| Comment Number: | OL-10512214 |
| Received: | 3/16/2005 11:49:27 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. Overall: I suspect that too much of the burden for managing personnel has been shifted to individual supervisors, vice having a well-function system for them to work within. Aside from making supervision a full-time job--no matter the tools and training offered--the net effect can only be to detract from the time the supervisor has to do the other 90% of the job he/she was hired to do. 2. On pay banding--without the benefit of evidence, I suspect that pay-banding will eventually create a top-heavy band where 'managing to the budget' must either drive out people to stay in budget, or result in no funds available to do the things advertised for the system. I don't believe small-scale test cases of the past reflect what will happen when budget pressures on whole Departments are brought to bear. 3. I do not believe that all the direct, secondary or follow-on effects of the system have been thought of, anticipated, or planned for. Presenting the system as a fait accompli and salvation for all the world's woes is a disservice to all. Regular revisits to sample the health of the system and its participants, perhaps by neutral third parties, should be built into the implementation plan, with open acknowledgement that changes may have to be made as we go along to adjust to unforeseen problems.