| Comment Number: | OL-10511560 |
| Received: | 3/16/2005 4:04:06 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:
1. Within the “Myths and Fact Sheet” on the NSPS website, is the statement that “NSPS will not affect rules governing retirement benefits.” This claim is reiterated at the Department of Defense NSPS Overview dated February 10, 2005, pg. 7. This claimed “fact” statement is misleading in that anything that affects pay also affects retirement benefits, because the benefit is based on pay. The honest factual answer is the NSPS will affect some employee’s retirement benefits. 2. In the Department of Defense NSPS Overview dated February 10, 2005, pg. 3, it is stated “ Current pay system results in outstanding performers being paid the same as poor performers”. a. Insufficient justification for this claim has been presented. In my 26 years of observation and experience, outstanding performers generally rise to the top through promotion. If this observation is true, why fix something that is not broken? If my observation is not true and the stated claim is true, we are left with the conclusion that many within the upper levels of our management are not outstanding performers; thus, cannot be expected or entrusted to launch a new challenging system with logic, fairness and impartiality. How will the new system ensure poor performers who may be in positions of authority are not the ones that are rating other’s performance and perhaps negatively affecting their lives unfairly? b. It is true that under the current system poor performers usually continue to get annual cost of living raises, within-grade increases, and often performance bonuses, sometimes even promotions. This is not a system failure…it is poor supervision and leadership that allows this to occur. Under the current system Supervisors are not compelled to give bonuses to poor performers, nor do they have to allow automatic step increases or promotions. It appears that it is simply easier and takes less effort to not have to deal with poor performance. Given that this is a failure of leadership rather than the system, how will a new system fix this problem? Systems do not substitute for leadership!