| Comment Number: | OL-10511848 |
| Received: | 3/16/2005 5:45:10 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:
My main concern is NSPS's proposal to use subjective measurements as a determining factor in an employee's standing in regards to RIF, Priority Placement, etc. Specifically, awards and appraisals are both subjective. Awards are often tied to budgetary constraints within an organization. An individuals career may be adversely impacted, not due to fault of their own, but rather as a result of lack of funding resulting in now award. Worse yet, many organizations typically look for reason not to give an award due to the limited funds available to award employees. For example, last year I was told I did not receive an award because I recently got promoted. They considered the promotion my award. Based on this scenario under NSPS, I am subject to displacement due to a factor for which had no basis on my actual work performance. Appraisals are also a subjective measurement that should not be used. The only way appraisals can possibly be used is if the appraisal rating was a simple pass/fail. Anything beyond a pass/fail system resulting in a numerical score is subjective. For example, one supervisor may rate an employee's communication skill as a 7 while another may deem it a 9. NSPS must be fair and just. Using appraisals and awards to determine the score in which on falls in for displacement is not a fair and just system. If DOD adopts the current NSPS proposal, it is my belief that the DOD will be challenged in the higher court as to the validity of their method for displacing employees.