Comment Number: OL-10511971
Received: 3/16/2005 7:03:10 PM
Subject: Notice of Proposed Rulemaking, Request for Comment
Title: National Security Personnel System
CFR Citation: 5 CFR Chapter XCIX and Part 9901
Attachment: CEC Final Pay for Performance Paper.doc Download Adobe Reader

Comments:

These comments are being submitted on behalf of the Coalition for Effective Change a non-partisan alliance of 30 professional associations representing current and retired federal managers, executives, and professionals (see http://www.effective-change.org/). The Coalition was established in 1993 to provide a collective voice for the approximately 600,000 current and retired federal executives, managers, and other professionals represented by our member associations. The Coalition is committed to communicating with policy officials at all levels of government and contributing the expertise and leadership of its members and their organizations towards the goal of achieving a government that is efficient, effective and works better for all Americans. Change that leads to improvement is our common goal. In that context, the Coalition supports the intent of the proposed regulations. More specifically, the Coalition finds that Subparts B, C, and D dealing with Classification, Pay, and Performance Management clearly have the potential to improve the Department of Defense’s ability to recruit, motivate, and retain a high-performing workforce by allowing it to developing a more flexible, market-sensitive and performance-sensitive compensation system. The Coalition also finds itself in agreement with the Government Accountability Office in that while GAO expresses strong support for human capital reform, it also correctly concludes that “how it is done, when it is done, and the basis on which it is done can be the difference between success and failure.” The implementation of the regulations and the operational details, indeed, will make all the difference in how well they achieve their purpose. The Coalition strongly encourages the Department of Defense and the Office of Personnel Management to actively solicit not only the viewpoints but also the active involvement of all employees--including managers, supervisors, and other professionals--in the implementation and ongoing evaluation of the new HR systems described in the proposed regulations. Finally, to offer more specific suggestions regarding the design of that part of the system intended to more closely link the pay of federal employees to their performance, I have attached a copy of the Coalition’s June 2004 issue paper, “Linking the Pay of Federal Employees to Their Performance.” Thank you for this opportunity to provide comments on the proposed regulations. Sincerely, John M. Palguta Vice Chair Coalition for Effective Change 3642 Upton Street, NW. Washington, DC 20008