| Comment Number: | OL-10511613 |
| Received: | 3/16/2005 4:20:01 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:
As I interpret the proposed personnel system, NSPS, I see advantages to personnel, but there is also significant latitude for abuse in its execution. Many DoD civilian personnel are highly dedicated professionals that provide many hours of time over the 40 hour week without compensation, for the unselfish reason of accomplishing the mission. Conversely, there are many less dedicated people who are abusive in many areas such as sick leave, unscheduled leave, use of government phones and government computers for nongovernment purposes. If the proposed personnel system could somehow identify these individuals and eliminate them from rosters, the DoD and the taxpayer would be well served. Theoretically, facilitating the rooting out the substandard personnel is one of the objectives of the NSPS. Unfortunately, the NSPS may identify some mediocre performers, but system can also be used by ethically challenged supervisors or managers to oust people that are intimidating. The proposed NSPS does not offer reasonable protection from this type of abuse. Further, a significant percentage of the marginal performers have received excellent performance reviews in the past and probably several performance awards along the way. In other cases, loyalty to a supervisor is what is rated in a performance evaluation, regardless of the elucidated criteria. Therefore, there are no protections for the ethical, hardworking civilan that refuses to participate in supervisor games. Because of virtually elinimating the possibility ofredress, the potential for disaster looms. (Loading the National Labor Relations Board with DoD representatives is probably not a good thing.) In my opinion, the present system provides a mechanism to accomplish each of the objectives behind NSPS. Civilians can be released for bad performance, it just requires some effort on the part of a manager and the personnelist. Civilians are sent on temporary duty many times for cumulative periods up to one year. Excellent work can be rewarded without great difficulty, and substandard performers can be downgraded. Consequently, the real reason for the NSPS must be to eliminate personnel on an ad hoc basis, possibly to accomplish outsourcing objectives without going through the often difficult process of competing FAIR Act positions. There are simply not enough "checks and balances" in the NSPS to protect the good performers from political agendas and poor leaders.