| Comment Number: | OL-10511363 |
| Received: | 3/16/2005 3:14:12 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:
Performance Management-Subpart D-Performance and Behavior Accountability. re: "DoD is committed to providing its employees, supervisors, and managers with extensive training on the new performance management system" Comment: Do not concur. We have been told that employees will receive 24 hrs of training and Supervisors/Managers will receive 48 hours of training. Why such a broad difference if equal understanding/communication/input is required from both employees and supervisors? Also- I'm in spiral 1 and we were told to "expect" training sometime in mid to late June 2005. We have been told either way, expect to convert to the NSPS in July 2005. No advance guidance other than the Fed Reg notification. Looks like more of the "thank you for your input, now proceed". Workforce Shaping- Subpart F re: "...the proposed regulations give greater emphasis to performance in RIF retention by placing performance ahead of length of service. Under current regulations performance is the least important factor" Comment: Do not concur. Current system offers additional years of service for exceptional performance. Example: An employee with 5 years of service where the last three appraisals were rated excellent will gain that employee enough credit years to out compete an employee with 15 years of service who has been rated "successful" on a retention register during a RIF. I know....I've done it. Consider revising statement to correct this inaccuracy. Wording of proposed rule leads me to believe this is simply a way to "bump" off senior more experienced and costly employees in favor of a newly hired and lower paid one.