| Comment Number: | OL-10511296 |
| Received: | 3/16/2005 2:57:09 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:
NSPS-2005-001 RIN3206-AK76 / 0790-AH82 General: The proposed system attempts to correct some perceived deficiencies in the current HR system by streamining the process for punishing poor employee performance (stick) and at the same time coupling performance more closely to pay (carrot). While these goals are laudable, we should inquire as to why the current system was designed with these perceived deficiencies. It doesn't take too close a look to find that the system includes rewarding specific groups of employees for purely political gains. This begins in the hiring phase where individuals are preferentially hired based on non-performance criterion such as handicaps, race, gender, armed service, the list goes on. At its very beginnings the process is flawed by hiring individuals whose qualifications for performing the required work are dubious. Many of these individuals are, or later become, the supervisors the NSPS wants to further empower. This is one of the reasons the current system has more checks and balances than the proposed one. This system flaw is compunded in the DoD because we add to it the criteria that rank alone endows one with suitable supervisory capability. Certainly the majority of supervisory personnel are fair minded, certainly not apolitical but at least careful in their application of duties, appropriately constrained by a set of rules we are about to overthrow. I suggest we move carefully and slowly, and in some cases not at all. Specific: Page 7560, Pay and Pay Administration-Subpart C. This paragraph addresses "pay" and "pay adjustments" which are generally understood to mean annual rate of pay, not bonuses. If an individual was at an arbitrary pay "control point", established by their local administrators/supervisors, they may not be awarded an annual pay adjustment, but rather a one time bonus. I see this "loophole" being used by some organizations as a means to minimize their pay expenditures at the employees expense. Conrol points should not be implemented. Page 7561, Performance Management-Subpart D. This section should include prohibited or poor management practices. It provides too much latitude for a supervisor to "communicate" expectations via means such as standard operating procedures, manuals, or "generally established job requirements", none of which are actually communicated by the suprevisor. None of this is communicating, but rather, they are obstacles to clear and concise, face to face communication. A supervisor could too easily shift his responsibilities down to subordinates who would be required to communicate responaibilites to others which could easily lead to many personnel issues. Page 7562, Setting and Communicating Performance Expectations. This paragraph establishes a conflct with the provisions of the paragraph cited above. It also provides for the use of the very subjective term "manner" to be used in employee performance measurement. This type of subjectivity only leads to confusion and resentment when applied. It should be avoided in any directive policy. Page 7563, 4. Single Process and Standard... Eliminating a set period for employee improvement of substandard performance does away with any ability the employee may have to correct performance when the reason may be direcly related to poor communcations of expectations. The requirement for this period allows for other supervisors to become involved in the situation and help both supervisor and the employee. It should be left as is. ------------------------------ The NSPS does not appear to be beneficial to employees in any manner and will lead to a more contentious relationship with supervision if implemented as written. It tries to resolve this potential by giving supervisors greater leeway in removing contentious employees but the primary role of management should be to provide employees with the resources needed to perform their jobs as best they can, not to be policemen or rule enforcers.