Comment from Rob Emmert

We can call this "promoting employee accountability all day but this is about letting management off the hook to actually demonstrate why any action is being taken and how it meets the just and sufficient cause standard for actions... If you have to ask yourself why the "12 steps" are important it is simply because the application of a standard is the bedrock principle of a professional civil service. When left to their own devices too often vibes and feels impinge upon good and impartial judgement. Having a "checklist of sorts is the bare minimum to insure employees are being treated fairly and with a similar approach, not favoritism due to personal affiliations. Every single one of us know someone in life who seems to get away with things that we couldn't simply because they know the right people, drive the right cars or hang out in the right social circles. Those are the people who always seem to get the beniift of the doubts and never get to the intersection of actions and consequences. The Douglas factors are a 12 step guidepost in the civil service to insure all employees are treated fairly and equally without regard to their personal affiliations. removing them returns the civil service to the days of vibes and connections that mean more than the actual impact on agency performance and goals. They insure that discipline is undertaken for the right and justifiable reasons. 1. The nature and seriousness of the offense, and its relation to the employee’s duties, position, and responsibilities, including whether the offense was intentional or technical or inadvertent, or was committed maliciously or for gain, or was frequently repeated; 2. The employee’s job level and type of employment, including supervisory or fiduciary role, contacts with the public, and prominence of the position; 3. The employee’s past disciplinary record; 4. The employee’s past work record, including length of service, performance on the job, ability to get along with fellow workers, and dependability; 5. The effect of the offense upon the employee’s ability to perform at a satisfactory level and its effect upon supervisors’ confidence in the employee’s ability to perform assigned duties; 6. Consistency of the penalty with those imposed upon other employees for the same or similar offenses; 7. Consistency of the penalty with any applicable agency table of penalties; 8. The notoriety of the offense or its impact upon the reputation of the agency; 9. The clarity with which the employee was on notice of any rules that were violated in committing the offense, or had been warned about the conduct in question; 10. Potential for the employee’s rehabilitation; 11. Mitigating circumstances surrounding the offense such as unusual job tensions, personality problems, mental impairment, harassment, or bad faith, malice or provocation on the part of others involved in the matter; and 12. The adequacy and effectiveness of alternative sanctions to deter such conduct in the future by the employee or others. I honestly don't know what is so dammed controversial about this - but - ignoring them is going to open up a minefield of litigation and increased awards for supervisory wrongdoing and retaliation with corresponding expenses borne of the US taxpayer