The GAO comments, in response to questions submitted for the record during a hearing earlier this year in the House, noted that prior to implementation of NSPS, GAO "cautioned that, while the DoD leadership had the intent and the ability to implement the needed infrastructure, it did not have the necessary infrastructure in place across the department."
GAO also said that while it has pointed out all along the importance of incorporating internal safeguards into the design and implementation of large-scale pay-for-performance programs, a report it issued late last year found that DoD should improve the safeguards for employees.
For example, DoD "does not require a third party to analyze rating results for anomalies prior to finalizing employee ratings, and therefore it is unable to ensure that ratings are fair and nondiscriminatory before they are finalized." Also, the process has lacked transparency until recently because DoD "did not require commands to publish final rating distributions, though doing so was recognized as a best practice by NSPS program officials at all four components." In addition, NSPS guidance may discourage rating officials from making meaningful distinctions in employee ratings because it indicated that the majority of employees should be rated at the "3" level, on a scale of 1 to 5, resulting in a hesitancy to award ratings in other categories.
"We continue to believe that improved implementation of these safeguards will help bolster employee confidence in the system and ensure that the system is fair, effective, and credible," said GAO.
GAO also said that DoD still needs to take action to address employee concerns about the program, such as "concerns about the potential influence that employees’ and supervisors’ writing skills have on the panels’ assessment of employee ratings and the lack of transparency and understanding of the pay pool panel process. Such a plan would demonstrate to employees that the department is listening to their concerns and making plans to address, as appropriate, the concerns that are identified. In short, DoD needs to tell the employees that they are going to take action on their concerns."