The Office of Personnel Management has been busily reversing course on federal workforce reductions with some splashy hiring announcements. In December, it launched Tech Force, a pooled recruitment effort targeting 1,000 early-career technologists to be placed across agencies for two-year stints. In March, it stood up across-government shared certificate for project managers. It launched an Early Career Talent Network spanning five job categories. Two weeks ago, it expanded Tech Force into cybersecurity. OPM Director Scott Kupor has been explicit about his ambition: this is a “model for more centralized, efficient hiring across government.”

I’ll bite: yes, there’s a lot of promise in that! The instinct behind all of these actions builds on years of initiatives meant to create efficiencies out of the hundreds of thousands of hires made federally each here. Pooled hiring, which should include one well-designed announcement, one shared assessment, and many agencies drawing from the same pool of qualified candidates, is exactly the kind of tool the federal government should be using. I saw this up close when I was at OMB and I fully drank this Kool-Aid. The logic is compelling: (typically) the federal government processes over 22 million applications and hires over 350,000 people into public service every year. No private employer operates anywhere near that scale, which I still believe can be an asset, and pooled hiring creates the entry point to get there. 

But pooled hiring has a track record (going back several administrations), and it’s uneven. Most recently, the Biden administration championed it most ambitiously during the infrastructure surge, where OPM partnered with seven agencies and hired roughly 5,000 employees, doing things like USDA hiring 39 HR specialists off a single certificate (if this sounds underwhelming to you, trust me when I say it’s mindblowing to your average hiring manager; more explained shortly). But the same period produced plenty of pooled actions that generated duplicative work, agency foot-dragging, and candidates who aged off certificates before anyone made them an offer. FAS and others have been studying these challenges in the context of the permitting workforce surge, and the problems are structural, predictable, and repeating. Also? Solvable. 

The concept has promise but implementation has kept breaking in the same places. This piece is about why and about how to get it right, now, while there’s political will and active momentum to use it.

The Design Error at the Center of Everything

First, a quick explainer on how this actually works — because “pooled hiring” gets used loosely and the mechanics matter. A pooled hiring action is a competitive job announcement run either by OPM centrally or by a lead agency on behalf of multiple agencies and intended to fill multiple open positions in multiple agencies. Instead of each agency posting its own announcement, recruiting its own applicants, and running its own assessment, one announcement goes out, one applicant pool forms, and one assessment process screens candidates into a shared certificate of eligibles (government-speak for a ranked list of candidates that agencies can choose from). Agencies that have signed on to participate can then make selections from that certificate without having to run their own action from scratch. OPM-run actions (like the current Tech Force or the project manager cert) work the same way, just with OPM as the lead rather than a single agency. Either way, the cert is the output: a ranked list of candidates who have been assessed as qualified, available to any participating agency to hire from without having to solicit new resumes, review their qualifications, administer assessments, or other tedious parts of the hiring process.

That’s the theory. 

The shared certificate is where most implementations stop. Agencies get a screened list and then do their own thing — their own interviews, on their own timelines, with their own offer processes. Or maybe they don’t, even when they said they would! The coordination ends at the cert. Everything downstream remains fully siloed at each agency.

This is far from the ideal that most policymakers have in mind and what many private employers do. A genuine pooled hiring action pools the whole pipeline. Recruitment, assessment, interviewing, and offers — all coordinated, all running in parallel across participating agencies. That doesn’t work for every role, but in surge situations, or for roles where agencies make dozens of hires of the same roles every year, it’s great. Agencies don’t just agree to draw from the same pool. They show up on the same interviewing days. They make offers on the same compressed timeline. Candidates who applied once get considered by many agencies simultaneously with each running its own slow-motion version of the process.

Almost nothing the federal government currently calls “pooled hiring” actually does this. The new OPM actions are no exception. Tech Force is better marketed than previous efforts, and the private-sector partnerships are genuinely new. But the selection and offer stages remain siloed at each agency and I’ll be very curious if they make selections. That’s the design flaw everything else flows from.

What Breaks When You Don’t Fix the Design

When I was at OMB, we saw these failure modes up close, in what were probably deeply frustrating meetings with the valiant program team as we learned where the seams were. Some things we saw:

Pooled hiring worked when it was a clear administration priority and had OPM and OMB supplementation. Early indicators suggest that Tech Force has success because it’s clear that the administration, the OPM director, and OPM staff are both giving it attention and smoothing implementation behind the scenes.  That’s good for proof of concept, but it doesn’t show the weaknesses that can emerge when administration accountability doesn’t hold agencies to delivery on innovation hiring methods. 

Agencies didn’t trust screening they didn’t run. OPM’s own guidance requires agencies making selections from another agency’s certificate to verify that the original qualification and assessment criteria are appropriate for their position. That verification step becomes a second screening — which defeats the efficiency rationale entirely. Agencies that double and triple-screened candidates created more work than if each had run its own action from scratch. The fix isn’t better guidance, it’s building trust into the design upfront, by ensuring the people trusted with the most relevant subject-matter expertise help design the assessment in the first place.

Demand didn’t stay put. Agencies raised their hands, agencies or OPM ran a resource-intensive recruitment action, and then agencies were slow to hire — or circumstances changed before they did. The August 2024 OMB/OPM hiring memo specifically directed agencies to review available shared certificates before launching new hiring actions — a discipline that, if actually followed, would force better demand alignment upfront. It mostly didn’t happen and, absent the sort of prompting we talk about later, is hard to enforce. Partly this is a culture problem, but it’s also a structural one: agencies that don’t plan for talent surges find that new hiring needs don’t align with their existing workforce plans or their capacity to recruit, assess, and onboard. You can’t opt into a pooled action and then be surprised when the pool fills.

We struggled to tell the right people, and the system didn’t either. There’s a more fundamental problem sitting underneath the demand-alignment failure: hiring managers and HR specialists often don’t hear about pooled hiring announcements at all, and when they do, it’s generally not with enough lead time to actually prepare. Pooled actions get announced through OPM memos and Chief Human Capital Officers (CHCO) Council communications that circulate at the leadership level (and boy howdy did we circulate!), but that information doesn’t reliably travel to the hiring manager who is already three weeks into drafting a job announcement for the exact role sitting in a shared cert. And when it does arrive, it arrives as information: there’s no deadline attached, no checklist triggered, no reason to stop what they’re already doing. As it stands, among the 200K+ hiring managers, most made very few hires a year or in their overall career, so learning a process with barriers to entry was challenging. 

Nothing interrupts the default action.The deeper problem is that nothing in the hiring workflow itself cues anyone to look. When a hiring manager initiates a new action in the hiring system, they’re not pushed or incentivized in any systematic way to check for an existing cert. When an HR specialist begins drafting a job announcement, no flag surfaces to say: a shared certificate for this position series already exists, do you want to use it? The system simply lets them proceed. This means that even when an agency or OPM has done the work of running a pooled action and producing a cert, agencies duplicate that effort anyway; less due to indifference, but because the path of least resistance is to do what they’ve always done, and nothing in the process interrupts that default.

The fix here is partly cultural but a lot technical. The Agency Talent Portal and USA Staffing need to surface available shared certificates at the moment a hiring manager or HR specialist initiates a new action for a covered position: as a required check embedded in the workflow itself. If you’re about to post a GS-12 data scientist announcement and there’s an active governmentwide cert for that exact series and grade, the system should tell you, right then, before you proceed. Opt-out, not opt-in. The current design assumes awareness that doesn’t exist and motivation that isn’t reliable.

Pooled actions were expensive for the “owner” and the experts: While cost-saving overall, running pooled actions could be resource and time consuming for the “owner,” and particularly the subject matter experts brought in for assessment, particularly when hires were not ultimately made. 

The position description bottleneck. Pooled hiring inherits whatever good and bad planning exists in agencies’ position description (PD) libraries. Even for commonly-hired roles, position descriptions are not always readily accessible and, likewise, standard assessments often don’t exist at every grade level. But it’s a bigger challenge than that: the whole GS system presumes (competencies, job task analyses, and more) that every job is highly specialized, not generalizable for cross-agencies pools. FAS documented this directly: OPM and the Permitting Council collaborated to create a pooled, cross-government announcement for Environmental Protection Specialists — one job announcement producing a candidate list many agencies could use. But the assessment became a bottleneck because standard assessments didn’t exist for each grade level in the announcement, requiring significant additional development time. This isn’t an edge case, it’s a Tuesday. Breaking!  OPM Director Kupor just announced a new AI tool to generate PDs!  We’ll follow with interest. 

Hiring managers couldn’t get access without a permission chain. For a new hiring innovation to be adopted, you’d think that all the barriers, incentives, and opt-in/out dynamics would be aligned. You’d be wrong. Pooled hiring at a “mother may I” architecture: system passwords and access, coordinators, gating processes, intermediaries between hiring managers and shared certificates. It’s a design flaw dressed up as compliance. The same 2024 memo had to explicitly direct agencies to update hiring manager permissions in the Agency Talent Portal. That it needed to be said tells you everything about how poorly the access question had been handled. As FAS and the Niskanen Center jointly documented in their analysis of the current OPM hiring memos, the toughest tasks are also the most crucial: changing the culture around hiring to empower managers, and actually letting line managers be managers.

Talent teams could be a good idea that keeps getting launched without the authority or resources to actually work. Every administration for the past decade has called for empowered agency talent teams — small, specialized units charged with driving hiring innovation, adopting new tools like SME-QA, and coordinating participation in pooled actions. M-24-16 explicitly called for agencies to create and sustain these teams, and the current OPM Merit Hiring Plan has stood one up at the central level as well. The concept has potential but execution has been consistently undercut by the same failure mode: no committed resources, no authority to intervene, no access, and no product mindset. In understaffed agency HR offices that were not empowered to “get to yes”, the function hasn’t meshed well, and moreover, it’s arrived in a system that already lacks strong strategic workforce planning, a key enabler of its potential success. 

As FAS and the Niskanen Center documented agency talent teams, OPM communications and education support, and the necessary systems changes all require people, money, and IT investment that hasn’t materialized. Announcing a mandate is not the same as funding its execution.

But underfunding isn’t the only problem. Even well-resourced talent teams have struggled when they lacked the institutional standing to actually change agency behavior. The core failure mode is assuming that having good people in the building is enough — that talent solves problems on its own, without a clear theory of change about authority, access, and how decisions get made. An agency talent team that is advisory in nature, without a direct line to hiring managers and HR decision-makers, without leadership backing when they push back against entrenched process habits, and without metrics that create accountability for adoption, is not going to move the needle on pooled hiring participation. It’s going to produce reports and hold workshops and then watch agencies do what they were already going to do.

Veterans preference created confusion that nobody addressed proactively. Preference applies differently in delegated examining versus merit promotion contexts. When agencies share certificates across those lanes, legal ambiguity creates real hesitation. This is genuinely solvable — but only if OPM issues targeted guidance with each pooled action as a standard part of the launch package. Stepping back, it’s necessary to state that any type of absolute preference is going to make pooled hiring challenging. Clarifying guidance is a Band-Aid.

Small technical barriers compound the problem. One underreported friction point: shared certificate policies can constrain agencies from sharing certs across different geographic locations designated in the original announcement, or across different hire types — temporary versus permanent. An agency running a pooled action for DC-based positions can’t easily extend that cert to field office hires. A cert issued for permanent positions doesn’t smoothly cover term appointments. These are solvable technical problems that OPM and OMB could fix through policy revision but they require someone to actually map the barriers before designing the action.

And when agencies go it alone anyway, the burden multiplies for everyone. This is the part that gets lost in discussions that treat siloed hiring as merely inefficient rather than actively harmful. When agencies that are already understaffed — particularly permitting and HR teams — don’t leverage opportunities to work together, bottlenecks compound. Pooled hiring isn’t just a convenience for well-resourced agencies. For teams that are already stretched, it’s the difference between a manageable workload and an impossible one.

Agency HR leads without the skills or network to work across agencies. Like so much else, pooled hiring depends on relationships. OPM and agencies have not carefully selected the HR managers who not only understand the potential policy barriers to working across agencies but the collaboration skills and networks to solve problems quickly. 

The Assessment Question: Use the Right Tool Not the Easy One

If you’ve read this far, you’ve probably heard of things like SME-QA, the greatest acronym in the hiring world. Let’s talk assessments. 

The default federal hiring assessment — the self-assessment questionnaire — is effectively worthless for identifying technical talent. As Jennifer Pahlka has put it, the system has been built so that the most important knowledge is how the hiring process works instead of the knowledge needed to do the job. A nationally recognized programmer once applied to the Department of Defense and was initially rejected because their resume described real expertise in language that didn’t match OPM’s classification keywords. Meanwhile, someone who understood the system could mark themselves “expert” across every self-assessment category with no verification at all.

The Subject Matter Expert Qualification Assessment, or SME-QA, was one of the skills based hiring toolkits developed to fix this: real experts screen for real skills, with HR ensuring merit principles hold. SMEs independently review every resume. Candidates who clear the initial bar then go through further steps like structured interviews, coding exercises, or written assessments — administered by other practitioners in the field, not generalist HR staff. For technical roles going into a pooled action — data scientists, cybersecurity professionals, engineers — SME-QA paired with a shared certificate is close to the ideal design. Build the assessment once with governmentwide SME input, share the cert, and every agency draws from a pool that was actually screened by people who know the field.

But any skills based hire practice has a scaling problem that’s been documented since the first USDS pilots. The work is resource intensive for federal agencies not used to dedicating so much SME time to a hiring process. As Niskanen’s recent analysis of the Chance to Compete Act makes clear, new written assessments developed by industrial-organizational psychologists are extremely resource-intensive to produce — likely prohibitively expensive at the scale needed to cover broad swaths of the federal workforce. But there are roles and moments where such dedicated investment makes sense. 

The design principle that should govern this: pooled hiring should be an opportunity to concentrate assessment burden at the enterprise level, not multiply it at the agency level. Build the assessment once, or maximize use of SME-QA time, governmentwide, for roles where it genuinely matters. Actually use them consistently rather than rebuilding from scratch at each agency. And as Niskanen argues, transform OPM’s role from compliance monitor to assessment engine: a marketplace of vetted, shared tools agencies can pull from rather than commission independently.

There’s a trust dividend here too. Agencies that contribute subject-matter experts to the assessment design have far more reason to trust the resulting certificate. Skin in the game at the assessment stage translates directly to confidence at the hiring stage.

A Note On Listening

Many successful pooled actions worked because OMB and OPM (or other senior White House offices) gave attention, capacity, authority and accountability to the process, bolstering agencies who were being asked to execute hiring  with unusual flexibility and competence. 

Overall, however, when agencies told OPM and OMB that pooled hiring was hard for them to execute alone, the response from the center was too often some version of: the guidance is out there, the instructions are online, that’s how the process works. Agencies described a cascade of rigidities that made implementation genuinely difficult, and we weren’t always responsive. We treated compliance problems as communication problems. If agencies weren’t doing it right, they must not have understood it correctly, so the answer was more guidance, clearer FAQs, better webinars.

That’s the wrong diagnosis. What they were telling us was that the process didn’t fit their reality and that the gap between what the policy assumed and what their operations actually looked like was wide enough that no amount of additional instruction was going to close it. When the people responsible for carrying out a policy are consistently telling you it’s hard in specific, consistent ways, the right response is to ask what’s broken in the desig.. The people designing these systems need to hear that feedback as signal instead of as resistance to be overcome.

This is the reason why the recommendations in this piece are about structural changes to how pooled hiring is designed, not about better outreach or clearer communications. Agencies don’t need another memo explaining how shared certificates work. They need a system that works in the conditions they’re actually operating in.

How to Actually Do This Right

The current OPM actions are a real opportunity. Here’s what would make them work, stated as plainly as possible.

Lock in real demand before you launch. Not expressions of interest: actual hiring commitments with funded billets and named positions. The failure mode is OPM building a pool that agencies shop from slowly or not at all. Require agencies to submit hiring forecasts before they’re included in a pooled action, and hold them to those forecasts with visible accountability.

Build assessment infrastructure before the announcement goes up. Standardized PDs, validated assessments, and clear SME selection criteria that agencies trust need to exist before the action launches. Thecentralized position description library called for in M-24-16 is the right vehicle. Critically, assessments need to exist at every grade level included in the announcement. 

Build the awareness and the system prompt together. Upgrade communication on pooled hiring announcements directly to hiring managers and HR specialists. But communication alone won’t fix this. The Agency Talent Portal and USA Staffing need to surface available shared certificates at the moment a hiring manager or HR specialist initiates a new action for a covered position series and grade. This should be a required check embedded in the workflow itself — before they proceed with drafting a new announcement. If you’re about to post a GS-12 data scientist announcement and an active government-wide cert exists for that series and grade, the system should tell you right then. The current design assumes awareness that doesn’t exist and motivation that isn’t reliable.

Pool the interviewing, not just the screening. Coordinated interviewing days. Same-day or 48-hour offer authority for hiring managers. Agencies competing for the same candidates simultaneously, not sequentially. Cross-agency onboarding cohorts that start together and build peer networks from day one. This is what actually compresses time-to-hire.

Fund and empower talent teams as implementation infrastructure. Every idea in this piece requires someone inside each major agency whose job it is to make that happen. That’s what a talent team is for. But talent teams need three things that they rarely get: a dedicated budget line, direct access to the hiring managers and HR leadership they’re supposed to influence, and metrics that hold them accountable for adoption rates and actual hiring outcomes rather than process activity. A talent team of one person with a shared budget and no senior sponsor is not an implementation strategy.

Give hiring managers direct access. Update the Agency Talent Portal permissions. Eliminate the intermediary layers between a hiring manager and a cert they’re authorized to use. Hold managers accountable for whether they hire. Culture change here is real but it follows structural change: when managers have direct access and clear authority, behavior shifts.

Make follow-through a metric with teeth. Agencies that opt in and don’t hire should have to explain why, publicly, to the President’s Management Council.The voluntary participation problem doesn’t get solved with please-and-thank-you memos.

Run continuous pooled actions for common roles. HR specialists, contracting officers, environmental specialists, IT managers — these aren’t surge needs, they’re permanent ones. A cert that’s always open, with agencies drawing from it as needs emerge, is far more useful than a prestige program that runs once a year and then goes quiet.

The Bigger Lens

(with thanks to Gabe Menchaca and Peter Bonner for making the stronger argument)

Pooled hiring is a microcosm of a question the federal government seesaws on constantly: what does it mean to govern as an enterprise rather than as several hundred agencies that happen to share a payroll source?

This requires admitting something those of us who have worked in the center don’t always say plainly: agencies and their leaders are protecting their turf for understandable reasons. They are accountable for their missions, their budgets, and their outcomes. When a pooled hiring action asks them to trust a cert they didn’t design, coordinate interviews around a shared calendar, and accept that they won’t get every single thing they want, and that’s a big ask! The trade may be worth making, but it doesn’t happen automatically, and the center has not historically done a good job making the case for why, or building the conditions under which agencies can actually say yes.

That’s a collective action problem, and it’s harder than it looks. It requires genuine leadership alignment across all the agencies involved, and a center that has made the benefit of cooperation concrete and visible rather than just asserting it in guidance. Too often the response to non-participation has been more documentation rather than an honest look at what the actual barrier was. That’s compounded by a structural problem worth naming: agencies are accountable for their HR outcomes but OPM holds much of the compliance authority over how hiring gets done. Accountability without authority produces exactly the behavior you’d expect.

The federal government has demonstrated it can operate differently. The BIL surge, the data scientist certs, USDA’s HR specialists (and maybe Tech Force) worked because the conditions were right: shared design, locked-in demand, leadership alignment, enough urgency to overcome the default toward agency autonomy. The question is whether we can build those conditions deliberately rather than stumbling into them during a crisis. That requires a solid theory of change about how cross-agency infrastructure actually gets adopted: one that takes agency self-interest seriously as a design constraint rather than an obstacle to be overcome by memo. Get that right, and pooled hiring becomes a model for how the federal government decides what to do together and what to do apart. That’s a bigger prize than faster hiring. It’s a more functional government.

In February 2026, the Office of Personnel Management finalized a rule creating Schedule Policy/Career, a new category for certain career federal positions they deem as “policy-influencing.” 

When the rule was initially proposed, FAS raised concerns that removing civil servant employment protections could place unnecessary and undesirable political pressure on highly specialized scientific and technical career professionals serving in government. While we appreciate the Administration’s revisions (such as those that clarify competitive service status), important questions remain about how the rule will be implemented in practice, and how it may affect agency operations, workforce motivation, and mission delivery. This is a complex change to a long-standing system, with significant implications for thousands of current and future public servants – with great potential for unintended consequences. Congress has both a responsibility and opportunity to understand the rule’s intent, implementation, and impacts as it works constructively to shape a better federal workforce system that meets the needs of the country.

This resource is designed to help Congressional members and staff (and other oversight bodies) with cross-cutting and agency oversight roles understand what implementation could look like, where discretion lives in implementation, what changes or risks may emerge over time, and what questions may be most useful to ask in oversight activities such as hearings, briefings, letters, commissioned reports, and GAO audits. Potential areas to watch and requests are aimed at specific implementation periods, as part ongoing engagement with individual agencies, or as part of more holistic review, with the goal of supporting practical, evidence-based oversight as agencies put the rule into effect.

Background

Under the rule, Schedule P/C positions remain career, merit-based roles, but employees in Schedule P/C roles:

• Move from the competitive service to the excepted service, with no appeal for such transfers
• Lose Chapter 43 (performance) and Chapter 75 (adverse action) due process protections under Title 5
• No longer have MSPB appeal rights
• Become effectively at-will for purposes of removal
• Retain protections from prohibited personnel practices (PPP) enforced internally instead of the U.S. Office of Special Counsel (OSC)

Importantly, career staff who had competitive status can transfer to a non-Schedule P/C role and regain competitive service protections. Staff who are hired into Schedule P/C roles under the merit system can likewise gain competitive status after 2 years and acquire competitive service protections if they move out of Schedule P/C.

This rule gives agencies significantly more authority over certain career policy roles. Whether that authority improves accountability or creates new risks depends almost entirely on how agencies interrupt and apply it. 

If you’re interested in….

What the rule actually changes (and what it doesn’t)

Understand

• Schedule P/C are not political appointees. Under the new regulation, schedule P/C roles are policy influencing roles hired through merit processes and who retain their roles across administrations, vs. political appointments, which are selected through the White House and whose tenure ends when a president leaves office. 
• The rule primarily changes protections and removal authority for staff moved to Schedule P/C, not hiring – though overseers should stay aware of hiring practices for these roles. 
• Schedule P/C roles remain career, merit-filled positions and P/C employees have or can attain competitive service status (but this is worth continued engagement on)
• However, while in P/C roles, employees lose Ch. 43/75 process due process protections and MSPB appeal rights.

Ask agencies (now)

• How are you explaining this change to managers and staff?
• By what criteria will you decide what agency positions are determined to be “policy influencing” for approval by OPM?
• What written guidance have supervisors received? 

Watch

• Confusion in agencies about what this is 
• Implementers with different interpretations on breadth of the definitions
• Differential discussion of or treatment of Schedule P/C roles beyond this rulemaking

Why it matters: Early confusion or inconsistency may lead to uneven or overbroad designation of roles, uneven treatment across agencies, or morale challenges due to confusion about goals.

What is policy influencing (and what isn’t)

Understand: Agencies are supposed to identify roles based on whether the duties of the position meet the statutory test for being policy influencing – the role, not the person. Agencies are told to consider: roles that:

• Shape, write, or interpret regulations or policy
• Advise senior leaders on policy choices
• Translate presidential or agency priorities into action
• Direct the work of people doing the above
• Sit in policy offices, regulatory offices, or leadership advisory roles
• Have authority to influence how laws and directives are carried out

Agencies should not be considering: 

• Performance
• Seniority
• Political beliefs
• Individual behavior

Ask (after agencies have made determinations): 

• What criteria did you use to determine a role was policy-influencing? 
• Did you conduct a role-by-role analysis? Are there instances where you designated whole offices?
• Which occupational series and functions were included? Were scientists, attorneys, grants officials, or program managers included? 
• How did you treat supervisory roles?
• What written justification exists for each position?

Watch: 

• Expansion or changing of definitions over time beyond the initial intent
• Use of office-wide or team-wide designations rather than position-specific analysis
• Application of the definition to roles that are primarily technical, scientific, legal, or delivery-oriented rather than policy-shaping
• Variation in interpretation across components or agencies

Why it matters: Good oversight here is about definitions and consistency.

How positions get put on the schedule

Understand: Agencies identify the roles, OPM vets the justification, and the President makes the final decision to place the positions into Schedule Policy/Career.

Ask (after agencies have made designations)

• What process did agencies use to identify positions? Are all such positions designated Schedule P/C?
• Who approved each designation at agencies?
• What documentation supports each decision at agencies?
• How are employees and job applicants notified about placement into Schedule P/C?
• How is OPM ensuring consistency between agencies?
• Given the volume of positions reviewed, what process exists to revisit or correct designations if needed?

Ask (on a rolling basis, or in a GAO review 1 year after implementation)

• How many positions were added after the initial designation?
• What justifications were used later, and did they change in scope?
• Whether the definition of “policy-influencing” is changing?

Watch

• Whether processes remain consistent and well-documented over time
• Patterns of employee questions or concerns about how decisions were made

Why it matters: Much of the practical discretion in this rule rests in how agencies conduct and document this step. Understanding this process is key to meaningful oversight.

What the loss of Chapter 43 & 75 protections really means

Understand: This removes performance improvement periods (PIPs), MSPB appeal rights, and statutory due process (notice and response) removal processes.

Ask

• How will agencies set standards for managers to meet before removing someone on Schedule P/C? 
• What internal review happens before a removal decision is finalized?

Watch

• How frequently this authority is used across agencies
• Whether managers express uncertainty about when or how to use this authority
• Differences in how agencies apply this authority
• Situations where employees raise concerns related to PPP protections

Why it matters: The health of the civil service depends on disciplined, fair, and consistent implementation of workforce policies. 

What replaces MSPB and OSC review and whistleblower safeguards

Understand: Schedule P/C employees cannot appeal placement or removal through MSPB or file complaints with the OSC. Instead, the rule requires agencies to create and enforce internal protections against Prohibited Personnel Practices (PPPs), including whistleblower reprisal.

Ask (when agencies have made designations)

• What PPP/whistleblower safeguards have you established for Schedule P/C?
• Who reviews allegations of misuse?
• Are these procedures public to employees?
• If an employee is separated, will they have access to these procedures?
• Will job applicants have access to these procedures?
• How are complaints tracked and reported?
• Will the confidentiality of whistleblowers be protected?
• What training have managers received on PPP risks when using Schedule P/C authority?
• What role do IG and OSC play?
• Are Schedule P/C related PPP complaints being flagged as a category?

Watch

• Whether employees understand where and how to raise concerns
• Whether safeguards are formalized in written procedures
• Whether managers demonstrate understanding of PPP responsibilities
• Patterns in complaint data that may indicate either effective safeguards or lack of awareness
• How seriously agencies operationalize these safeguards in practice

Why it matters: Under the traditional civil service system, MSPB provided an independent judge,  formal record, public decisions, visible check on agency action. OSC safeguarded the merit system by protecting federal employees and applicants from prohibited personnel practices and provided a secure channel for federal employees to blow the whistle by disclosing wrongdoing. Under Schedule P/C, legitimacy depends on whether agencies build credible, transparent, and trusted internal safeguards. Visible safeguards are essential for preventing misuse of at-will authority; protecting whistleblowers and dissenters acting in good faith; maintaining workforce trust in policy offices; ensuring accountability does not become perceived politicization. Agencies need to have strong systems before problems arise.

Hiring and merit rules

Understand: Hiring for Schedule P/C roles must still follow merit procedures. New hires in Schedule P/C can gain competitive status in 2 years.

Ask (on a rolling basis)

• Are there any differences between traditional merit hiring and Schedule P/C hiring practices?
• As the rule is implemented, how many new hires have been made into these roles?
• Have any individuals previously serving in political roles been hired into Schedule P/C roles?

Watch

• Whether employees and managers clearly understand how competitive status is gained
• Public hiring announcements and transparency around these roles

Why it matters: Perceptions of politicization may arise here.

Workforce and mission impacts

Understand: These roles will sit in a wide range of functions across agencies. Early concerns about Schedule P/C highlighted risks to sensitive, scientific, technical, or high-demand roles where continuity and ability to “speak truth to power” are valued. 

Ask (on a rolling basis)

• Have you seen retention or recruitment impacts in Schedule P/C roles?
• Have employees moved to Schedule P/C declined roles or departed Federal service?
• What Schedule P/C roles are in the national security, scientific, or health fields, or fields engaged in long-term risk work?
• How are agencies addressing concerns that Schedule P/C would stifle dissent or evidence-based policymaking? 
• How many employees in Schedule PC roles have transferred or competed for  non-Schedule PC roles? How many have sought to?

Watch

• Hollowing out of key policy offices
• Reluctance of experienced staff to serve

Why it matters: Accountability gains should not come at the expense of mission capacity.

Does this address the performance problem it’s meant to solve?

Understand: OPM justifies the rule using MSPB and FEVS data showing managers struggle to remove poor performers; however, the rule does not introduce a more mature performance management standard. 

Ask (on a rolling basis, or through GAO review)

• What evidence do you have that those in “policy influencing” roles have performance issues, or that the impact of such performance issues is greater? 
• Have you used this authority to remove employees for performance issues? Why could they not be addressed under prior mechanisms?
• Are managers finding it easier to address poor performance? What about to incent strong performance?
• What indicators are you watching for improved overall performance?
• What standards are being applied for performance? Are they consistent within or across agencies?

Watch

• Rule exists on paper but behavior doesn’t change
• Different definitions for poor performance arise from adverse action, conduct and performance as defined in Chapters 43 and 75
• Performance problems persist for other reasons

Why it matters: Congress should know if the remedy matches the diagnosis.

Data Congress should request via GAO for ongoing tracking and comparison

Request from agencies:

• List of all positions designated
• Written justifications
• Counts by grade, office, and occupational series
• Number of removals using this authority
• Number of PPP/whistleblower complaints related to it
• Number of hires into Schedule P/C roles

Why it matters: Early transparency prevents speculation and enables evidence-based oversight.

In a previous post, we announced an initiative to connect scientists, engineers, technologists, and skilled federal workers and contractors who have recently departed government service with the emerging innovation ecosystems across America that could use their expertise. With the support of FAS, we are now excited to share the launch of the Innovation Ecosystem Job Board. This unique job board contains opportunities from across the nation with the explicit goal of matching in-demand science and technology talent with open positions across the nation’s innovation ecosystems, in roles ranging from lab researchers and data scientists to workforce development practitioners and science communicators.

These innovation ecosystems – namely Tech Hubs and NSF Engines – are advancing critical technologies spanning from advanced manufacturing to quantum computing to biotech, all vital for our national and economic security. To accomplish this work, they operate as multi-stakeholder coalitions that bring together universities, industry, nonprofits, and other partners, all searching for talent to help them fulfill their missions. 

These coalitions face growing talent needs, particularly for mission-driven roles that can help drive progress across critical technology areas. Meanwhile, we’re witnessing an exodus of thousands of experienced federal talent from agencies like the National Science Foundation, National Institutes for Health, and the Department of Energy whose knowledge gained from years of managing and working in multimillion-dollar technical programs could be lost entirely if not effectively redeployed.

This initiative directly addresses both challenges by collaborating with innovation ecosystems to identify their immediate talent needs while simultaneously engaging displaced federal workers through job fairs and targeted outreach to understand their backgrounds and geographic preferences. It’s a purposeful approach that ensures mission-driven federal talent can continue contributing to America’s technological leadership. By connecting talent to need, we help strategically imperative innovation ecosystems access the experienced professionals necessary for success. 

We will be updating this job board regularly with opportunities from additional Tech Hubs, NSF Engines, and other innovation ecosystems. While our outreach is specifically to former federal workers and contractors, this job board is open to all, and we encourage others on the job hunt to take a look.

As economic policy wonks, we understand that there are often frictions that hinder matching between individuals with the right skills and geographic preferences and the jobs that exist. We are taking this seriously and will engage in what we’re calling “light-touch matching”. Please feel free to fill out this interest form (whether you have applied to a listing on the job board or not), and we will flag profiles that generally align with relevant innovation ecosystems and their needs. 

Our process:

We spent the last several months talking to and learning from other talent connectors, innovation ecosystem builders, and the talent themselves. Through facilitated federal roundtables with former federal workers, we understood more deeply their diverse skill sets, their unwavering commitment to mission-driven work, and the unique challenges they face in their current job transition. Work for America’s research on federal workers also validated our hypotheses: these are experienced professionals (59% of survey respondents have a decade or more of experience), are geographically distributed (53% already live outside the DC-Virginia-Maryland area), and are mobile (54% are open to relocating). Job fairs additionally provided us an opportunity to meet individuals leaving the federal government and hear about their backgrounds and interests.

Simultaneously, we reached out to several innovation ecosystems to explore if they had immediate talent needs. Some ecosystems shared their most critical postings among their partners; others had recently conducted surveys of their coalitions to assess available positions and passed that information on to us; still others are actively developing comprehensive approaches to capture all the talent needs across their expansive coalitions. We reviewed and aggregated these opportunities into the job board which is now available and will be regularly updated. We are grateful for all these ecosystems that have engaged in this initiative and we look forward to continuing the conversation with more ecosystems and skilled former federal professionals alike.

Like anything new, this is an experiment. Does this effort in the end successfully match candidates and employers based on skills and geography? If you use this tool, please let us know how it goes!

Maryam Janani-Flores (mjananiflores@fas.org) is a Senior Fellow at FAS and former Chief of Staff at the U.S. Economic Development Administration. Meron Yohannes (myohannes@fas.org) is a Digital Services Alumni Fellow at FAS and most recently served as Senior Policy Advisor for the U.S. Secretary of Commerce.

New initiative brings nine experts with federal government experience to work with the FAS and Tech & Society’s Beeck Center for Social Impact + Innovation, the Knight-Georgetown Institute, and the Institute for Technology Law & Policy

Wednesday, June 11, 2025—Today Georgetown University’s Tech & Society Initiative and the Federation of American Scientists (FAS) announce two new fellowship programs. These fellowships will bring technologists, lawyers, and policymakers with recent federal government experience to Georgetown University centers, where they will advance nonpartisan research and analysis in their areas of expertise and engage with students. 

Federal Alumni Fellows will work with Georgetown University’s Beeck Center for Social Impact + Innovation, the Knight-Georgetown Institute, and the Georgetown Law Institute for Technology Law & Policy to advance competition policy and antitrust enforcement in the tech sector, modernize consumer protection and competition for American innovation, and support expanded internet access for underserved communities. 

Digital Service Alumni Fellows will be housed under the University’s Tech & Society Initiative and will collaborate with FAS senior fellows to develop and execute “big wins” that significantly impact the science and tech policy landscape. In addition to providing a place and community for senior leaders to carry forward their work, both FAS and Tech & Society are providing support for digital service experts exiting federal service and continuing to grow the skills of the next generation of leaders in tech and policy.

“The launch of the Federal Alumni and Digital Service Fellowship Programs is a critical step in leveraging the departure of leaders and innovators from the federal government who helped modernize tech policy and digital service delivery,” said incoming Tech & Society Chair and Beeck Center Executive Director Lynn Overmann. “The fellows will bring deep experience that aligns with Tech & Society’s mission to foster innovative and interdisciplinary approaches at the intersection of tech, ethics, and governance. The fellows will elevate our centers’ collaborative work and share their expertise with Georgetown students, benefiting both our academic community and the broader field of science, data, effective service delivery, and technology communications. I am thrilled to welcome them to Georgetown University.”

“At FAS, we believe that talented and well-placed policy entrepreneurs are one of the most critical keys to unlocking innovation and solving our society’s most pressing challenges,” said Dr. Jedidah Isler, Chief Science Officer at the Federation of American Scientists.  “It’s why we launched our Senior Fellows Program earlier this year, and why we wanted to collaborate with Georgetown to supercharge our collective impact. Together with our FAS Senior Fellows, the Digital Services Alumni Fellows will tackle ambitious projects – from clean energy modernization to preserving the most essential federal datasets – that drive positive change. In an uncertain time, we are taking a bold step to lead the way and champion the current and future science, technology and innovation policy leaders we will need for tomorrow.”

Federal Alumni Fellows 

Erie Meyer most recently served as chief technologist of the Consumer Financial Protection Bureau (CFPB). She was on the implementation team that launched the bureau and was a founding member of its Office of Technology and Innovation. Prior to that, she served as senior adviser for policy planning to former Federal Trade Commission (FTC) Chair Lina Khan, as well as FTC chief technologist and technology adviser to former FTC Commissioner Rohit Chopra. Before working at the FTC, Meyer launched the U.S. Digital Service (USDS) in the White House, served as senior director for Code for America, and was a senior adviser to the White House chief technology officer. She is a recipient of the Harvard Kennedy School’s Joan Shorenstein fellowship and received a bachelor’s degree in journalism from American University. Meyer will be placed at the Georgetown Law Institute for Technology Law & Policy.

Stephanie Nguyen most recently served as chief technologist of the FTC. She spearheaded and launched the agency’s first Office of Technology with senior technologist experts to strengthen and support enforcement matters. Prior to her tenure at the FTC, Nguyen worked at the USDS in the White House, where she built and deployed products and services to millions of people across the Department of Education, Department of State, Health and Human Services, and Centers for Medicare and Medicaid Services. She previously was a research scientist at the Massachusetts Institute of Technology’s Media Lab, a researcher at Consumer Reports, and a Gleitsman scholar at the Center for Public Leadership. She received a Master in Public Policy from the Harvard Kennedy School and a bachelor’s degree in Digital Media Theory and Design from the University of Virginia. Nguyen will be placed at the Georgetown Law Institute for Technology Law & Policy.

Reed Showalter most recently served as senior policy adviser on the National Economic Council. Showalter has broad expertise in competition law, previously serving at the Department of Justice as counsel for antitrust in the Office of Legislative Affairs and as an attorney adviser in the Antitrust Division. He has also worked as an antitrust attorney at the FTC, an associate at the Kanter Law Group, and as a member of the Digital Markets Investigation in the House of Representatives. He received a J.D. from Columbia Law School and a B.A. in International Politics from New York University. Showalter will be placed at the Knight-Georgetown Institute.

Stephanie Weiner most recently served as chief counsel of the National Telecommunications and Information Administration in the Department of Commerce. She has held senior positions in private industry, the Federal Communications Commission (FCC), and the Department of Energy. She previously served as senior legal adviser to former FCC Chairman Tom Wheeler, where she oversaw all FCC matters relating to broadband competition and deployment. She received her law degree, magna cum laude, from Northwestern University School of Law, her master’s degree in public policy from the University of Chicago, and her bachelor’s degree from Brown University. Weiner will be placed at the Georgetown Law Institute for Technology Law & Policy.

Digital Service Alumni Fellows

Thushan Amarasiriwardena is an Emmy award-winning product leader focused on artificial intelligence (AI) and public impact. He led Google’s earliest efforts to bring large language models into production to power the Google Assistant; this project grew into the foundations of Gemini. Most recently, he served in the White House’s USDS, driving AI products in federal agencies like the IRS, following the Biden-era AI executive order. Previously, he co-founded Launchpad Toys, a Y Combinator and venture backed startup acquired by Google. His apps were recognized by the New York Times and Apple as one of the top iPad Apps.  Amarasiriwardena began his career as a journalist at The Boston Globe.

Luke Farrell is a public interest technology and policy executive. He currently serves as a fellow at FAS and as executive director for strategic innovation at the College Board. Most recently, Farrell served as senior adviser for technology and delivery on the White House Domestic Policy Council, where he worked to improve the delivery of core safety net benefits and health care for millions of Americans. At the USDS, he built and led rapid-response technology teams that mitigated nationwide supply chain shocks, launched critical public websites, and ensured millions of Americans remained enrolled in Medicaid following the end of the COVID-19 public health emergency. Prior to government service, Farrell led crisis response and machine learning teams at Google.

Faith Savaiano is a public policy professional and consultant with expertise in technology, government innovation, and STEM (science, technology, engineering and mathematics) workforce development. Most recently, she served as a digital services expert with the USDS, where she provided policy guidance and contributed to the implementation of workforce and skilling objectives in President Biden’s executive order on AI. Additionally, she served as a subject-matter expert on federal regulatory policies and issues related to the federal workforce, public-private partnerships, and technology policy. Previously, Savaiano was the associate director of social innovation at the Federation of American Scientists, where she helped launch and lead a fellowship program that has now placed more than 100 technical experts into government. Prior to that time, she has worked at a variety of advocacy organizations focused on STEM workforce and education issues and the U.S. Department of State.

Diego Núñez most recently served in the Biden-Harris administration’s White House Climate Policy Office as a senior policy adviser. In that role, he led major initiatives across the power and transportation sectors, focusing on advanced transmission technologies, grid modernization, nuclear power, critical minerals, and solutions to manage increased demand from data centers and AI. Núñez began his tenure in the White House as an Associate Staff Secretary. Before that, Núñez served at the Department of the Treasury in the Office of Recovery Programs, at Stanford University’s Institute for Human-Centered Artificial Intelligence, and on multiple political campaigns. 

Meron Yohannes is a fellow at FAS focused on innovation, inclusivity, and technology related to economic and national security policy. Most recently, she served as the senior policy adviser for the U.S. Secretary of Commerce, formulating policy decisions related to economic development, minority businesses, workforce development, disaster recovery, and entrepreneurship. Her purpose was to guide policy development and program design for several agencies, a portfolio worth over $5 billion in funding that benefits underserved, distressed, and rural communities. Previously, she was the housing, infrastructure, and technology policy analyst at the Bipartisan Policy Center, a Washington, D.C.-based think tank researching and developing recommendations on affordable housing, water infrastructure, AI implications for the U.S. workforce, and evidence-based policymaking.

Participating Organizations: 

Beeck Center for Social Impact + Innovation at Georgetown University: 

The Beeck Center for Social Impact + Innovation at Georgetown University connects government and the civic tech ecosystem to tackle problems that no one can solve alone, to create a people-centered, digitally-enabled government for all. An anchor of Georgetown University’s Tech & Society Initiative, the Beeck Center works alongside public, private, and nonprofit organizations to identify and establish human-centered solutions that help government services work better for everyone—especially the most vulnerable and underserved populations.

Federal of American Scientists: 

The Federation of American Scientists (FAS) works to advance progress on a broad suite of contemporary issues where science, technology, and innovation policy can deliver transformative impact, and seeks to ensure that scientific and technical expertise have a seat at the policymaking table. Established in 1945 by scientists in response to the atomic bomb, FAS continues to bring scientific rigor and analysis to address contemporary challenges. 

Institute for Technology Law & Policy at the Georgetown University Law Center:

The Tech Institute is a hub for policymakers, academics, advocates, and technologists to study and discuss how to center humans and the social good, using technology as a tool. With the leading academic program for law and technology in the United States, the institute trains the next generation of lawyers and lawmakers with deep expertise in technology law and policy, provides nonpartisan insights to policymakers on issues related to new and emerging technologies, and fosters interdisciplinary approaches to solving complex technology law and policy problems. 

Knight-Georgetown Institute: 

The Knight-Georgetown Institute (KGI) is dedicated to connecting independent research with technology policy and design. KGI serves as a central hub for the growing network of scholarship that seeks to shape how technology is used to produce, disseminate, and access information. KGI is designed to provide practical resources that policymakers, journalists, and private and public sector leaders can use to tackle information and technology issues in real time. Georgetown University and the Knight Foundation came together to launch the institute in 2024.

Tech & Society Initiative: 

The Tech & Society Initiative creates novel approaches for interdisciplinary collaboration, research, and understanding at the intersection of technology, ethics, and governance at Georgetown University. We bring together ten centers and programs at Georgetown that are deeply immersed in particular parts of the technology and society equation: ethics, privacy, national security, law, policy, governance, and data—and we are building connective tissue between them. We identify the points of connection between them, and then create opportunities for them to collaborate in tangible and productive ways. 

Media Contact

Jessica Yabsley
Director of Communications
jessica.yabsley@georgetown.edu

On May 29, the Office of Personnel Management (OPM) published two memoranda that could substantially reshape federal hiring. The first–“Merit Hiring Plan”–issued with the White House Domestic Policy Council—implements Executive Order 14170.  The second provides guidance on “Hiring and Talent Development for the Senior Executive Service”. Spanning 53 pages, the documents are written in dense HR jargon that can overwhelm even seasoned practitioners. To clarify their meaning and impact, the Niskanen Center and the Federation of American Scientists have teamed up to translate both memos for journalists, researchers, and the general public.

The Memos Generally: Lots To Like, Dangerous Partisanship, & A Long Road Ahead

The memos, at their core, attempt to address well-documented and long-existing challenges: federal hiring is too sluggish, procedural, and opaque. Both of our organizations have long argued for the need to move faster, hire better, and hold poor performing employees accountable while still adhering to the merit system principles.  A high-performing, agile, and engaged federal workforce is essential if Americans are to trust if Americans are to trust that laws passed by Congress will be executed quickly, competently and efficiently. 

These memos are the latest in a long line of efforts by Presidents of both parties to bring common sense to federal hiring and performance – speed up the hiring process, focus on the skills to do the job, evaluate those skills objectively, and share resources across agencies to economize on effort and investment. These memos push that agenda further than earlier efforts, delivering several long‑sought wins such as streamlined applications and résumés more in line with private‑sector norms. 

They also venture further than any recent initiative in politicizing the civil service. Mandatory training and essay questions tied to the current Administration’s executive orders—and explicit political sign‑off on certain hiring actions—risk blurring the firewall between career professionals and partisan appointees. We have discussed the dangers associated with this type of partisan drift in other places, including in response to the recent OPM rulemaking on “Schedule Policy/Career”.

Implementing even the non-controversial portions will be daunting. Reforming the federal government–the largest employer in the country–requires sustained, years-long effort from OPM and OMB. 

The memos themselves are only the starting gun. Notably absent is a realistic plan to resource this work: for example, OPM has fired or lost nearly all of its enterprise data analytics team, limiting its ability to supply the metrics needed for oversight and accountability. Additionally, the inclusion of extremely ideological and partisan goals politicizes the entire agenda and risks overshadowing the rest of the positive reform agenda, threatening its ability to succeed anywhere. 

In evaluating these documents, we have to weigh each part of the Administration’s strategy separately and objectively – there is a lot to like in these documents, there are things that are deeply troubling, and there are things that desperately need leadership attention in implementation.

What We Like: Skills-Based Hiring, Resume Reform, Assessments, Sharing Across Agencies

The bulk of both memos represents a bold next step in long‑running federal hiring reforms—initiatives that agencies have piloted for years but often struggled to scale. We commend OPM for learning from past efforts and, in several critical areas, pushing further than any of its predecessors by:

• Recognizing the role of recruiting and sourcing talent – The plan highlights the importance of active recruiting in the hiring process.Agencies have long relied on USAJobs alone as a crutch, hoping the right kinds of talent will be scouring the job board every day and happen upon job postings – this works okay for some roles that are highly-specialized to government, but particularly as agencies have need for emerging talent it they cannot assume critical talent pools are even aware that the federal government wants to hire them.
• Focusing on skills and evaluating for those skills – The memo limits the use of self-assessments to minimum qualifications only and requires agencies to use some form of technical or alternative assessment for all postings, implementing 2024’s bipartisan Chance to Compete Act. This is a critical move forward from the reliance on applicant’s self-assessment,a status quo that disadvantages honesty and self-awareness.
• Implementing ‘Rule of Many’ ranking procedures – OPM will finalize its proposed ‘Rule of Many’ regulation from the last Administration, which empowers agencies to choose the various ways to “cut off” applicants after they are assessed. Finalizing ‘Rule of Many’ will enable agencies to set clear, objective criteria for which applicants it will consider based on test scores (e.g., considering the top 10% of scorers), a numerical approach (e.g., considering the top 50 applicants), and other mechanisms (e.g., clear pass/fail standards) that give hiring managers and HR specialists the flexibility they need to tailor hiring procedures to specific needs.
• Sharing resources and certifications of eligibles across agencies – This expands requirements for agencies to share candidates, position descriptions, and talent pools across agencies, including conducting pooled hiring actions where one candidate can apply once to many similar jobs across government. It builds on recent tremendous success agencies have with recruiting high-quality applicants across government through shared hiring actions, which enables agencies to surge talent in a specific field and advertise as one enterprise to potential applicants.
• Reducing size of referral resumes to two pages – OPM is finally attempting to move away from a “federal resume” format that needlessly burdens members of the public with overly-specific requirements. Previously, applicants that didn’t know to include things like the “average number of hours worked per week” or their complete salary history were unknowingly disqualifying themselves from federal employment and even those that knew better had to maintain two separate resumes, making it harder to jump between sectors.
• Simplifying Senior Executive applications – Applicants for Senior Executive Service roles will no longer be required to write multiple pages of essays describing their experience – a process so unique it has spawned a cottage industry of professional writers – and will be evaluated via resumes and structured interviews like their peers across the economy. This builds on a long history of successful pilots of new selection procedures focusing on resumes and structured interviews rather than the traditional essays.
• Removing unnecessary degree requirements – While efforts have been underway since the first Trump Administration to remove unnecessary degree requirements. The new memos solidify that trajectory, embracing a skills‑first hiring model that prizes demonstrated ability over paper credentials—a trend mirrored in state governments and the private sector. Yet dropping degree rules is only half the battle. To truly broaden the talent pool, agencies must replace résumé shortcuts (like “years of experience”) with rigorous, job‑relevant assessments that let candidates prove what they can actually do. 
• Focusing on speed and responsiveness – The memo doesn’t ignore the aspect of the applicant experience that differs most from the private sector: speed and responsiveness, setting a government-wide target of 80 days for hiring actions and requiring timely updates to applicants on their status. This builds on years of work to wrestle down timelines for security clearances and recognizes that one of the biggest reasons the federal government loses amazing applicants is the length of the process, not the pay.

Finally, the memos contain a compendium of useful resources in Appendices that agencies that can use to improve their approach to hiring.

Potential Red Flags: Politicization, Red Tape, & Extra, Unfunded Mandates

While OPM is advancing important nonpartisan reforms, we are concerned that several explicitly ideological provisions could erode the civil service’s neutrality and jeopardize the very hiring‑efficiency agenda OPM seeks to champion:

• Requiring essay questions on political views–Despite reducing applicant burden in other areas, OPM also introduces a requirement for all applicants for jobs above GS-05 (98%+ of jobs) to draft responses to free-response essay questions that describe their views on the present administration, including identifying which of the current president’s Executive Orders are “significant” to them. At best, this is an additional requirement that will be irrelevant for most jobs – there shouldn’t be any impact of EOs on a seasonal wildland firefighter’s strategy for fighting fires, for instance.  More realistically, this constitutes a partisan loyalty test for federal employees to evaluate their views on the current President. Federal employees swear their allegiance to the Constitution, not the current President and there are legitimate open questions about the constitutionality of many Executive Orders.
• Introducing extra layers of political approval in the hiring process–While the memo emphasizes time to hire, it also emphasizes that “agency leadership” must either personally approve or designate an official to approve all positions before they are posted and all selections prior to extension of an offer. It also requires that they do an “executive interview” with candidates and opens the door to obvious partisan abuse of the merit hiring process when paired with the free response essay questions. Even without that risk, however, this requirement adds tremendous amounts of friction into a process that is already too full of approvals and pulls the decision-making authority in the wrong direction: to leadership instead of to the line management that knows the needs of a given program best. We are already seeing the problems with this approach play out with a similar requirement for agency leadership to personally approve payments or contracts, leading to extreme slowdowns. Additionally, just as with OPM’s recent rulemaking on Schedule Policy/Career, the opportunity for abuse is extremely obvious: highly partisan agency leaders may see it as their right to disapprove of candidates for purely political reasons–like, for example, donations to opposing candidates.
• Prioritizes political training for the SES corps–While the Administration has closed down training programs like the Federal Executive Institute that were designed to train new generations of federal leaders, it is also adding ideological training to the SES that lacks a clear purpose or evidence that it will improve governing outcomes. Requiring Senior Executives to watch an “80-hour video-based program that provides training regarding President Trump’s Executive Orders” is both offensive to the principle of a nonpartisan civil service and a waste of time for the busiest, most senior leaders across the entire enterprise. While America’s most productive tech companies are trying to reduce the meeting load to free staff to get things done, torching 4% of our senior executives’ working years for ideological training is the opposite of efficient. 
• No mention of resources to carry out these changes – As with past legislation, EOs, and memos requiring skills-based talent practices, no apparent financial or other resources come with these memos. This has hampered adoption for more than a decade. The Talent Teams at OPM and the agencies, the communications and education support, the changes to OPM and agency systems all need people, money, and IT support. The lack of committed resources will delay, and perhaps scuttle, implementation. We know this because it has happened before. In the Clinton Administration, for example, a major push to de-proceduralize federal hiring fell down because they underresourced agency HR offices to stick the landing. This will happen again on skills-based hiring without commensurate investment, a problem discussed at length in a recent paper from the Niskanen Center.

What’s Missing: A Scalable Implementation Strategy

Executing these reforms will be no small feat, and the toughest tasks are also the most crucial: getting good technical assessments in the hands of managers, conducting strategic workforce planning, changing the culture around hiring to empower managers and not HR, and letting line managers be managers. OPM’s memos are light on details about how they intend to resource and manage implementation, an omission that they have plenty of time to correct but one that needs some serious consideration if they are going to be successful:

• Changing entrenched oversight, HR, and hiring manager policies, practices, and culture – OPM and the agencies will need to focus on how to move decades-learned compliance and risk aversion behaviors embedded in the current hiring and performance management practices into a skills-based future. The change management and consistent leadership required here is a substantial undertaking. Because OPM has conditioned the federal HR profession to be incredibly risk-averse, it won’t immediately embrace these new mandates without coaching, training, and professional development. To facilitate this, OPM should re-submit its uncontroversial legislative proposal from last year to help professionalize and develop the federal HR workforce, and Congress should expeditiously pass it.
• Hiring is just one piece of the effective federal employee puzzle – Though the SES Memo addresses some aspects of performance management, the focus on hiring diminishes other parts of the management system that impact effectiveness and performance. Onboarding, the early job experience, consistent feedback, professional development, challenging assignments, and career paths all help to ensure employees are helping meet agency missions. Implementation needs to take the whole system into account if OPM and the agencies are going to impact effectiveness and accountability.
• An all-of-the-above approach for getting assessments into the hands of agencies – The memo focuses on USAHire but, as we’ve discussed, there are many third-party assessment vendors that offer validated assessments and tools to help lower the unit and marginal cost of using objective assessments. Emerging companies offer things like AI-proctored video interviews that could quickly surface the most promising candidates and are already in use by the private sector for high-volume roles. At the federal level, parts of the Department of Homeland Security and other agencies have already experimented with some of these platforms. We want to see OPM think bigger about how to quickly bring assessments online and recognize that the private sector can play a role in accelerating this transformation.
• Focus on the candidate experience – Job candidates – users of the federal hiring system – complain that the experience of applying for a federal job is neither easy nor seamless, as it can be in the private sector. While the memos make some progress in reducing the burden on candidates (e.g., reducing resume and SES application requirements), the system is still rife with bureaucratic bloat. High-performing candidates have many options; they will go elsewhere if we do not reduce the friction. 
• Public accountability & data – According to the hiring plan memo, agencies need to develop a data-driven plan for implementation and report frequently to OPM and OMB on their progress. With the practical dissolution of OPM’s human capital data team and a years-long problem with lagging human capital data releases via Fedscope, OPM should commit to releasing data publicly on their progress: how many people are hired, where they are hired, how many apply, how many pass technical assessments, etc. that will hold agencies accountable for getting this work done, give Congress the insight it needs to trust OPM, and provide the public with a window into progress.
• A plan to staff for success – In the best of times, OPM struggles with capacity for human capital policy work, and it will need every federal human capital expert it can get to pull off implementation of these memos. However, at the same time, OMB’s FY2026 budget proposal outlines a significant reduction in total headcount for OPM that locks in a 25%+ reduction in headcount across all parts of the agency, from policy to direct support for agencies. Given the technical complexity involved in many of these efforts–delivering validated assessments, for example, will likely require bringing in new expertise from outside government–OPM will need a plan to staff itself for success that is missing in these memos today.

In urgent circumstances, agencies have experimented with some of these practices and policies (e.g., cybersecurity hiring and intelligence community hiring, infrastructure and energy development). However, action on skills-based talent practices is far from pervasive. Together with outside experts, we continue to map the obstacles that keep skills‑first hiring from taking root: limited resources, hesitant leadership, and a pervasive fear of downside risk. Many of the opportunities and chokepoints highlighted in the memos came from this work, and we will keep collaborating with all stakeholders to craft practical fixes.

Most of the reforms in these memoranda set federal hiring on a promising trajectory, but their impact will hinge on disciplined execution. Some of them are deeply troubling attacks on the basis of the merit system. We will track OPM’s progress closely—amplifying best practices and calling out any drift from merit‑based, nonpartisan norms.  These challenges are not new, yet  they have become increasingly existential to building a government that works; OPM must keep that urgency front and center as implementation moves forward.

Our government depends on objective, evidence-based, information to make the best policy. From national defense to our everyday quality of life, Americans depend on highly specialized  government professionals doing research, gathering data, analyzing results, and delivering services. We depend on people doing this work, making the best decisions they can, without fear or favor. That objectivity is key to their work.

Right now there’s a threat to government professionals’ ability to do their jobs: The Proposed Rule on Improving Performance, Accountability and Responsiveness in the Civil Service, also known as Schedule Policy/Career. If adopted, this rule will change the employment relationship for a significant number of federal employees, depending on the agencies’ reclassification determinations. It changes them to “at will” employees, stripping them of civil service protections if they are in positions that affect policy. 

On the surface, changing a federal employee’s status seems like simply an administrative change. But, the reason Americans want federal employees with career longevity isn’t just for all their accumulated knowledge and expertise; it is to insulate our system from the shocks and cold-starts that come with constant turnover. When we introduce “at-will” employment to government employees, we also introduce the potential for environments where people are more concerned about self-preservation than service to others.

What makes this problematic, and even potentially dangerous, is that the Proposed Rule has few guidelines for agencies to determine what positions “influence policy” and therefore go into this new schedule. “Schedule Policy/Career” (“Schedule PC”) rescinds civil servant employment protections, placing unnecessary and undesirable political pressure on highly specialized scientific and technical career professionals serving in government. Assigning federal employees to this status could foster an environment of fear when reporting data that is viewed as politically incorrect or inconvenient. For these reasons FAS believes this could have an outsized, negative impact on scientific and technical research in particular. Read our full policy statement here; we encourage citizens to submit public comment here through May 23rd, when the window for comment closes.

How might a change like this proposed rule make it difficult to keep, or even do, one’s job? How might this be damaging not to just one person, but to our government’s capacity to pursue necessary scientific and technical research? 

Picture yourself an industrial hygienist, a person tasked with evaluating workplace safety, at a nuclear power research facility. You are a federal employee newly placed in the Policy/Career Schedule because it has been determined that your job affects policy. Through your work testing the safety of new nuclear generator technologies, you uncover serious vulnerabilities that would require safety equipment and protocols. If you make the recommendation to implement safety changes, you know that this will likely delay power deployment and increase costs. However, you are working in an administration that has policies, written and unwritten, to accelerate nuclear technology development, even if it includes taking greater risks in deployment. What would you choose to do? If you were working as a Schedule P/C there might be immense pressure to drop safety recommendations to speed power delivery. You are now in a position to either bring this information forward and potentially risk your job or hold back or downplay this information and keep your job.

Consider a few more examples of how this shift in classification could permanently alter the way in which federal employees are incentivized. Do you want them looking out only for themselves, or for the larger mission and for the health and wellbeing of the nation? Do you want them to have the freedom to present challenging data, or would you prefer they meekly do whatever serves the immediate needs of their individual situation even if it causes long term or widespread harm?

How do you want the marine biologist to handle this? How about a cybersecurity professional protecting the nation from cyberattacks? How about the statisticians reporting on the health of our economy? How about the pharmacologist testing the safety of your medicines? How about the administrative law judge deciding on Social Security benefits? Each of these federal employees are gathering information and making decisions that affect us. We depend on their objectivity and their forthright, evidence-based delivery of what they find.

If you want better, more effective, more efficient government write a comment to oppose this Proposed Rule before comments close June 7th.