| Comment Number: | OL-10511813 |
| Received: | 3/16/2005 5:30:05 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:
First, I firmly believe we have “performance based” evaluation capability under the current personnel system. I have been a civil servant for nearly 20 years. In my early career days, our performance standards were 5-tier, with objective and measurable evaluation criteria. If the data reflected you didn’t meet the standard for an “Outstanding”, by golly you didn’t get an outstanding (not rocket science). You got the rating you earned by meeting the pre-defined criteria. Somewhere along the way, someone in their infinite wisdom decided we should be rated on a pass/fail system using such insanely loose criteria that it ensured virtually everyone received a “pass” as long as you showed up for work (even if it was only once in a while). This was a VERY discouraging change to the system for those of us who bust hump every day to meet the mission & make things happen; we are now rated equal to those who do nothing (or less than nothing in some cases). I applaud the idea to go BACK to performance-based evaluations based on objective, measurable criteria. However, I don’t understand why we need an entirely new personnel system to accomplish this. It seems to me we’re throwing the baby out with the bathwater (so to speak). This makes me think the real agenda here is to reduce our rights, which appears to be a significant piece of this new system. Much of the critical detail of NSPS is to be designed/detailed later (after the fact!) via “implementing issuances." How can we, the affected parties, truly evaluate and comment on a system when we don’t have all the facts? It appears that the strength of things like our unions, collective bargaining, and appeal rights/abilities are severely diminished under NSPS. This is not acceptable. There is HUGE concern about implementation. The Government is notorious for very poor implementation of major systems – we see it EVERY DAY at the working level. And once it’s in place, we can forget about ever getting it corrected or reversed – somebody high up the chain has a career riding on it so come heck or high water…it is purported to be a marvelous success despite the fact that it’s failing miserably (again, we live with this kind of problem every day at the working level). Again, I’m not opposed to performance-based evaluation if done CORRECTLY. Based on what I’ve read, I’m not convinced it will be implemented well since so much of the heart-and-soul of how it will really work is not provided now; it’s to be provided later in the “implementing issuances.” OBJECTIVE, MEASURABLE performance standards are an absolute MUST if this is to work correctly and fairly. Anything short of such standards will continue to perpetuate the “good ol’ boys” club. If you have a boss that likes you, you make out great whether you really get the job done or not. If you’re boss doesn’t like you, you can be the world’s best employee and you will never achieve advancement. I also find it frustrating that after I’ve dedicated my adult life to Government service, I’ll may be forced to accept MAJOR changes to the rules of operation that I signed up under (or leave service). I made the conscious decision to be a civil servant based on the knowledge that I would never “get rich,” but at least the leave and retirement benefits were good, there were good mobility opportunities, and there was a sense of job security. I understand that things change, and the Government certainly needs to keep up with the demands of current times. I’ve willingly accepted the majority of the changes. Unfortunately, I just can’t accept this one based on the incomplete information. I suggest that it is appropriate to “grandfather” current employees under the existing personnel system, and implement NSPS with new employees (much the way the conversion from CSRS to FERS retirement system occurred), and allow current employees to convert to NSPS if they choose to do so.