Comment Number: OL-10511470
Received: 3/16/2005 3:40:37 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:

Obviously, the rule laid out for NSPS is intentionally quite vague. Nevertheless, having said that, it's understandable that it leaves more questions in my mind than answers. The assumption is that, having made a case for national security, everyone will be truly righteous, upholding principles, and doing what they are supposed to do. While on paper this sounds wonderful, reality is that people are human and no system, no matter how perfect on paper, will achieve that, to include what they say this one will. -- Pay for Performance. As written, this rule sounds like they are treading new water, when in fact; it wasn't so many years ago that we were put under the Merit Pay System. Same premise...pay for performance. They trained supervisors and managers for this change, too, and nevertheless, it failed. Part of it was supervisors and managers really weren't held accountable as planned. Human nature, as it is, makes people avoid doing difficult things... dealing with poor performers being one. Being a supervisor is difficult under the best of circumstances. Therefore, no matter how much you train people on the PROCESS and what is intended/expected to happen, it will be extremely difficult to get there when it requires folks to move out of their comfort zone. The 1978 Civil Service Reform Act also emphasized the importance of job performance. Yet, we have systems in place now that do not work effectively as they should. To blame the system as not working (as is stated in the background for NSPS) is easy, but history has proven it’s deeper than that. You are dealing with people and issues that require them to tackle uncomfortable issues. This has resulted in a laxness regarding performance that is now systemic in the culture – one based on lip service and avoiding tough situations, particularly if it might bring EEO complaints. The document states: “…DoD is committed to providing.... extensive training...” Be assured that the training needs to go way beyond actual PROCESS in order to work. It needs to deal with the culture these same folks have been working in for years and strongly teach (pinpoint) what is acceptable for effective supervisors and managers to do...that they cannot avoid tough decisions. … In addition, hold them to do their jobs as objectively as possible. -- Collaboration. It's truly amazing how many times the term is used in the document and yet, in actual practice, I can say that to this point in time, it does not seem to be working effectively. When you realize where I work, it is unreal that we are (and have been) so in the dark. And what about the unions? They are suing for not having the ability to “participate meaningfully in the process.” Future continuing collaboration needs to be truly open. While you may have attempted to connect with certain select folks, it does not meet the intent of good faith efforts that the document speaks to. On page 7556, it states, "(2) demonstrate openness and transparency in the design.” .... Moreover, why the rush? One almost gets the impression that you are trying to railroad this on purpose. -- Elimination of career-conditional. This concerns me that we are trying to streamline and speed up the processes so much that we may be sacrificing security in this case. The career-conditional period was purposefully put in place to be a trial period to see if this person was truly someone who warranted to be made permanent. Several checks were processed on this person in the time. With the realization that security screenings are significantly backed up and not happening in a timely manner, does it make sense to eliminate the trial period without the crucial information needed to determine his/her suitability? The whole basis for moving to the NSPS system speaks to national security. Why would we cut a corner that does not support that premise?