| Comment Number: | OL-10512159 |
| Received: | 3/16/2005 10:45:39 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:
Subpart B Classification--9901.212--pg 7579 Like any other tool for improving organizational performance, paybanding/broadbanding can be misapplied. One major concern is that work will be shifted from higher-level to lower-level positions. An example of this in the health care industry is ironically called "patient-focused care," under which many tasks associated with patient care are shifted from licensed to unlicensed staff. The unlicensed staff are "broadbanded" in that they must perform new responsibilities in addition to their regular tasks, often with little training or increase in pay. Licensed staff find that their contact with patients is limited through the erosion of their job duties, and thus their ability to provide quality care is hindered. Ultimately, unless protections are built in, this form of "broadbanding" is driven by the bottom line and provides no benefit for licensed staff, unlicensed staff, or patients. It is often a method of reducing and de-skilling the workforce. Another concern with regard to broadbanding is that it can allow management too much discretion and can lead to abuse. Narrow, specialized job classifications have served at least one purpose for workers over the years: They offer some protection from arbitrary job assignments and being forced to perform out-of-class work without extra pay. Thus, a broadbanding plan must include objective criteria for movement within pay grades and clear distinctions between levels within the broadbanded classifications. Broadbanding also increases the range of tasks that employees may be asked to perform, which can lead to poor performance and increased stress if workers are forced to perform unfamiliar work. Another potential problem is that training opportunities may be provided only to a few "favored" employees. Thus, assurances need to be made that all workers have an equal opportunity to develop skills that will allow them to perform effectively. This is even more important if a skill-based pay plan is in effect, since advancement within a salary band would be at least partially contingent on the development of job-related skills. Because each worker is more versatile, broadbanding often leads to a decrease in the aggregate number of workers and/or higher productivity. It is essential that the union negotiate to ensure that workers are appropriately compensated for these efficiencies.