Comment Number: OL-10511899
Received: 3/16/2005 6:14:58 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:

Performance Management Subpart D (pg 7562) -- general concern that upon conversion and continuing, that with the communication of performance expectations that the workloading of an individual is appropriate to the band and the level within the band (there are cases now that because there is not adequate secretarial and admin support that high level professionals are having to perform these functions which could bring down contribution scores) Adverse Actions Subpart G (pg 7565) -- Is the sentence referencing the IRS needed? Appeals Subpart H (pg 7565) -- The sentence beginning As noted, ...is the section beginning ...",despite the fact that DoD and OPM could have established a separate appellate body for the initial review of all such actions," needed? Labor-Management Relations Subpart I -- (pg 7569) Sec 2 FLRA is not spelled out, (pg 7571) sec 11 "However, we have provided.." who is we? Next Steps (pg 7573) The Secretary and the Director must provide employee representatives -- these are not explained Subpart A -- Sec 9901.101 Purpose NSPS will be operational and demonstrate success prior to November 2009 -- how will success be measured and determined? Sec 9901.103 (pg 7576) Definitions Is contribution a subset or part of performance? Sec 9901.106 (pg 7578) Continuing collaboration How many employees are considered a substantial number? Subpart D--Performance Management Sec 9901.405 and Sec 9901.406(pg 7585) Recommend specifying employee/subordinate feedback/input into the holding of supervisors and managers accountable for effectively managing the performance of employees and in the assessment and measurement of how well supervisors and managers plan, .... Sec 9901.405 (pg 7585) Performance management system requirements Recommend adding subsection on appropriately workloading such that expected contribution can be achieved Sec 9901.407 (pg 7586) Monitoring performance and providing feedback Recommend two (vice one) or more interim reviews which will allow for performance correction/documtation or incentivization/reward Subpart H Appeals (pg 7592) Sec 9901.806 Alternative dispute resolution -- I applaud the strong recommendation to use this mechanism throughout the process -- from the setting of objectives through the each formal or informal review -- so as to avoid formal grievances