to be given them in the decision-making.