| Comment Number: | OL-10512022 |
| Received: | 3/16/2005 7:59:18 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:
1. My immediate concern with the NSPS is the time line to establish the program. Details about the program, until recently, have been vague. (Proposed rules dated Feb 05). The length of time required to research and understand the program should be worked into people’s schedules. Why start the whole 9 yards at the same time? Why not implement the program in stages-e.g. Start with the hiring changes. 2. I do not believe that “extensive training” has been provided prior to deploying the program, as I have seen none. Employees have not been provided the opportunity to ask how this will effect their positions, nor have supervisors been trained in their responsibilities. There should have been a lengthy advertising campaign (road show, presentations, town hall meeting, etc) well in advance of instituting this program. The second phase should have been the training, third phase implementation. The web site certainly indicates to me that the road map isn’t clear to everyone. It is hard to expect people to get on board when they don’t know what is going on-you leave supervisors “holding the bag”. “Supervisors and managers will be held accountable for how effectively they use the tools provided by NSPS”.—Where are the tools-Still haven’t seen the tools. “They will also be subject to the pay and performance provisions of the system, and their pay will be affected by how well they perform their duties as supervisors and managers”. The assumption here is that all supervisors are well supervised or that they are all equally skilled at supervising (remember the Peter Principle). 3. Now that supervisors are tied to employee’s salary they will be looked at differently. I see a rise in disgruntled employees and some supervisors who don’t want to create a hostile work environment skirting the confrontation. The stakes for being in the supervisor roll have gone up considerable. 4. Not sure why throw the baby out with the bath water. Looks as thought the whole civil service program was done away with as if none if the "old" ways had merit. I can agree that the hiring area needed some re-vamping but I’m still not sure I know how the pay banding ratings work. Already I hear supervisors who believe this is a way to get their workers GS-11 pay for GS-9 jobs or a quicker way to get their people upgraded when the request was turned down under the old system. 5. Are the taxpayers ready to pay people for work not required or directly mission related? A position description shows the parameters of the job. If someone volunteers in the base/community or takes on additional work and another person doesn’t but fills in the void left by the volunteer, who gets more money? The following year the supervisor may find all the “extras” got the unit notoriety and require these additional duties of all their workers. Are there checks and balances that say this is or isn’t value added to the mission? Who pays for the “extras”? -Seems to promote, or at least looks like, you are doing more instead of streamlining the basic job/mission focus. Of course who will be able to question if someone is doing their job or not, since NSPS get away from “lengthy, detailed job descriptions”. 6. Who pays for all this? If a band pays from GS-5 through GS-11, invariable the tax payer can be paying, (using the GS ratings as an example of comparison) a GS-5 at a GS-9 level when the job required has responsibilities and duties that would not exceed a GS-5. There will be GS-11s with supervisory duties that may find someone working at a GS-9 rated position being paid more than they are without having equal responsibilities. I can’t see how this is incentive for the civilian in the supervisory position. 7. I see much too much subjectivity in pay banding. Will the breath of responsibility required in one position of an organization be viewed at an equal pay band in another organization?