On the left is the Bankside Power Station in 1953. That vast relic of the fossil era once towered over London, oily smoke pouring from its towering chimney. These days, Bankside looks like the right:

Bankside Power Station in 1953 via A London Inheritance; Bankside today via the Telegraph.

The old power plant’s vast turbine hall is now at the heart of the airy Tate Modern Art Museum; sculptures rest where the boilers once churned.

Bankside’s evolution into the Tate illustrates that transformations, both literal and figurative, are possible for our energy and economic systems. Some degree of demolition – if paired with a plan – can open up space for something innovative and durable.

Today, the entire energy sector is undergoing a massive transformation. After years of flat energy demand served by aging fossil power plants, solar energy and battery storage are increasingly dominating energy additions to meet rising load. Global investment in clean energy will be twice as big as investment in fossil fuels this year. But in the United States, the energy sector is also undergoing substantial regulatory demolition, courtesy of a wave of executive and Congressional attacks and sweeping potential cuts to tax credits for clean energy. 

What’s missing is a compelling plan for the future. The plan certainly shouldn’t be to cede leadership on modern energy technologies to China, as President Trump seems to be suggesting; that approach is geopolitically unwise and, frankly, economically idiotic. But neither should the plan be to just re-erect the systems that are being torn down. Those systems, in many ways, weren’t working. We need a new plan – a new paradigm – for the next era of climate and clean energy progress in the United States.

Asking Good Questions About Climate Policy Designs

How do we turn demolition into a superior remodel? First, we have to agree on what we’re trying to build. Let’s start with what should be three unobjectionable principles.

Principle 1. Climate change is a problem worth fixing – fast. Climate change is staggeringly expensive. Climate change also wrecks entire cities, takes lives, and generally makes people more miserable. Climate change, in short, is a problem we must fix. Ignoring and defunding climate science is not going to make it go away.

Principle 2. What we do should work. Tackling the climate crisis isn’t just about cleaning up smokestacks or sewer outflows; it’s about shifting a national economic system and physical infrastructure that has been rooted in fossil fuels for more than a century. Our responses must reflect this reality. To the extent possible, we will be much better served by developing fit-for-purpose solutions rather than just press-ganging old institutions, statutes, and technologies into climate service. 

Principle 3. What we do should last. The half-life of many climate strategies in the United States has been woefully short. The Clean Power Plan, much touted by President Obama, never went into force. The Trump administration has now turned off California’s clean vehicle programs multiple times. Much of this hyperpolarized back-and-forth is driven by a combination of far-right opposition to regulation as a matter of principle and the fossil fuel industry pushing mass de-regulation for self-enrichment – a frustrating reality, but one that can only be altered by new strategies that are potent enough to displace vocal political constituencies and entrenched legacy corporate interests.

With these principles in mind, the path forward becomes clearer. We can agree that ambitious climate policy is necessary; protecting Americans from climate threats and destabilization (Principle 1) directly aligns with the founding Constitutional objectives of ensuring domestic tranquility, providing for the common defense, and promoting general welfare. We can also agree that the problem in front of us is figuring out which tools we need, not how to retain the tools we had, regardless of their demonstrated efficacy (Principle 2). And we can recognize that achieving progress in the long run requires solutions that are both politically and economically durable (Principle 3).

Below, we consider how these principles might guide our responses to this summer’s crop of regulatory reversals and proposed shifts in federal investment.

Honing Regulatory Approaches

The Trump Administration recently announced that it plans to dismantle the “endangerment finding” – the legal predicate for the Environmental Protection Agency (EPA) to regulate greenhouse gas emissions from power plants and transportation; meanwhile, the Senate revoked permission for California to enforce key car and truck emission standards. It has also proposed to roll back key power plant toxic and greenhouse gas standards. We agree with those who think that these actions are scientifically baseless and likely illegal, and therefore support efforts to counter them. But we should also reckon honestly with how the regulatory tools we are defending have played out so far.

Federal and state pollution rules have indisputably been a giant public-health victory. EPA standards under the Clean Air Act led directly to dramatic reductions in harmful particulate matter and other air pollutants, saving hundreds of thousands of lives and avoiding millions of cases of asthma and other respiratory diseases. Federal regulations similarly caused mercury pollution from coal-fired power plants to drop by 90% in just over a decade. Pending federal rollbacks of mercury rules thus warrant vocal opposition. In the transportation sector, tailpipe emissions standards for traditional combustion vehicles have been impressively effective. These and other rules have indeed delivered some climate benefits by forcing the fossil fuel industry to face pollution clean-up costs and driving development of clean technologies.

But if our primary goal is motivating a broad energy transition (i.e., what needs to happen per Principle 1), then we should think beyond pollution rules as our only tools – and allocate resources beyond immediate defensive fights. Why? The first reason is that, as we have previously written, these rules are poorly equipped to drive that transition. Federal and state environmental agencies can do many things well, but running national economic strategy and industrial policy primarily through pollution statutes is hardly the obvious choice (Principle 2). 

Consider the power sector. The most promising path to decarbonize the grid is actually speeding up replacement of old coal and gas plants with renewables by easing unduly complex interconnection processes that would speed adding clean energy to address rising demand, and allow the old plants to retire and be replaced – not bolting pollution-control devices on ancient smokestacks. That’s an economic and grid policy puzzle, not a pollution regulatory challenge, at heart. Most new power plants are renewable- or battery-powered anyway. Some new gas plants might be built in response to growing demand, but the gas turbine pipeline is backed up, limiting the scope of new fossil power, and cheaper clean power is coming online much more quickly wherever grid regulators have their act together. Certainly regulations could help accelerate this shift, but the evidence suggests that they may be complementary, not primary, tools.

The upshot is that economics and subnational policies, not federal greenhouse gas regulation, have largely driven power plant decarbonization to date and therefore warrant our central focus. Indeed, states that have made adding renewable infrastructure easy, like Texas, have often been ahead of states, like California, where regulatory targets are stronger but infrastructure is harder to build. (It’s also worth noting that these same economics mean that the Trump Administration’s efforts to revert back to a wholly fossil fuel economy by repealing federal pollution standards will largely fail – again, wrong tool to substantially change energy trajectories.)

The second reason is that applying pollution rules to climate challenges has hardly been a lasting strategy (Principle 3). Despite nearly two decades of trying, no regulations for carbon emissions from existing power plants have ever been implemented. It turns out to be very hard, especially with the rise of conservative judiciaries, to write legal regulations for power plants under the Clean Air Act that both stand up in Court and actually yield substantial emissions reductions. 

In transportation, pioneering electric vehicle (EV) standards from California – helped along by top-down economic leverage applied by the Obama administration – did indeed begin a significant shift and start winning market share for new electric car and truck companies; under the Biden administration, California doubled down with a new set of standards intended to ultimately phase out all sales of gas-powered cars while the EPA issued tailpipe emissions standards that put the industry on course to achieve at least 50% EV sales by 2030. But California’s EV standards have now been rolled back by the Trump administration and a GOP-controlled Congress multiple times; the same is true for the EPA rules. Lest we think that the Republican party is the sole obstacle to a climate-focused regulatory regime that lasts in the auto sector, it is worth noting that Democratic states led the way on rollbacks. Maryland, Massachusetts, Oregon, and Vermont all paused, delayed, or otherwise fuzzed up their plans to deploy some of their EV rules before Congress acted against California. The upshot is that environmental standards, on their own, cannot politically sustain an economic transition at this scale without significant complementary policies.

Now, we certainly shouldn’t abandon pollution rules – they deliver massive health and environmental benefits, while forcing the market to more accurately account for the costs of polluting technologies, But environmental statutes built primarily to reduce smokestack and tailpipe emissions remain important but are simply not designed to be the primary driver of wholesale economic and industrial change. Unsurprisingly, efforts to make them do that anyway have not gone particularly well – so much so that, today, greenhouse gas pollution standards for most economic sectors either do not exist, or have run into implementation barriers. These observations should guide us to double down on the policies that improve the economics of clean energy and clean technology — from financial incentives to reforms that make it easier to build — while developing new regulatory frameworks that avoid the pitfalls of the existing Clean Air Act playbook. For example, we might learn from state regulations like clean electricity standards that have driven deployment and largely withstood political swings.

To mildly belabor the point – pollution standards form part of the scaffolding needed to make climate progress, but they don’t look like the load-bearing center of it.

Refocusing Industrial Policy

Our plan for the future demands fresh thinking on industrial policy as well as regulatory design. Years ago, Nobel laureate Dr. Elinor Ostrom pointed out that economic systems shift not as a result of centralized fiat, from the White House or elsewhere, but from a “polycentric” set of decisions rippling out from every level of government and firm. That proposition has been amply borne out in the clean energy space by waves of technology innovation, often anchored by state and local procurement, regional technology clusters, and pioneering financial institutions like green banks.

The Biden Administration responded to these emerging understandings with the  CHIPS and Science Act, Bipartisan Infrastructure Law (BIL), and Inflation Reduction Act (IRA) – a package of legislation intended to shore up U.S. leadership in clean technology through investments that cut across sectors and geographies. These bills included many provisions and programs with top-down designs, but the package as a whole but did engage with, and encourage, polycentric and deep change.

Here again, taking a serious look at how this package played out can help us understand what industrial policies are most likely to work (Principle 2) and to last (Principle 3) moving forward.

We might begin by asking which domestic clean-technology industries need long-term support and which do not in light of (i) the multi-layered and polycentric structure of our economy, and (ii) the state of play in individual economic sectors and firms at the subnational level. IRA revisions that appropriately phase down support for mature technologies in a given sector or region where deployment is sufficient to cut emissions at an adequate pace could be worth exploring in this light – but only if market-distorting supports for fossil-fuel incumbents are also removed. We appreciate thoughtful reform proposals that have been put forward by those on the left and right.

More directly: If the United States wants to phase down, say, clean power tax credits, such changes should properly be phased with removals of support for fossil power plants and interconnection barriers, shifting the entire energy market towards a fair competition to meet increasing load, as well as new durable regulatory structures that ensure a transition to a low-carbon economy at a sufficient pace. Subsidies and other incentives could appropriately be retained for technologies (e.g., advanced battery storage and nuclear) that are still in relatively early stages and/or for which there is a particularly compelling argument for strengthening U.S. leadership. One could similarly imagine a gradual shift away from EV tax credits – if other transportation system spending was also reallocated to properly balance support among highways, EV charging stations, transit, and other types of transportation infrastructure. In short, economic tools have tremendous power to drive climate progress, but must be paired with the systemic reforms needed to ensure that clean energy technologies have a fair pathway to achieving long-term economic durability.

Our analysis can also touch on geopolitical strategy. It is true that U.S. competitors are ahead in many clean technology fields; it is simultaneously true that the United States has a massive industrial and research base that can pivot ably with support. A pure on-shoring approach is likely to be unwise – and we have just seen courts enjoin the administration’s fiat tariff policy that sought that result. That’s a good opportunity to have a more thoughtful conversation (in which many are already engaging) on areas where tariffs, public subsidies, and other on-shoring planning can actually position our nation for long-term economic competition on clean technology. Opportunities that rise to the top include advanced manufacturing, such as for batteries, and critical industries, like the auto sector. There is also a surprising but potent national security imperative to center clean energy infrastructure in U.S. industrial policy, given the growing threat of foreign cyberattacks that are exploiting “seams” in fragile legacy energy systems.

Finally, our analysis suggests that states, which are primarily responsible for economic policy in their jurisdictions, have a role to play in this polycentric strategy that extends beyond simply replicating repealed federal regulations. States have a real opportunity in this moment to wed regulatory initiatives with creative whole-of-the-economy approaches that can actually deliver change and clean economic diversification, positioning them well to outlast this period of churn and prosper in a global clean energy transition.

A successful and “sticky” modern industrial policy must weave together all of the above considerations – it must be intentionally engineered to achieve economic and political durability through polycentric change, rather than relying solely or predominantly on large public subsidies. 

Conclusion

The Trump Administration has moved with alarming speed to demolish programs, regulations, and institutions that were intended to make our communities and planet more liveable. Such wholesale demolition is unwarranted, unwise, and should not proceed unchecked. At the same time, it is, as ever, crucial to plan for the future. There is broad agreement that achieving an effective, equitable, and ethical energy transition requires us to do something different. Yet there are few transpartisan efforts to boldly reimagine regulatory and economic paradigms. Of course, we are not naive: political gridlock, entrenched special interests, and institutional inertia are formidable obstacles to overcome. But there is still room, and need, to try – and effort bears better fruit when aimed at the right problems. We can begin by seriously debating which past approaches work, which need to be improved, which ultimately need imaginative recasting to succeed in our ever-more complex world. Answers may be unexpected. After all, who would have thought that the ultimate best future of the vast oil-fired power station south of the Thames with which we began this essay would, a few decades later, be a serene and silent hall full of light and reflection?

On May 28, we hosted 40 leaders from across government, civic tech, and advocacy at the Federation of American Scientists’ office in D.C. to reflect and chart the future of public interest tax filing. The backdrop was a wildly successful product beloved by users, which the AP reported DOGE and the Trump administration intend on sunsetting, while the public is calling for easy, free tax filing. This meeting was a coalition of experts unwilling to let this momentum go to waste.

Participants, ranging from former IRS staff and state tax teams to advocates, engineers, and policy veterans, brainstormed how to carry forward the most valuable parts of Direct File. What surfaced was clear: the tool was just the start. The ideas, tech, and values behind it can, and should, be applied far beyond a single product.

The good news: since this convening the IRS released Direct File software and made it open source. 

Key findings

• Build the playbook. Show others, especially states, how Direct File was built, shipped, and maintained at high quality. Own the story, share the code, and make it replicable.
• Scale smart customer support. Direct File redefined what IRS service could look like, with real-time help and data-driven improvements. Let’s apply that bar elsewhere.
• Modernize the bureaucracy. From reforming the Paper Work Reduction Act to common-sense data sharing, participants named concrete ways to untangle red tape and better serve people.
• Unlock better benefits access. Direct File proved tax filing can be an on-ramp to other public benefits. Now let’s make that vision real—with smarter data use and simplified experiences.
• Support the states. Multiple attendees are already collaborating to help states stand up free filing tools or expand access to benefits using the Direct File codebase.

The outcome was shared clarity that the work continues. Direct File wasn’t just a product. It was a proof point that the government can deliver simple, elegant services that work. And the people who made that possible are already thinking about what comes next. The following outlines some of the key ideas, opportunities, and takeaways from the day – note, these are not comprehensive, nor are they commitments set in stone.

Specific Opportunities for Leadership

Theme	Idea / Opportunity	Description / Next Step
Narrative + Legacy for change	Direct File Playbook & Roadshow	Document how Direct File was built and share lessons with agencies and states via a “roadshow” and comms package.
	Build the Narrative	Proactively tell the story of Direct File’s success, especially user satisfaction and cost-effectiveness, to combat misinformation.
Service Delivery	Modernized Customer Support	Promote Direct File’s Live Chat model as a new gold standard for federal digital customer service.
Ecosystem Gaps	DOGE Recovery	What will it take to rebuild capacity and trust after the dismantling of Direct File and cuts to digital services?
	Benefits Integration	Use tax data to help connect people to benefits automatically or semi-automatically.
	Data Flows	Identify and improve key data-sharing bottlenecks
	Industry / Lobby Strategy	How can we anticipate and plan for the work needed for Direct File to survive private interests? How can we build interesting alliances?
	Funding the Progress	Identifying and connecting the disparate parts of this movement who want to fund this work, and who need funding to continue this work.
State + Local Momentum	State Direct File Support	Help states build or extend their own free filing tools (building on NJ/Code for America model).
	State-Federal Integration	Continue building tools that help people file state taxes after using federal Direct File.
Product + Engineering	Open Source Use + Growth	Encourage use of Direct File’s now-public codebase for other benefits or gov services.
	Componentization	Explore how to break various parts of the product into reusable components (e.g., logic, eligibility, assertion model) with documentation that can be used by other agencies.
Institutional + Regulatory	PRA Reform	Tackle burdensome Paperwork Reduction Act process bottlenecks and rules that can hinder fast, responsive service design.
	6103 Modernization	Revisit dated interpretations of tax confidentiality law to allow limited, secure data sharing.
	User Research Mandate	Push for usability testing to be required for all government digital services.
	Language Access	Start work now on high-impact translations beyond Spanish.
	Identity + Access Innovation	Prototype more flexible identity requirements for low-risk returns or refunds.
Movement + Equity	IRS Democratization	Create formal channels for taxpayer voices, especially low-income and underserved, in IRS design and policy.
	Credit Uptake Strategy	Use tax data and eligibility engines to help people get all the credits they qualify for.
	Cross-Gov Benefits Alignment	Align eligibility logic and interfaces across IRS, SSA, CMS, etc., using Direct File-style tech.

Key Resources

IRS Direct File Filing Season 2025 Report
Obtained by Center for Taxpayer Rights through a FOIA request, this report highlights the incredible results of Direct File in the 2025 filing season.

Direct File Source Code on GitHub: The source code for Direct File, currently being actively maintained by the IRS. As a work of the United States Government, this project is in the public domain within the United States of America.

Thank you

I want to thank all the participants who contributed to this important conversation. The event followed the Chatham House framework to create a free and open dialogue; the following organizations agreed to be named:

• American Economic Liberties Project
• Economic Security Project
• Groundwork Collaborative
• New Practice Lab
• Vanderbilt Policy Accelerator

Thank you to our incredible facilitators, former Direct File teammates Allison Abbott, Sam Powers, and Andrea Schneider; and civic tech leader and friend of Direct File, Erie Meyer.

And thank you to the Federation of American Scientists for hosting.

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.

For more than twenty years, the Department of Education’s Institute of Education Sciences (IES) has served as a guiding light for U.S. education research. Its work has pushed the field forward, supporting high-quality, rigorous research in a field known for its reliance on word-of-mouth over science. The studies it funded have answered critical questions about “what works” in key areas like improving reading achievement and increasing associate’s degree attainment. It has served as a centralized, objective repository of data and research to inform educator practice, school district procurement, and state legislation. Even with these achievements, IES has room to grow to ensure that cutting edge research makes it into the hands of those who need it, when they need it.

As part of IES’s ongoing leadership, it has been moving to adopt an approach called “living evidence.” Use of this emerging approach would keep decision-makers up-to-date about the solutions that have been rigorously tested and hold potential to address core challenges facing American schools: How do we respond to astonishingly low scores on NAEP tests? Are there evidence-based approaches we can employ in schools that will help end the national “epidemic” of social isolation? How do we ensure that both our college graduates and those who do not wish to attend college can obtain high-paying jobs?

Harnessing Innovation

This week, FAS and its partners at the Future Evidence Foundation (FEF) released a new report: Harnessing Innovation: Options for Implementing Living Evidence at the Institute of Education Sciences (which you can download using the button on the left-hand side of this page). It describes in great depth how IES could build on existing processes to produce living reviews as part of their What Works Clearinghouse. 

Over time, many have come to believe that the agency moves too slowly to be responsive to practitioner needs, that its approach to sharing research findings does not make clear enough for users whether an intervention is backed by strong evidence, and that it needs to better support innovation. Living evidence is not the silver bullet that can address all of these issues in full. And yet, its proposed adoption could be the foundation for a sea change, allowing IES to more responsively share when new best practices and innovative approaches are identified in the academic literature through the What Works Clearinghouse. However, recent seismic shifts have severely damaged IES’s capability to move forward with using this innovative model: the Trump Administration’s cancellation of nearly all active contracts, including those that made the What Works Clearinghouse’s work possible, and a reduction-in-force (RIF) that led to the firing of nearly all of IES’s staff. 

Report Insights and Key Takeaways

The report was produced as the product of a year-long partnership, where FAS and FEF were granted the opportunity to engage deeply with leadership and staff from IES. Our team learned about their day-to-day processes and potential roadblocks on the path to change. The final ‘options memo’ was carefully constructed to give the IES team a set of realistic approaches they could take to addressing some of their greatest challenges: discerning the topics where knowing ‘what works’ could be most beneficial to the more than 100 million people that the U.S. education system touches, finding the highest-quality academic research from the thousands of studies produced each year on education, and doing this work within a limited set of resources (IES funding made up less than 1% of the Department of Education’s overall spending in 2024). These recommendations were informed by conversations with many of those that knew IES’s work best, from its contractors to the readers of the What Works Clearinghouse’s reports. They offer feasible ways for IES to craft more efficient processes for developing their resources.

From this process, our team had two key takeaways: 

1. While the What Works Clearinghouse faces challenges in achieving its goal to make rigorous research accessible to policymakers and practitioners, the staff and contractors that led its work were steadfast in their dedication to improving its resources. 
2. Living evidence is not just the way of the future in academic circles beyond the U.S., but is a model that is feasible to implement in large federal agencies.

However, canceling contracts and firing experienced, dedicated staff has kneecapped IES’s ability to make the changes necessary to begin creating and deploying living reviews. An opportunity may now be missed to better align IES’s work not just to what their constituents need, but also to how a global community is moving forward in thinking about how to better connect evidence to policy and practice. While the administration has signaled its intent to rebuild IES in the future, it will take time to enact a new vision, and to fix what will inevitably break in the absence of staff to support key resources including the Regional Education Laboratories, the Education Resources Information Center (ERIC), and the What Works Clearinghouse. In that time, peer government R&D agencies such as UK Research and Innovation and major philanthropic organizations such as the Wellcome Trust will step up to lead the way on developing infrastructure that supports the use of emerging technology to build living reviews, moving the rest of the world forward while U.S. government agencies remain in the past.

Living Evidence Global Community of Practice

Living evidence still has a path forward in the U.S, and opportunities to continue to grow along with the growing global movement. Innovation outside of government for living evidence holds promise for U.S. education stakeholders, led by work through the HEDCO Institute at the University of Oregon and the clearinghouse Blueprints for Healthy Youth Development. The recommendations in the report will offer value for such organizations as they work to shift toward living systematic reviews, setting the tone for best practice in evidence synthesis while IES is in transition. FAS and FEF will continue to help support this work through our convening of a Living Evidence Community of Practice.

Further, it is our hope that the learnings shared in the report will be considered in re-imagining future iterations of IES. In its short 23 years of existence, IES has raised the rigor of evidence that influences education and made strides in both generating and summarizing evidence that has the potential to inform practice. Even if the administration moves forward in its stated aim of “returning education back to the states”, state and local leaders will still need IES’s resources to understand how best to disburse their budgets. Employing a living approach to evidence synthesis, disseminated at a national level, is a streamlined way to enable evidence-based decision-making nationwide. If the administration genuinely prioritizes government efficiency, the report’s recommendations warrant serious consideration.

The Clean Air Act. The Clean Water Act. The National Environmental Policy Act. These and most of our nation’s other foundational environmental laws were passed decades ago – and they have started to show their age. The Clean Air Act, for instance, was written to cut air pollution, not to drive the whole-of-economy response that the climate crisis now warrants. The Energy Policy and Conservation Act of 1975 was designed to make cars more efficient in a pre-electric vehicle era, and now puts the Department of Transportation in the awkward position of setting fuel economy standards in an era when more and more cars don’t burn gas.

Trying to manage today’s problems with yesterday’s laws results in government by kludge. Legacy regulatory architecture has foundered under a patchwork of legislative amendments and administrative procedures designed to bridge the gap between past needs and present realities. Meanwhile, Congressional dysfunction has made purpose-built updates exceptionally difficult to land. The Inflation Reduction Act, for example, was mostly designed to move money rather than rethink foundational statutes or regulatory processes – because those rethinks couldn’t make it past the filibuster.

As the efficacy of environmental laws has waned, so has their durability. What was once a broadly shared goal – protecting Americans from environmental harm – is now a political football, with rules that whipsaw back and forth depending on who’s in charge. 

The second Trump Administration launched the biggest environmental deregulatory campaign in history against this backdrop. But that campaign, coupled with massive reductions in the federal civil service and a suite of landmark court decisions (including Loper Bright) about how federal agencies regulate, risks pushing U.S. regulatory architecture past the point of sensible and much-needed reform and into a state of complete disrepair.

Dismantling old systems has proven surprisingly easy. Building what comes next will be harder. And the work must begin now. 

It is time to articulate a long-term vision for a government that can actually deliver in an ever-more complex society. The Federation of American Scientists (FAS) is meeting this moment by launching an ambitious new project to reimagine the U.S. environmental regulatory state, drawing ideas from across ideological lines.

The Beginning of a New Era

Fear of the risks of systemic change often prevent people from entertaining change in earnest. Think of the years of U.S. squabbles over how or whether to reform permitting and environmental review, while other countries simply raced ahead to build clean energy projects and establish dominance in the new world economy. Systemic stagnation, however, comes with its own consequences. 

The Inflation Reduction Act (IRA) and the Infrastructure Investment and Jobs Act (IIJA) are a case in point when it comes to climate and the environment. Together, these two pieces of legislation represented the largest global investment in the promise of a healthier, more sustainable, and, yes, cheaper future. Unfortunately, as proponents of the “abundance” paradigm and others have observed, rollout was hampered by inefficient processes and outdated laws. Implementing the IRA and the IIJA via old systems, in short, was like trying to funnel an ocean through a garden hose – and as a result, most Americans experienced only a trickle of real-world impact.

Similar barriers are constraining state progress. For example, the way we govern and pay for electricity has not kept pace with a rapidly changing energy landscape – meaning that the United States risks ceding leadership on energy technologies critical to national security, economic competitiveness, and combating climate change.

But we are perhaps now entering a new era. The United States appears to be on the edge of real political realignments, with transpartisan stakes around the core role of government in economic development that do not match up neatly to current coalitions. This realignment presents a crucial opportunity to catalyze a new era of climate, environmental, and democratic progress.

FAS will leverage this opportunity by providing a forum for debate and engagement on different facets of climate and environmental governance, a platform to amplify insights, and the capacity to drive forward solutions. Examples of topics ripe for exploration include:

• Balancing agility and accountability. As observed, regulatory approaches of the past have struggled to address the interconnected, quickly evolving nature of climate and environmental challenges. At the same time, mechanisms for ensuring accountability have been disrupted by an evolving legal landscape and increasingly muscular executive. There is a need to imagine and test new systems designed to move quickly but responsibly on climate and environmental issues. 
• Complementing traditional regulation through novel strategies. There is growing interest in using novel financial, contractual, and other strategies as a complement to regulation for driving climate and environmental progress. There is considerable room to go deeper in this space, identifying both the power of these strategies and their limits. 
• Rethinking stakeholder engagement. The effectiveness of regulation depends on its ability to serve diverse stakeholder needs while advancing environmental goals. Public comment and other pipelines for engaging stakeholders and integrating external perspectives and expertise into regulations have been disrupted by technologies such as AI, while the relationship between regulated entities and their regulators has become increasingly adversarial. There is a need to examine synergies and tradeoffs between centering stakeholders and centering outcomes in regulatory processes, as well as examine how stakeholder engagement could be improved to better ensure regulations that are informed, feasible, durable, and distributively fair. 

In working through topics like these, FAS seeks to lay out a positive vision of regulatory reconstruction that is substantively superior to either haphazard destruction or incremental change. Our vision is nothing less than to usher in a new paradigm of climate and environmental governance: one that secures a livable world while reinforcing democratic stability, through systems that truly deliver for America. 

We will center our focus on the federal government given its important role in climate and environmental issues. However, states and localities do a lot of the work of a federated government day-to-day. We recognize that federal cures are unlikely to fully alleviate the symptoms that Americans are experiencing every day, from decaying infrastructure to housing shortages. We are committed to ensuring that solutions are appropriately matched to the root cause of state capacity problems and that federal climate and environmental regulatory regimes are designed to support successful cooperation with local governments and implementation partners. 

FAS is no stranger to ambitious endeavors like these. Since our founding in 1945, we have been committed to tackling the major science policy issues that reverberate through American life. This new FAS workstream will be embedded across our Climate and Environment, Clean Energy, and Government Capacity portfolios. We have already begun engaging and activating the diverse community of scholars, experts, and leaders laying the intellectual groundwork to develop compelling answers to urgent questions surrounding the climate regulatory state, against the backdrop of a broader state capacity movement. True to our nonpartisan commitment, we will build this work on a foundation of cross-ideological curiosity and play on the tension points in existing coalitions that strike us all as most productive.

We invite you to join us in conversation and collaboration. If you want to get involved, contact Zoë Brouns (zbrouns@fas.org).

Decision to Sunset IRS’ Direct File Previews Worse Taxpayer Experience in 2026

Yesterday, tens of thousands of taxpayers filed their returns using IRS Direct File, the agency’s new free, public, online tax filing service now in its second filing season. They joined hundreds of thousands who have used the service, and who have been nearly-unanimously thrilled to fulfill their tax obligations easily and directly. It seems we have finally done the impossible: make Tax Day anything but the most dreaded day of the year. At least we did.

Today, the Associated Press reported that the Treasury Department will discontinue the program. “Cutting costs and saving money for families were just empty campaign promises,” says Adam Ruben, a vice president at the Economic Security Project of the administration’s decision to end the program.

I was an original architect of Direct File from 2021 until just a few months ago, and got to see its impact on government and on taxpayers directly. Make no mistake: Direct File is a shining example of government capacity and government efficiency. By providing a critical government service for free, and helping taxpayers file more timely and more accurate returns, it is projected to eventually generate $11 billion in net savings for taxpayers every year. 

The dismantling of the program is not, at all, a step toward government efficiency. This is a move that will degrade our government services, incurring massive costs for people trying to file their taxes, further damaging the capacity of the nation’s revenue-collection agency, and making our institutions less robust and less capable.

It’s no secret: Americans do not love tax season.

The Direct File story started for me, personally, when I moved back to the U.S. after living in London for 9 years. I had already spent years working in digital services: I had built the first in-house digital team at the brand-new Consumer Financial Protection Bureau in 2010, and then worked on multiple projects in London, culminating in helping the London Borough of Camden digitally transform its entire operations practically overnight during the pandemic. I moved back to the States and joined the US Digital Service to help rebuild after Covid, bringing the lessons I had learned from the UK. My first project at USDS was leading our efforts on Child Tax Credit expansion — ensuring that families across the country could access the enormous new child benefit that was created in the March 2021 American Rescue Plan.

But there was a problem: families naturally had to file a tax return to claim their tax credit. And I was pretty surprised to learn that our government still did not, in 2021, offer a free, online way to file your taxes directly with the government. Around the world, tax collection is seen as an inherent government function and, as such, tax filing is a service that the government offers free of charge. I thought we should too, especially if we were going to make such critical social supports contingent on it during a crisis. 

Instead, in the U.S., we relied on a confusing — and sometimes costly — mishmash of private offerings and support from non-profits designed to ensure most people could maybe, sort of, file a return for free if they needed to. It made the barrier to entry high, both in terms of trying to navigate how to simply file a return, nevermind to do so without cost. Tax filing, I thought, is a core function of government, and making it free and easy to use would cut through this waste and deliver for the American people.

I wasn’t the only one who thought this way. By 2021, a free public filing service was already the “white whale” of civic tech; everyone knew this was the critical government function to bring into a modern digital product, and yet it was too big, too daunting, too much of a change. Honestly, never in a million years did I think we would pull it off, either. The IRS, for all its genuine accomplishments in the face of constantly shrinking budgets and aging technology, had no real experience launching an enormous, high-stakes tech product designed to simplify the mind-numbing complexities of an American tax return. This was government capacity we would have to create.

But, we did. Since Direct File launched as a pilot in March 2023, hundreds of thousands of people have now filed their returns with it, to stunning results. In its pilot year, 86% of users said that Direct File increased their trust in the IRS. In its second year, it is winning awards and killing it with users, with a Net Promoter Score in the +80s, up from +74 last year (Apple’s, which is considered astronomically high, is +72). Direct File is a wildly successful government startup. Not only that, but the IRS now has its own in-house capacity to continue building awesome digital experiences — capacity that could have gone toward cost savings and experience improvements in all matter of IRS operations. This is all capacity, needless to say, that has gone away, all in the name of “efficiency.”

The impact for taxpayers from Direct File alone are, and would have been, enormous. In the U.S., the IRS estimates that it takes the average person over 9 hours and costs $160 to file your taxes each year. We even heard anecdotally from Direct File users who had paid thousands of dollars to do what Direct File does for free. There also remain millions of households who, every year, don’t file their returns at all, leaving sizable refunds on the table, because they can’t navigate the confusing tax filing “offers” advertising tax filing services. These households would have stood to finally access billions of dollars they leave unclaimed every year.

Not only are taxpayers saving these hundreds of dollars, they also feel newly empowered to interact with their government and take control of their tax situations. For decades, Americans have been told that they are not smart enough to do your own taxes; only highly-paid specialists that you have to pay for, can do it for you. Direct File stripped away the noise and showed taxpayers that filing can be simple and easy. The valuable trust this creates in government and public institutions is impossible to quantify.

Finally, there is the issue of data privacy and security. Taxpayers filing via private services must expose their most sensitive personal and financial information to third parties that monetize their data, sometimes illegally and without taxpayers’ consent. Without a public filing option, taxpayers are more or less required to sacrifice their privacy and the security of their data just to fulfill their filing obligations. Direct File gives taxpayers the option to protect their data and provide it straight to the tax agency, without a middleman.

All this — the in-house capacity to modernize the IRS, billions of dollars in cost savings, an empowered public — is what is cancelled today. But they have it exactly backwards. It’s a functional, high-quality government that’s efficient. The chaos they are sowing is anything but.

Federal Advisory Committees (FACs) are the single point of entry for the American public to provide consensus-based advice and recommendations to the federal government. These Advisory Committees are composed of experts from various fields who serve as Special Government Employees (SGEs), attending committee meetings, writing reports, and voting on potential government actions.

Advisory Committees are needed for the federal decision-making process because they provide additional expertise and in-depth knowledge for the Agency on complex topics, aid the government in gathering information from the public, and allow the public the opportunity to participate in meetings about the Agency’s activities. As currently organized, FACs are not equipped to provide the best evidence-based advice. This is because FACs do not meet transparency requirements set forth by GAO: making pertinent decisions during public meetings, reporting inaccurate cost data, providing  official meeting documents publicly available online, and more. FACs have also experienced difficulty with recruiting and retaining top talent to assist with decision making. For these reasons, it is critical that FACs are reformed and equipped with the necessary tools to continue providing the government with the best evidence-based advice. Specifically, advice as it relates to issues such as 1) decreasing the burden of hiring special government employees 2) simplifying the financial disclosure process 3) increasing understanding of reporting requirements and conflict of interest processes 4) expanding training for Advisory Committee members 5) broadening  the roles of Committee chairs and designated federal officials 6) increasing public awareness of Advisory Committee roles 7) engaging the public outside of official meetings 8) standardizing representation from Committee representatives 9) ensuring that Advisory Committees are meeting per their charters and 10) bolstering Agency budgets for critical Advisory Committee issues. 

Challenge and Opportunity

Protecting the health and safety of the American public and ensuring that the public has the opportunity to participate in the federal decision-making process is crucial. We must evaluate the operations and activities of federal agencies that require the government to solicit evidence-based advice and feedback from various experts through the use of federal Advisory Committees (FACs). These Committees are instrumental in facilitating transparent and collaborative deliberation between the federal government, the advisory body, and the American public and cannot be done through the use of any other mechanism. Advisory Committee recommendations are integral to strengthening public trust and reinforcing the credibility of federal agencies. Nonetheless, public trust in government has been waning and efforts should be made to increase public trust. Public trust is known as the pillar of democracy and fosters trust between parties, particularly when one party is external to the federal government. Therefore, the use of Advisory Committees, when appropriately used, can assist with increasing public trust and ensuring compliance with the law. 

There have also been many success stories demonstrating the benefits of Advisory Committees. When Advisory Committees are appropriately staffed based on their charge, they can decrease the workload of federal employees, assist with developing policies for some of our most challenging issues, involve the public in the decision-making process, and more. However, the state of Advisory Committees and the need for reform have been under question, and even more so as we transition to a new administration. Advisory Committees have contributed to the improvement in the quality of life for some Americans through scientific advice, as well as the monitoring of cybersecurity. For example, an FDA Advisory Committee reviewed data and saw promising results for the treatment of sickle cell disease (SCD) which has been a debilitating disease with limited treatment for years. The Committee voted in favor of gene therapy drugs Casgevy and Lyfgenia which were the first to be approved by the FDA for SCD. 

Under the first Trump administration, Executive Order (EO) 13875 resulted in a significant decrease in the number of federal advisory meetings. This  limited agencies’ ability to convene external advisors. Federal science advisory committees met less during this administration than any prior administration, met less than what was required from their charter, disbanded long standing Advisory Committees, and scientists receiving agency grants were barred from serving on Advisory Committees. Federal Advisory Committee membership also decreased by 14%, demonstrating the issue of recruiting and retaining top talent. The disbandment of Advisory Committees, exclusion of key scientific external experts from Advisory Committees, and burdensome procedures can potentially trigger  severe consequences that affect the health and safety of Americans. 

Going into a second Trump administration, it is imperative that Advisory Committees have the opportunity to assist federal agencies with the evidence-based advice needed to make critical decisions that affect the American public. The suggested reforms that follow can work to improve the overall operations of Advisory Committees while still providing the government with necessary evidence-based advice. With successful implementation of the following recommendations, the federal government will be able to reduce administrative burden on staff through the recruitment, onboarding, and conflict of interest processes. 

The U.S. Open Government Initiative encourages the promotion and participation of public and community engagement in  governmental affairs. However, individual Agencies can and should do more to engage the public. This policy memo identifies several areas of potential reform for Advisory Committees and aims to provide recommendations for improving the overall process without compromising Agency or Advisory Committee membership integrity. 

Plan of Action

The proposed plan of action identifies several policy recommendations to reform the federal Advisory Committee (Advisory Committee) process, improving both operations and efficiency. Successful implementation of these policies will  1) improve the Advisory Committee member experience, 2) increase transparency in federal government decision-making, and 3) bolster trust between the federal government, its Advisory Committees, and the public. 

Streamline Joining Advisory Committees

Recommendation 1. Decrease the burden of hiring special government employees in an effort to (1) reduce the administrative burden for the Agency and (2) encourage Advisory Committee members, who are also known as special government employees (SGEs), to continue providing the best evidence-based advice to the federal government through reduced onerous procedures

The Ethics in Government Act of 1978 and Executive Order 12674 lists OGE-450 reporting as the required public financial disclosure for all executive branch and special government employees. This Act provides the Office of Government Ethics (OGE) the authority to implement and regulate a financial disclosure system for executive branch and special government employees whose duties have “heightened risk of potential or actual conflicts of interest”. Nonetheless, the reporting process becomes onerous when Advisory Committee members have to complete the OGE-450 before every meeting even if their information remains unchanged. This presents a challenge for Advisory Committee members who wish to continue serving, but are burdened by time constraints. The process also burdens federal staff who manage the financial disclosure system. 

Policy Pathway 1. Increase funding for enhanced federal staffing capacity to undertake excessive administrative duties for financial reporting.

Policy Pathway 2. All federal agencies that deploy Advisory Committees can conduct a review of the current OGC-450 process, budget support for this process, and work to develop an electronic process that will eliminate the use of forms and allow participants to select dropdown options indicating if their financial interests have changed.  

Recommendation 2. Create and use public platforms such as OpenPayments by CMS to (1) aid in simplifying the financial disclosure reporting process and (2) increase transparency for disclosure procedures

Federal agencies should create a financial disclosure platform that streamlines the process and allows Advisory Committee members to submit their disclosures and easily make updates. This system should also be created to monitor and compare financial conflicts. In addition, agencies that utilize the expertise of Advisory Committees for drugs and devices should identify additional ways in which they can promote financial transparency. These agencies can use Open Payments, a system operated by Centers for Medicare & Medicaid Services (CMS), to “promote a more financially transparent and accountable healthcare system”. The Open Payments system makes payments from medical and drug device companies to individuals, healthcare providers, and teaching hospitals accessible to the public. If for any reason financial disclosure forms are called into question, the Open Payments platform can act as a check and balance in identifying any potential financial interests of Advisory Committee members. Further steps that can be taken to simplify the financial disclosure process would be to utilize conflict of interest software such as Ethico which is a comprehensive tool that allows for customizable disclosure forms, disclosure analytics for comparisons, and process automation.   

Policy Pathway. The Office of Government Ethics should require all federal agencies that operate Advisory Committees to develop their own financial disclosure system and include a second step in the financial disclosure reporting process as due diligence, which includes reviewing the Open Payments by CMS system for potential financial conflicts or deploying conflict of interest monitoring software to streamline the process.

Streamline Participation in an Advisory Committee

Recommendation 3. Increase understanding of annual reporting requirements for conflict of interest (COI)

Agencies should develop guidance that explicitly states the roles of Ethics Officers, also known as Designated Agency Ethics Officials (DAEO), within the federal government. Understanding the roles and responsibilities of Advisory Committee members and the public will help reduce the spread of misinformation regarding the purpose of Advisory Committees. In addition, agencies should be encouraged by the Office of Government Ethics to develop guidance that indicates the criteria for inclusion or exclusion of participation in Committee meetings. Currently, there is no public guidance that states what types of conflicts of interests are granted waivers for participation. Full disclosure of selection and approval criteria will improve transparency with the public and draw clear delineations between how Agencies determine who is eligible to participate. 

Policy Pathway. Develop conflict of interest (COI) and financial disclosure guidance specifically for SGEs that states under what circumstances SGEs are allowed to receive waivers for participation in Advisory Committee meetings.

Recommendation 4. Expand training for Advisory Committee members to include (1) ethics and (2) criteria for making good recommendations to policymakers

Training should be expanded for all federal Advisory Committee members to include ethics training which details the role of Designated Agency Ethics Officials, rules and regulations for financial interest disclosures, and criteria for making evidence-based recommendations to policymakers. Training for incoming Advisory Committee members ensures that all members have the same knowledge base and can effectively contribute to the evidence-based recommendations process.

Policy Pathway. Agencies should collaborate with the OGE and Agency Heads to develop comprehensive training programs for all incoming Advisory Committee members to ensure an understanding of ethics as contributing members, best practices for providing evidence-based recommendations, and other pertinent areas that are deemed essential to the Advisory Committee process.

Leverage Advisory Committee Membership

Recommendation 5. Uplifting roles of the Committee Chairs and Designated Federal Officials

Expanding the roles of Committee Chairs and Designated Federal Officers (DFOs) may assist federal Agencies with recruiting and retaining top talent and maximizing the Committee’s ability to stay abreast of critical public concerns. Considering the fact that the General Services Administration has to be consulted for the formation of new Committees, renewal, or alteration of Committees, they can be instrumental in this change.

Policy Pathway. The General Services Administration (GSA) should encourage federal Agencies to collaborate with Committee Chairs and DFOs to recruit permanent and ad hoc Committee members who may have broad network reach and community ties that will bolster trust amongst Committees and the public. 

Recommendation 6. Clarify intended roles for Advisory Committee members and the public

There are misconceptions among the public and Advisory Committee members about Advisory Committee roles and responsibilities. There is also ambiguity regarding the types of Advisory Committee roles such as ad hoc members, consulting, providing feedback for policies, or making recommendations. 

Policy Pathway. GSA should encourage federal Agencies to develop guidance that delineates the differences between permanent and temporary Advisory Committee members, as well as their roles and responsibilities depending on if they’re providing feedback for policies or providing recommendations for policy decision-making.

Recommendation 7. Utilize and engage expertise and the public outside of public meetings

In an effort to continue receiving the best evidence-based advice, federal Agencies should develop alternate ways to receive advice outside of public Committee meetings. Allowing additional opportunities for engagement and feedback from Committee experts or the public will allow Agencies to expand their knowledge base and gather information from communities who their decisions will affect.

Policy Pathway. The General Services Administration should encourage federal Agencies to create opportunities outside of scheduled Advisory Committee meetings to engage Committee members and the public on areas of concern and interest as one form of engagement. 

Recommendation 8. Standardize representation from Committee representatives (i.e., industry), as well as representation limits

The Federal Advisory Committee Act (FACA) does not specify the types of expertise that should be represented on all federal Advisory Committees, but allows for many types of expertise. Incorporating various sets of expertise that are representative of the American public will ensure the government is receiving the most accurate, innovative, and evidence-based recommendations for issues and products that affect Americans. 

Policy Pathway. Congress should include standardized language in the FACA that states all federal Advisory Committees should include various sets of expertise depending on their charge. This change should then be enforced by the GSA.

Support a Vibrant and Functioning Advisory Committee System

Recommendation 9. Decrease the burden to creating an Advisory Committee and make sure Advisory Committees are meeting per their charters

The process to establish an Advisory Committee should be simplified in an effort to curtail the amount of onerous processes that lead to a delay in the government receiving evidence based advice.

Advisory Committee charters state the purpose of Advisory Committees, their duties, and all aspirational aspects. These charters are developed by agency staff or DFOs with consultation from their agency Committee Management Office. Charters are needed to forge the path for all FACs.

Policy Pathway. Designated Federal Officers (DFOs) within federal agencies should work with their Agency head to review and modify steps to establishing FACs. Eliminate the requirement for FACs to require consultation and/or approval from GSA for the formation, renewal, or alteration of Advisory Committees.

Recommendation 10. Bolster agency budgets to support FACs on critical issues where regular engagement and trust building with the public is essential for good policy

Federal Advisory Committees are an essential component to receive evidence-based recommendations that will help guide decisions at all stages of the policy process. These Advisory Committees are oftentimes the single entry point external experts and the public have to comment and participate in the decision-making process. However, FACs take considerable resources to operate depending on the frequency of meetings, the number of Advisory Committee members, and supporting FDA staff. Without proper appropriations, they have a diminished ability to recruit and retain top talent for Advisory Committees. The Government Accountability Office (GAO) reported that in 2019, approximately $373 million dollars was spent to operate a total of 960 federal Advisory Committees. Some Agencies have experienced a decrease in the number of Advisory Committee convenings. Individual Agency heads should conduct a budget review of average operating and projected costs and develop proposals for increased funding to submit to the Appropriations Committee.  

Policy Pathway. Congress should consider increasing appropriations to support FACs so they can continue to enhance federal decision-making, improve public policy, boost public credibility, and Agency morale. 

Conclusion

Advisory Committees are necessary to the federal evidence-based decision-making ecosystem. Enlisting the advice and recommendations of experts, while also including input from the American public, allows the government to continue making decisions that will truly benefit its constituents. Nonetheless, there are areas of FACs that can be improved to ensure it continues to be a participatory, evidence-based process. Additional funding is needed to compensate the appropriate Agency staff for Committee support, provide potential incentives for experts who are volunteering their time, and finance other expenditures.

Frequently Asked Questions

How will Federal Advisory Committees (Advisory Committees) increase government efficiency?

With reform of Advisory Committees, the process for receiving evidence-based advice will be streamlined, allowing the government to receive this advice in a faster and less burdensome manner. Reform will be implemented by reducing the administrative burden for federal employees through the streamlining of recruitment, financial disclosure, and reporting processes.

read more

The administration should create a federal center of excellence for state and local artificial intelligence (AI) procurement and use—a hub for expertise and resources on public sector AI procurement and use at the state, local, tribal, and territorial (SLTT) government levels. The center could be created by expanding the General Services Administration’s (GSA) existing Artificial Intelligence Center of Excellence (AI CoE). As new waves of AI technologies enter the market, shifting both practice and policy, such a center of excellence would help bridge the gap between existing federal resources on responsible AI and the specific, grounded challenges that individual agencies face. In the decades ahead, new AI technologies will touch an expanding breadth of government services—including public health, child welfare, and housing—vital to the wellbeing of the American people. An AI CoE federal center would equip public sector agencies with sustainable expertise and set a consistent standard for practicing responsible AI procurement and use. This resource ensures that AI truly enhances services, protects the public interest, and builds public trust in AI-integrated state and local government services. 

Challenge and Opportunity 

State, local, tribal, and territorial (SLTT) governments provide services that are critical to the welfare of our society. Among these: providing housing, child support, healthcare, credit lending, and teaching. SLTT governments are increasingly interested in using AI to assist with providing these services. However, they face immense challenges in responsibly procuring and using new AI technologies. While grappling with limited technical expertise and budget constraints, SLTT government agencies considering or deploying AI must navigate data privacy concerns, anticipate and mitigate biased model outputs, ensure model outputs are interpretable to workers, and comply with sector-specific regulatory requirements, among other responsibilities. 

The emergence of foundation models (large AI systems adaptable to many different tasks) for public sector use exacerbates these existing challenges. Technology companies are now rapidly developing new generative AI services tailored towards public sector organizations. For example, earlier this year, Microsoft announced that Azure OpenAI Service would be newly added to Azure Government—a set of AI services that target government customers. These types of services are not specifically created for public sector applications and use contexts, but instead are meant to serve as a foundation for developing specific applications. 

For SLTT government agencies, these generative AI services blur the line between procurement and development: Beyond procuring specific AI services, we anticipate that agencies will increasingly be tasked with the responsible use of general AI services to develop specific AI applications. Moreover, recent AI regulations suggest that responsibility and liability for the use and impacts of procured AI technologies will be shared by the public sector agency that deploys them, rather than just resting with the vendor supplying them.

SLTT agencies must be well-equipped with responsible procurement practices and accountability mechanisms pivotal to moving forward given the shifts across products, practice, and policy. Federal agencies have started to provide guidelines for responsible AI procurement (e.g., Executive Order 13960, OMB-M-21-06, NIST RMF). But research shows that SLTT governments need additional support to apply these resources.: Whereas existing federal resources provide high-level, general guidance, SLTT government agencies must navigate a host of challenges that are context-specific (e.g., specific to regional laws, agency practices, etc.). SLTT government agency leaders have voiced a need for individualized support in accounting for these context-specific considerations when navigating procurement decisions. 

Today, private companies are promising state and local government agencies that using their AI services can transform the public sector. They describe diverse potential applications, from supporting complex decision-making to automating administrative tasks. However, there is minimal evidence that these new AI technologies can improve the quality and efficiency of public services. There is evidence, on the other hand, that AI in public services can have unintended consequences, and when these technologies go wrong, they often worsen the problems they are aimed at solving. For example, by increasing disparities in decision-making when attempting to reduce them. 

Challenges to responsible technology procurement follow a historical trend: Government technology has frequently been critiqued for failures in the past decades. Because public services such as healthcare, social work, and credit lending have such high stakes, failures in these areas can have far-reaching consequences. They also entail significant financial costs, with millions of dollars wasted on technologies that ultimately get abandoned. Even when subpar solutions remain in use, agency staff may be forced to work with them for extended periods despite their poor performance.

The new administration is presented with a critical opportunity to redirect these trends. Training each relevant individual within SLTT government agencies, or hiring new experts within each agency, is not cost- or resource-effective. Without appropriate training and support from the federal government, AI adoption is likely to be concentrated in well-resourced SLTT agencies, leaving others with fewer resources (and potentially more low income communities) behind. This could lead to disparate AI adoption and practices among SLTT agencies, further exacerbating existing inequalities. The administration urgently needs a plan that supports SLTT agencies in learning how to handle responsible AI procurement and use–to develop sustainable knowledge about how to navigate these processes over time—without requiring that each relevant individual in the public sector is trained. This plan also needs to ensure that, over time, the public sector workforce is transformed in their ability to navigate complicated AI procurement processes and relationships—without requiring constant retraining of new waves of workforces. 

In the context of federal and SLTT governments, a federal center of excellence for state and local AI procurement would accomplish these goals through a “hub and spoke” model. This center of excellence would serve as the “hub” that houses a small number of selected experts from academia, non-profit organizations, and government. These experts would then train “spokes”—existing state and local public sector agency workers—in navigating responsible procurement practices. To support public sector agencies in learning from each others’ practices and challenges, this federal center of excellence could additionally create communication channels for information- and resource-sharing across the state and local agencies. 

Procured AI technologies in government will serve as the backbone of local public services for decades to come. Upskilling government agencies to make smart decisions about which AI technologies to procure (and which are best avoided) would not only protect the public from harmful AI systems but would also save the government money by decreasing the likelihood of adopting expensive AI technologies that end up getting dropped. 

Plan of Action 

A federal center of excellence for state and local AI procurement would ensure that procured AI technologies are responsibly selected and used to serve as a strong and reliable backbone for public sector services. This federal center of excellence can support both intra-agency and inter-agency capacity-building and learning about AI procurement and use—that is, mechanisms to support expertise development within a given public sector agency and between multiple public sector agencies. This federal center of excellence would not be deliberative (i.e., SLTT governments would receive guidance and support but would not have to seek approval on their practices). Rather, the goal would be to upskill SLTT agencies so they are better equipped to navigate their own AI procurement and use endeavors. 

To upskill SLTT agencies through inter-agency capacity-building, the federal center of excellence would house experts in relevant domain areas (e.g., responsible AI, public interest technology, and related topics). Fellows would work with cohorts of public sector agencies to provide training and consultation services. These fellows, who would come from government, academia, and civil society, would build on their existing expertise and experiences with responsible AI procurement, integrating new considerations proposed by federal standards for responsible AI (e.g., Executive Order 13960, OMB-M-21-06, NIST RMF). The fellows would serve as advisors to help operationalize these guidelines into practical steps and strategies, helping to set a consistent bar for responsible AI procurement and use practices along the way. 

Cohorts of SLTT government agency workers, including existing agency leaders, data officers, and procurement experts, would work together with an assigned advisor to receive consultation and training support on specific tasks that their agency is currently facing. For example, for agencies or programs with low AI maturity or familiarity (e.g., departments that are beginning to explore the adoption of new AI tools), the center of excellence can help navigate the procurement decision-making process, help them understand their agency-specific technology needs, draft procurement contracts, select amongst proposals, and negotiate plans for maintenance. For agencies and programs with high AI maturity or familiarity, the advisor can train the programs about unexpected AI behaviors and mitigation strategies, when this arises. These communication pathways would allow federal agencies to better understand the challenges state and local governments face in AI procurement and maintenance, which can help seed ideas for improving existing resources and create new resources for AI procurement support.

To scaffold intra-agency capacity-building, the center of excellence can build the foundations for cross-agency knowledge-sharing. In particular, it would include a communication platform and an online hub of procurement resources, both shared amongst agencies. The communication platform would allow state and local government agency leaders who are navigating AI procurement to share challenges, learned lessons, and tacit knowledge to support each other. The online hub of resources can be collected by the center of excellence and SLTT government agencies. Through the online hub, agencies can upload and learn about new responsible AI resources and toolkits (e.g., such as those created by government and the research community), as well as examples of procurement contracts that agencies themselves used. 

To implement this vision, the new administration should expand the U.S. General Services Administration’s (GSA) existing Artificial Intelligence Center of Excellence (AI CoE), which provides resources and infrastructural support for AI adoption across the federal government. We propose expanding this existing AI CoE to include the components of our proposed center of excellence for state and local AI procurement and use. This would direct support towards SLTT government agencies—which are currently unaccounted for in the existing AI CoE—specifically via our proposed capacity-building model.

Over the next 12 months, the goals of expanding the AI CoE would be three-fold:

1. Develop the core components of our proposed center of excellence within the AI CoE. 

• Recruit a core set of fellows with expertise in responsible AI, public interest technology, and related topics from government, academia, and civil society for a 1-2 year placement; 
• Develop a centralized onboarding and training program for the fellows to set standards for responsible AI procurement and use guidelines and goals; 
• Create a research strategy to streamline documentation of SLTT agencies’ on-the-ground practices and challenges for procuring new AI technologies, which could help prepare future fellows. 

2. Launch collaborations for the first sample of SLTT government agencies. Focus on building a path for successful collaborations: 

• Identify a small set of state and local government agencies who desire federal support in navigating AI procurement and use (e.g., deciding which AI use cases to adopt, how to effectively evaluate AI deployments through time, what organizational policies to create to help govern AI use); 
• Ensure there is a clear communication pathway between the agency and their assigned fellow; 
• Have each fellow and agency pair create a customized plan of action to ensure the agency is upskilled in their ability to independently navigate AI procurement and use with time. 

3. Build a path for our proposed center of excellence to grow and gain experience. If the first few collaborations show strong reviews, design a scaling strategy that will: 

• Incorporate the center of excellence’s core budget into future budget planning;
• Identify additional fellows for the program; 
• Roll out the program to additional state and local government agencies. 

Conclusion

Expanding the existing AI CoE to include our proposed federal center of excellence for AI procurement and use can help ensure that SLTT governments are equipped to make informed, responsible decisions about integrating AI technologies into public services. This body would provide necessary guidance and training, helping to bridge the gap between high-level federal resources and the context-specific needs of SLTT agencies. By fostering both intra-agency and inter-agency capacity-building for responsible AI procurement and use, this approach builds sustainable expertise, promotes equitable AI adoption, and protects public interest. This ensures that AI enhances—rather than harms—the efficiency and quality of public services. As new waves of AI technologies continue to enter the public sector, touching a breadth of services critical to the welfare of the American people, this center of excellence will help maintain high standards for responsible public sector AI for decades to come.

This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.

PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.

Frequently Asked Questions

What is existing guidance for responsible SLTT procurement and use of AI technologies?

Federal agencies have published numerous resources to support responsible AI procurement, including the Executive Order 13960, OMB-M-21-06, NIST RMF. Some of these resources provide guidance on responsible AI development in organizations broadly, across the public, private, and non-profit sectors. For example, the NIST RMF provides organizations with guidelines to identify, assess, and manage risks in AI systems to promote the deployment of more trustworthy and fair AI systems. Others focus on public sector AI applications. For instance, the OMB Memorandum published by the Office of Management and Budget describes strategies for federal agencies to follow responsible AI procurement and use practices.

read more

Why a federal center? Can’t SLTT governments do this on their own?

Research describes how these forms of resources often require additional skills and knowledge that make it challenging for agencies to effectively use on their own. A federal center of excellence for state and local AI procurement could help agencies learn to use these resources. Adapting these guidelines to specific SLTT agency contexts necessitates a careful task of interpretation which may, in turn, require specialized expertise or resources. The creation of this federal center of excellence to guide responsible SLTT procurement on-the-ground can help bridge this critical gap. Fellows in the center of excellence and SLTT procurement agencies can build on this existing pool of guidance to build a strong theoretical foundation to guide their practices.

read more

How has this “hub and spoke” model been used before?

The hub and spoke model has been used across a range of applications to support efficient management of resources and services. For instance, in healthcare, providers have used the hub and spoke model to organize their network of services; specialized, intensive services would be located in “hub” healthcare establishments whereas secondary services would be provided in “spoke” establishments, allowing for more efficient and accessible healthcare services. Similar organizational networks have been followed in transportation, retail, and cybersecurity. Microsoft follows a hub and spoke model to govern responsible AI practices and disseminate relevant resources. Microsoft has a single centralized “hub” within the company that houses responsible AI experts—those with expertise on the implementation of the company’s responsible AI goals. These responsible AI experts then train “spokes”—workers residing in product and sales teams across the company, who learn about best practices and support their team in implementing them.

read more

Who would be the experts selected as fellows by the center of excellence? What kind of training would they receive?

During the training, experts would form a stronger foundation for (1) on-the-ground challenges and practices that public sector agencies grapple with when developing, procuring, and using AI technologies and (2) existing AI procurement and use guidelines provided by federal agencies. The content of the training would be taken from syntheses of prior research on public sector AI procurement and use challenges, as well as existing federal resources available to guide responsible AI development. For example, prior research has explored public sector challenges to supporting algorithmic fairness and accountability and responsible AI design and adoption decisions, amongst other topics.

The experts who would serve as fellows for the federal center of excellence would be individuals with expertise and experience studying the impacts of AI technologies and designing interventions to support more responsible AI development, procurement, and use. Given the interdisciplinary nature of the expertise required for the role, individuals should have an applied, socio-technical background on responsible AI practices, ideally (but not necessarily) for the public sector. The individual would be expected to have the skills needed to share emerging responsible AI practices, strategies, and tacit knowledge with public sector employees developing or procuring AI technologies. This covers a broad range of potential backgrounds.

read more

What are some examples of the skills or competencies fellows might bring to the Center?

For example, a professor in academia who studies how to develop public sector AI systems that are more fair and aligned with community needs may be a good fit. A socio-technical researcher in civil society with direct experience studying or developing new tools to support more responsible AI development, who has intuition over which tools and practices may be more or less effective, may also be a good candidate. A data officer in a state government agency who has direct experience procuring and governing AI technologies in their department, with an ability to readily anticipate AI-related challenges other agencies may face, may also be a good fit. The cohort of fellows should include a balanced mix of individuals coming from government, academia, and civil society.

read more

The United States faces urgent challenges related to aging infrastructure, vulnerable energy systems, and economic competitiveness. Improving American competitiveness, security, and prosperity depends on private and public stakeholders’ ability to responsibly site, build, and deploy critical energy and infrastructure. Unfortunately, these projects face one common bottleneck: permitting. 

Permits and authorizations are required for the use of land and other resources under a series of laws, such as the National Environmental Policy Act (NEPA), the Endangered Species Act (ESA), and National Historic Preservation Act of 1966. However, recent court rulings and the Trump Administration’s executive actions have brought uncertainty and promise major disruption to the status quo. The Executive Order (EO) on Unleashing American Energy mandates guidance to agencies on permitting processes be expedited and simplified within 30 days, requires agencies prioritize efficiency and certainty over any other objectives, and revokes the Council of Environmental Quality’s (CEQ) authority to issue binding NEPA regulations. While these changes aim to advance the speed, efficiency, and certainty of permitting, the impact will ultimately depend on implementation by the permitting workforce.

Unfortunately, the permitting workforce is unprepared to swiftly implement changes following shifts in environmental policy and regulations. Teams responsible for permitting have historically been understaffed, overworked, and unable to complete their project backlogs, while demands for permits have increased significantly in recent years. Building workforce capacity is critical for efficient and effective federal permitting. 

Project Overview

Our team at the Federation of American Scientists (FAS) has spent 18 months studying and working to build government capacity for permitting talent. The Inflation Reduction Act (IRA) provided resources to expand the federal permitting workforce, and we partnered with the Permitting Council, which serves as a central body to improve the transparency, predictability, and accountability of the federal environmental review and authorization process, to gain a cross-agency understanding of the hiring challenges experienced in permitting agencies and prioritize key challenges to address. Through two co-hosted webinars for hiring managers, HR specialists, HR leaders, and program leaders within permitting agencies, we shared tactical solutions to improve the hiring process.

We complemented this understanding with voices from agencies (i.e., hiring managers, HR specialists, HR teams, and leaders) by conducting interviews to identify new issues, best practices, and successful strategies for building talent capacity. With this understanding, we developed long-term solutions to build a sustainable, federal permitting workforce for the future. While many of our recommendations are focused on permitting talent specifically, our work naturally uncovered challenges within the broader federal talent ecosystem. As such, we’ve included recommendations to advance federal talent systems and improve federal hiring.

Problem

Building permitting talent capacity across the federal government is not an easy endeavor. There are many stakeholders involved across different agencies with varying levels of influence who need to play a role: the Permitting Council staff, the Permitting Council members-represented by Deputy Secretaries (Deputy Secretaries) of permitting agencies, the Chief Environmental Review and Permitting Officers (CERPOs) in each agency, the Office of Personnel and Management (OPM), the Chief Human Capital Officer (CHCO) in each permitting agency, agency HR teams, agency permitting teams, hiring managers, and HR specialists. Permitting teams and roles are widely dispersed across agencies, regions, states, and programs. The role each agency plays in permitting varies based on their mission and responsibilities, and there are many silos within the broader ecosystem. Few have a holistic view of permitting activities and the permitting workforce across the federal government.

With this complex network of actors, one challenge that arises is a lack of standardization and consistency in both roles and teams across agencies. If agencies are looking to fill specialized roles unique to one permitting need, it means that there will be less opportunity for collaboration and for building efficiencies across the ecosystem. The federal hiring process is challenging, and there are many known bottlenecks that cause delays. If agencies don’t leverage opportunities to work together, these bottlenecks will multiply, impacting staff who need to hire and especially permitting and/or HR teams who are understaffed, which is not uncommon. Additionally, building applicant pools to have access to highly qualified candidates is time consuming and not scalable without more consistency.

Tracking workforce metrics and hiring progress is critical to informing these talent decisions. Yet, the tools available today are insufficient for understanding and identifying gaps in the federal permitting workforce. The uncertainty of long-term, sustainable funding for permitting talent only adds more complexity into these talent decisions. While there are many challenges, we have identified solutions that stakeholders within this ecosystem can take to build the permitting workforce for the future.

There are six key recommendations for addressing permitting workforce capacity outlined in the table below. Each is described in detail with corresponding actions in the Solutions section that follows. Our recommendations are for the Permitting Council staff, Deputy Secretaries, CERPOs, OPM, CHCOs, OMB, and Congress.

High-level Recommendations

Enhance the Permitting Council’s Authority to Improve Processes and Workforce Collaboration	Congress needs to give the Permitting Council staff greater authority to standardize permitting practices, direct better permitting outcomes, and serve as a central authority for mandating permitting performance.
Build Efficient Permitting Teams and Standardize Roles	The Permitting Council staff, Deputy Secretaries, CERPOs, OMB, and the CHCO Council should improve the performance and consistency of permitting processes by establishing standards in permitting team roles and configurations to support cross-agency collaboration and drive continuous improvements.
Improve Workforce Strategy, Planning, and Decisions through Quality Workforce Metrics	OPM, OMB, the CHCO Council, and Permitting Council staff need to accurately gather and report on hiring metrics for talent surges and workforce metrics by domain.
Invest in Professional Development and Early Career Pathways	The Permitting Council staff, Deputy Secretaries, and CERPOs should create more development opportunities and early career pathways for civil servants.
Improve and Invest in Pooled Hiring for Common Positions	OPM, CHCOs, OMB, Permitting Council staff, Deputy Secretaries, and CERPOs should improve and make joint announcements, shared position descriptions, assessments, and certificates of eligibles for common positions a standard practice.
Improve Human Resources Support for Hiring Managers	The CHCO Council, OPM, CERPOs, and the Permitting Council staff need to test new HR resourcing models to implement hiring best practices and offer additional support to hiring managers.

Solutions

The six solutions described below include an explanation of the problem and key actions our signal stakeholders (Permitting Council staff, Deputy Secretaries, CERPOs, OPM, CHCOs, OMB, and Congress) can take to build permitting workforce capacity. The table in the appendix specifies the stakeholders responsible for each recommendation.

Enhance the Permitting Council’s Authority to Improve Permitting Processes and Workforce Collaboration 

Permitting process, performance, and talent management cut across agencies and their bureaus—but their work is often disaggregated by agency and sub-agency, leading to inefficient and unnecessarily discrete practices. While the Permitting Council plays a critical coordinating role, it lacks the authority and accountability to direct and guide better permitting outcomes and staffing. There is no central authority for influencing and mandating permitting performance. Agency-level CERPOs vary widely in their authority, whereas the Permitting Council is uniquely positioned for this role. Choosing to overlook this entity will lead to another interagency workaround. Congress needs to give the Permitting Council staff greater authority to improve permitting processes and workforce collaboration. 

1. Enhance Permitting Council Authority for Improved Performance: Enhance provisions in FAST-41 and IRA by passing legislation that empowers the Permitting Council staff to create and enforce consistent performance criteria for permitting outcomes, permitting process metrics, permitting talent acquisition, talent management, and permitting teams KPIs.
2. Enhance Permitting Council Authority for Interagency Coordination: Empower the Permitting Council staff to manage interagency coordination and collaboration for defining permitting best practices, establishing frameworks for permitting, and reinforcing those frameworks across agencies. Clarify the roles and responsibilities between Permitting Council staff, Deputy Secretaries, CERPOs, and the Council on Environmental Quality (CEQ).
3. Assign Responsibility for Tracking Changes and Providing Guidance for Permitting Practices: Assign the Permitting Council staff in coordination with OMB responsibility for tracking changes and providing guidance on permitting practices in response to recent and ongoing court rulings that change how permitting outcomes are determined (e.g., Loper Bright/Chevron Deference, CEQ policies, etc.).
4. Provide Permitting Council staff with Consistent Funding: Either renew components of IRA and/or IIJA funding that enables the Council to invest in agency technologies, hiring, and workforce development, or provide consistent appropriations for this.
5. Enhance CERPO Authority and Position CERPOs for Agency-Wide and Cross-Agency Permitting Actions: Expand CERPO authority beyond the FAST-41 Act to include all permitting work within their agency. Through legislation, policy, and agency-level reporting relationships (e.g., CERPO roles assigned to the Secretary’s office), provide CERPOs with clear authority and accountability for permitting performance. 

Build Efficient Permitting Teams and Standardize Roles

In our research, we interviewed one program manager who restructured their team to drive efficiency and support continuous improvement. However, this is not common. Rather, there is a lack of standardization in roles engaged in permitting teams within and across agencies, which hinders collaboration and prevents efficiencies. This is likely driven by the different roles played by agencies in permitting processes. These variances are in opposition to shared certifications and standardized job descriptions, complicate workforce planning, hinder staff training and development, and impact report consistency. The Permitting Council staff, Deputy Secretaries, CERPOs, OMB, and the CHCO Council should improve the performance and consistency of permitting processes by establishing standards in permitting team roles and configurations to support cross-agency collaboration and drive continuous improvements.

1. Characterize Types of Permitting Processes: Permitting Council staff should work with Deputy Secretaries, CERPOs, and Permitting Program Team leaders to categorize types of permitting processes based on project “footprint”, complexity, regulatory reach (i.e., regulations activated), populations affected and other criteria. Identify the range of team configurations in use for the categories of processes.  
2. Map Agency Permitting Roles: Permitting Council staff should map and clarify the roles played by each agency in permitting processes (e.g., sponsoring agency, contributing agency) to provide a foundation for understanding the types of teams employed to execute permitting processes.
3. Research and Analyze Agency Permitting Staffing: Permitting Council staff should collaborate with OMB to conduct or refine a data call on permitting staffing. Analyze the data to compare the roles and team structures that exist between and across agencies. Conduct focus groups with cross agency teams to identify consistent talent needs, team functions, and opportunities for standardization.
4. Develop Permitting Team Case Studies: Permitting Council staff should conduct research to develop a series of case studies that highlight efficient and high performing permitting team structures and processes.
5. Develop Permitting Team Models: In collaboration with Deputy Secretaries and CERPOs, Permitting Council staff should develop team models for different agency roles (i.e., sponsor, lead agency, coordinating agency) that focus on driving efficiencies through process improvements and technology, and develop guidelines for forming new permitting teams.
6. Create Permitting Job Personas: In collaboration with Deputy Secretaries and CERPOs, Permitting Council staff should develop personas to showcase the roles needed on each type of permitting team and roles, recognizing that some variance will always remain, and the type of hiring authority that should be used to acquire those roles (e.g., IPA for highly specialized needs). This should also include new roles focused on process improvements; technology and data acquisition, use, and development; and product management for efficiency, improved customer experience, and effectiveness.
7. Define Standardized Permitting Roles and Job Analyses: With the support of Deputy Secretaries and CERPOs, Permitting Council staff should identify roles that can be standardized across agencies based on the personas, and collaborate with permitting agencies to develop standard job descriptions and job analyses.
8. Develop Permitting Practice Guide: In collaboration with Deputy Secretaries and CERPOs, Permitting Council staff should develop a primer on federal permitting practices that explains how to efficiently and effectively complete permitting activities.
9. Place Organizational Strategy Fellows: Permitting Council staff should hire at least one fellow to their staff to lead this effort and coordinate/liaise between permitting teams at different agencies.
10. Mandate Permitting Hiring Forecasts: Permitting Council staff should collaborate with the CHCO Council to mandate permitting hiring forecasts annually with quarterly updates.
11. Revise Permitting Funding Requirements: Permitting Council staff should include requirements for the adoption of new team models and roles in the resources and coordination provided to permitting agencies to drive process efficiencies.

Improve Workforce Strategy, Planning, and Decisions through Quality Workforce Metrics

Agency permitting leaders and those working across agencies do not have the information to make informed workforce decisions on hiring, deployment, or workload sharing. Attempts to access accurate permitting workforce data highlighted inefficient methods for collecting, tracking, and reporting on workforce metrics across agencies. This results in a lack of transparency into the permitting workforce, data quality issues, and an opaque hiring progress. With these unknowns, it becomes difficult to prioritize agency needs and support. Permitting provided a purview into this challenge, but it is not unique to the permitting domain. OPM, OMB, the CHCO Council, and Permitting Council staff need to accurately gather and report on hiring metrics for talent surges and workforce metrics by domain.

1. Establish Permitting Workforce Data Standards: OPM should create minimum data standards for hiring and expand existing data standards to include permitting roles in employee records, starting with the Request for Personnel Action that initiates hiring (SF52). Permitting Council staff should be consulted in defining standards for the permitting workforce.
2. Mandate Agency Data Sharing: OPM and OMB should require agencies share personnel action data; this should be done automatically through APIs or a weekly data pull between existing HR systems. To enable this sharing, agencies must centralize and standardize their personnel action data from their components.
3. Create Workforce Dashboards: OPM should create domain-specific workforce dashboards based on most recent agency data and make it accessible to the relevant agencies. This should be done for the permitting workforce.
4. Mandate Permitting Hiring Forecasts: The CHCO Council should mandate permitting hiring forecasts annually with quarterly updates. This data should feed into existing agency talent management/acquisition systems to track workforce needs and support adaptive decision making.

Invest in Professional Development and Early Career Pathways

There are few early career pathways and development opportunities for personnel who engage in permitting activities. This limits agencies’ workforce capacity and extends learning curves for new staff. This results in limited applicant pools for hiring, understaffed permitting teams, and limited access to expertise. More recently, many of the roles permitting teams hired for were higher level GS positions. With a greater focus on early career pathways and development, future openings could be filled with more internal personnel. In our research, one hiring manager shared how they established an apprenticeship program for early career staff, which has led 12 interns to continue into permanent federal service positions. The Permitting Council staff, Deputy Secretaries, and CERPOs should create more development opportunities and early career pathways for civil servants.

1. Invest in Training to Upskill and Reskill Staff: The Permitting Council staff should continue investing in training and development programs (i.e., Permitting University) to upskill and reskill federal employees in critical permitting skills and knowledge. Leveraging the knowledge gained through creating standard permitting team roles and collaborating with permitting leaders, the Permitting Council staff should define critical knowledge and skills needed for permitting and offer additional training to support existing staff in building their expertise and new employees in shortening their learning curve.
2. Allocate Permitting Staff Across Offices and Regions: CERPOs and Deputy Secretaries should implement a flexible staffing model to reallocate staff to projects in different offices and regions to build their experience and skill set in key areas, where permitting work is anticipated to grow. This can also help alleviate capacity constraints on projects or in specific locations.
3. Invest in Flexible Hiring Opportunities: CERPOs and Deputy Secretaries should invest in a range of flexible hiring options, including 10-year STEM term appointments and other temporary positions, to provide staffing flexibility depending on budget and program needs. Additionally, OPM needs to redefine STEM to include technology positions that do not require a degree (e.g., Environmental Protection Specialists).
4. Establish a Permitting Apprenticeship: The Permitting Council staff should establish a 1-year apprenticeship program for early career professionals to gain on-the-job experience and learn about permitting activities. The apprenticeship should focus on common roles shared across agencies and place talent into agency positions. A rotational component could benefit participants in experiencing different types of work.

Improve and Invest in Pooled Hiring for Common Positions

Outdated and inaccurate job descriptions slow down and delay the hiring process. Further delays are often caused by the use of non-skills-based assessments, often self-assessments, which reduce the quality of the certificate list, or the list of eligible candidates given to the hiring manager. HR leaders confront barriers in the authority they have to share job announcements, position descriptions (PDs), classification determinations, and certificate lists of eligible candidates (Certs). Coupled with the above ideas on creating consistency in permitting teams and roles and better workforce data, OPM, CHCOs, OMB, Permitting Council staff, Deputy Secretaries, and CERPOs should improve and make joint announcements, shared position descriptions, assessments, and certificates of eligibles for common positions a standard practice.

1. Provide CHCOs the Delegated Authority to Share Announcements, PDs, Assessments, and Certs: OPM and OMB should lower the barriers for agencies to share key hiring elements and jointly act on common permitting positions by delegating the authority for CHCOs to work together within and across their agencies, including with the Permitting Council staff.
2. Revise Shared Certificate Policies: OPM and OMB should revise shared certificate policies to allow agencies to share certificates regardless of locations designated in the original announcement and the type of hire (temporary or permanent). They should require skills-based assessments in all pooled hiring. Additionally, OPM should streamline and clarify the process for sharing certificates across agencies. Agencies need to understand and agree to the process for selecting candidates off the certificate list.
3. Create a Government-wide Platform for Permitting Hiring Collaboration: OPM should create a platform to gather and disseminate permitting job announcements, PDs, classification determinations, job/competency evaluations, and cert. lists to support the development of consistent permitting teams and roles.
4. Pilot Sharing of Announcements, PDs, Assessments, and Certs for Common Permitting Positions: OPM and the CHCO Council should collaborate with the Permitting Council staff to select most common and consistent permitting team roles (e.g., Environmental Protection Specialist) to pilot sharing within and across agencies.
5. Track Permitting Hiring and Workforce Performance through Data Sharing and Dashboards: Permitting Council staff, Deputy Secretaries, and CERPOs should leverage the metrics (see Improve Workforce Decisions Through Quality Workforce Metrics) and data actions above to track progress and make adjustments for sharing permitting hiring actions.
6. Incorporate Shared Certificates into Performance: OPM and the CHCO Council should incorporate the use of shared certificates into the performance evaluations of HR teams within agencies.

Improve Human Resources Support for Hiring Managers

Hiring managers lack sufficient support in navigating the hiring and recruiting process due to capacity constraints. This causes delays in the hiring process, restricts the agency’s recruiting capabilities, limits the size of the applicant pools, produces low quality candidate assessments, and leads to offer declinations. The CHCO Council, OPM, CERPOs, and the Permitting Council staff need to test new HR resourcing models to implement hiring best practices and offer additional support to hiring managers.

1. Develop HR Best Practice Case Studies: OPM should conduct research to develop a series of case studies that highlight HR best practices for recruitment, performance management, hiring, and training to share with CHCOs and provide guidance for implementation.
2. Document Surge Hiring Capabilities: In collaboration, the Permitting Council staff and CERPOs should document successful surge hiring structures (e.g., strike teams), including how they are formed, how they operate, what funding is required, and where they sit within an organization, and plan to replicate them for future surge hiring.
3. Create Hiring Manager Community of Practice: In collaboration, the Permitting Council staff and Permitting Agency HR Teams with support from the CHCO Council should convene a permitting hiring manager community of practice  to share best practices, lessons learned, and opportunities for collaboration across agencies. Participants should include those who engage in hiring, specifically permitting hiring managers, HR specialists, and HR leaders.
4. Develop Permitting Talent Training for HR: OPM should collaborate with CERPOs to create a centralized training for HR professionals to learn how to hire permitting staff. This training could be embedded in the Federal HR Institute.
5. Contract HR Support for Permitting: The Permitting Council staff should create an omnibus contract for HR support across permitting agencies and coordinate with OPM to ensure the resources are allocated based on capacity needs.
6. Establish HR Strike Teams: OPM should create a strike team of HR personnel that can be detailed to agencies to support surge hiring and provide supplemental support to hiring managers.
7. Place a Permitting Council HR Fellow: The Permitting Council should place an HR professional fellow on their staff to assist permitting agencies in shared certifications and build out talent pipelines for the key roles needed in permitting teams.
8. Establish Talent Centers of Excellence: The CHCO Council should mandate the formation of a Talent Center of Excellence in each agency, which is responsible for providing training, support, and tools to hiring managers across the agency. This could include training on hiring, hiring authorities, and hiring incentives; recruitment network development; career fair support; and the development of a system to track potential candidates.

Next Steps

These recommendations aim to address talent challenges within the federal permitting ecosystem. As you can see, these issues cannot be addressed by one stakeholder, or even one agency, rather it requires effort from stakeholders across government. Collaboration between these stakeholder groups will be key to realizing sustainable permitting workforce capacity.

Federal hiring ebbs and flows with changes in administrations, legislative mandates, attrition, hiring freezes, and talent surges. The lessons and practices in this blog post series explore the earlier stages of the hiring process. Though anchored in our permitting talent research, the lessons are universal in their application, regardless of the hiring environment. They can be used to accelerate and improve hiring for a single or multiple open positions, and they can be kept in reserve during hiring downturns.

Assessing, Selecting, and Onboarding the Successful Candidate

Previously we described the end-to-end hiring process, the importance of getting hiring right from the start, and how sharing resources speeds hiring. This post focuses on the last two phases of the process: Assessment and Offer. While these phases include eight steps, we’ve narrowed down our discussion to five key steps:

1. Close Job Opportunity Announcement and Evaluate Applicants
2. Review Certificate of Eligibles, Conduct Interviews, and Make Selection
3. Make Tentative Job Offer and Receive Acceptance
4. Initiate Investigation at the Appropriate Level (Security Check)
5. Make Official Offer and Enter on Duty (Onboard New Hire)

Our insights shared in this post are based on extensive interviews with hiring managers, program leaders, staffing specialists, workforce planners, and budget professionals as well as on-the-job experience. These recommendations for improvement focus on process and do not require policy or regulatory changes. They do require adoption of these practices more broadly throughout HR, program, and permitting managers, and staff. These recommendations are not unique to permitting; they apply broadly to federal government hiring. These insights should be considered both for streamlining efforts related to environmental permitting, as well as improving federal hiring.

Breaking Down the Steps

For each step, we provide a description, explain what can go wrong, share what can go right, and provide some examples from our research, where applicable.

Close Job Opportunity Announcement and Evaluate Applicants 

Once the announcement period has ended, job announcements close, and HR begins reviewing the applications in the competitive hiring process. HR reviews the applications, materials provided by the applicants, and the completed assessments, which vary depending on the assessment strategy. This selection process is governed by policies in competitive examination and will be determined by whether the agency is following category rating, rule of many, or other acceptable evaluation methods.

If the agency is using a different hiring authority or flexibility, this step will change. For example, if the agency has Direct Hire Authority (DHA), they may not need to provide a rigorous assessment and may be able to proceed to selection after a review of resumes. Most agencies will still engage in some assessment process for these types of positions. After the applicants are evaluated, HR issues a Certificate of Eligibles (or “cert list”) with the ranking of the applicants from which the hiring manager can select, including the implementation of Veterans preference. 

What Can Go Wrong

• Most applicant assessments rely on the resume review and candidate self-assessment. Applicants who understand the process rate themselves as highly qualified on all aspects of the job, resulting in a certificate list with unqualified applicants at the top. Agencies are now required by law to use skills-based assessments in the Chance to Compete Act and previous Executive Order guidance to prevent this, but the adoption process will be slow.
• HR staffing resources are frequently strained to immediately review applications and resumes causing delays. This causes applicant and hiring manager dissatisfaction and possibly a loss of attractive, qualified applicants. Within permitting, hiring managers have been struggling to find talent with the required expertise, especially specialized or niche expertise, and this loss is a critical setback.
• Frequently HR specialists do not consult with the program managers to gain a deep understanding of what they’re looking for in a resume or application and rely solely on their interpretation of the qualifications listed in the position description. This can result in poor quality applicants referred to the hiring manager. 

What Can Go Right

• If the recruiters and hiring manager have engaged in effective recruiting, applicant quality is likely to be quite high. This eases the HR’s job of finding strong applicants.
• With a strong applicant pool, HR specialist can limit the number of applicants they consider and/or limit how long the job announcement is open. This will expedite the process, as the assessment will be faster. Rigorous assessments reduce the likelihood of unqualified applicants making it to the certificate list. A hiring manager who insists on a skills-based assessment will likely move forward with a successful hire. Using subject-matter experts in a Subject Matter Expert Qualifications Assessment (SME-QA) or similar assessment process can result in a strong list of applicants, and it has the added benefit of building familiarity by engaging the employee’s future peers in the process.

Review Certificate of Eligibles, Conduct Interviews, and Make Selection 

HR sends a Certificate of Eligibles (certificate list) to the hiring manager that ranks the applicants who passed the assessment(s). Under competitive hiring rules (as opposed to some of the other hiring authorities), hiring managers are obligated to select from the top of the Certificate of Eligibles list, or those considered to be most qualified. 

The Veterans preference rules also require that qualified Veterans move to the top of the list and must be considered first. Outside of competitive hiring and under other hiring authorities, the hiring manager may have more flexibility in the selection of candidates. For example, direct hire authority allows the hiring manager to make a selection decision based on their own review of resumes and applications. 

If determined as part of the assessment process beforehand, the hiring manager may choose to conduct final interviews with the top candidates. In this case, the manager then informs HR of their selection decision. 

What Can Go Wrong

• If the hiring manager cannot find an applicant they deem qualified on the certificate list, they inform HR, restart the hiring action, and/or re-post the position, further delaying the process. This happens frequently when the assessment tools default to a self-evaluation, or self-assessment. One Hiring Manager we met needed to request a second certificate list, and this extended the hiring process to nine months.
• Lack of resources in HR or the hiring manager’s program often results in evaluation and selection delays. Top applicants in high demand may take other jobs if the process takes longer than anticipated. This was a concern voiced by hiring managers during our interviews.
• In rare circumstances, agency funding could be uncertain and the budget function could rescind the approval to hire at this stage, frustrating hiring managers, applicants, and HR specialists.

What Can Go Right

• Strong recruiting early and throughout the process results in a strong certificate list with excellent candidates. One permitting agency, following best practice, kept a pipeline of potential candidates, including prior applicants to boost the quality of the applicant pool.
• An effective assessment process weeds out unqualified or unsuitable candidates and culls the list of applicants to only those who can do the job.
• A deep partnership between the HR staffing specialist and the hiring manager in which they discuss the skills and “fit” of the top candidates increases the hiring manager’s confidence in the selection.

Make Tentative Job Offer and Receive Acceptance

HR reaches out to the applicant to make a tentative job offer (i.e., tentative based on the applicant’s suitability determination, outlined below) and asks for a decision from the applicant within an acceptable time frame, which is normally a couple of days to a week. The HR staffing specialist will keep in close contact with the hiring manager and HR officials regarding the status of the candidate accepting the position.

What Can Go Wrong

• The applicant rejects the offer due to a misunderstanding of the job. This could be the location, remote work, or telework availability. In our interviews, we learned that some applicants declined offers because they believed the position was full time or a temporary position that could convert to a full time role, but that was not the case.
• The applicant rejects the offer due to a competing offer at a higher salary or as a result of other financial factors (e.g., relocation expenses). Some participants shared that financial factors had been the reason for some of their declinations.
• The applicant rejects the offer because of how they have been treated throughout the process or delays, which have led them to remain in their current role or accept another position.

What Can Go Right

• The HR specialist and others involved in the hiring process maintain regular communications with the candidate regarding their offer, listens to any concerns they may have about accepting their offer, and works with the hiring manager to correct any misperceptions about the job requirements.
• The HR specialist and the hiring manager understand the financial incentives they can use to negotiate salary, relocation expenses, signing bonuses, and other benefits to negotiate with the candidate. These options are usually agency-, function-, or job-specific.

Initiate Investigation at the Appropriate Level (Security Check)

Different federal occupations require different levels of suitability determinations or security clearances – from simple background checks to make sure the information an applicant provided on their application is accurate to a Top Secret clearance that enables the employee to access sensitive information. Each type of suitability determination has a different time frame needed for a security officer to evaluate the candidate. (Some positions require the security officer to not only interview the candidate, but also interview their friends, relatives, and neighbors.) This takes time during a part of the hiring process when both the candidate with the tentative offer and the hiring manager are anxious to move forward.

Once the candidate selection is made, the HR specialist works with the agency suitability professionals to initiate the background check and clearance process. Agency suitability experts work with the Defense Counterintelligence Security Agency (DCSA) to conduct the determination of the applicant. 

What Can Go Wrong

• Applicants who have never applied for a federal job may be unfamiliar with their responsibilities during the suitability determination. If they do not fill out the forms properly, this causes delays, especially when the applicant is slow to respond.
• If the candidate does not know how long the suitability determination will take or what is involved in the process, the lack of transparency may create uncertainty and/or frustration among the applicant. Furthermore, if the candidate is not kept informed on where they are in the process or what to expect next, they may get discouraged and decline the tentative offer.
• Delays in scheduling fingerprinting appointments or access to fingerprinting facilities can also lengthen the time for the suitability determination.

What Can Go Right

• The hiring manager, HR specialist, and suitability experts work together to ensure the candidate knows where they are in the process and what is expected of them through frequent check-ins and progress tracking.
• Offering applicants a range of options for fingerprinting, including the opportunity to go to a third party vendor for prints. This can enable fast digital uploads within 24 hours (applicant may have to pay for third-party services).
• Hiring managers and HR specialists leverage the DCSA resources and tools, including the PDT Tool to determine the level of background check needed for their role.
• The Suitability manager uses a case management system to track and maintain all suitability requests. This will help ensure nothing is lost, and system notifications can help keep the process on track by requesting applicants, hiring managers, and HR specialists complete their tasks in a timely manner. One interview participant highlighted this as critical to the timeliness of the suitability process.

Make Official Offer and Enter on Duty (Onboard New Hire)

The last step in the hiring process is administering the final offer of employment, identifying and Entry on Duty date, and onboarding the new employee. HR staff usually shepherd the new employee through this step. The hiring manager, administrator, or a peer mentor frequently assists the new employee in making sure the employee understands what they need to do to begin contributing to the agency.

What Can Go Wrong

• The candidate declines the final offer of employment due to delays or dissatisfaction with their experience during the hiring process.
• Frequently, onboarding consists of filling out online forms, paperwork to register the new employee in the various agency systems, and required compliance training. Minimal attention is spent on their work and how it connects to the agency mission.
• All too often, the new employee does not receive their computer equipment, phone, or other resources necessary for them to do their jobs in a timely manner. These delays degrade the initial employee experience.

What Can Go Right

• HR and hiring manager program staff stay in constant connection with the candidate as they accept the job and start the onboarding process, ensuring that the early employee experience is positive. This includes not only the administrative activities but also introductions to the agency and the work they will be doing.
• Program managers and administrative staff can work with IT functions and other departments to make sure the new employee has the equipment and resources needed to start their job successfully.
• The hiring manager establishes their relationship with the new employee during onboarding, creating a positive atmosphere for the employee by clearly articulating expectations.

Conclusion

Hiring success depends heavily on the broader hiring ecosystem. There are many stakeholders (e.g., leadership, budget, program, HR, suitability, applicant) who play a crucial role; collaboration and communication is important for both a timely and successful hire. Adoption of best practices across the ecosystem will help to improve hiring outcomes, reduce process delays, and enhance the overall hiring experience for all parties involved. The best practices outlined in our blog post series provide a guide to better navigate the hiring process. 

The overall intent of hiring is to improve the performance of the federal program or function. New employees expand the organization’s workforce capacity and bring capabilities needed to achieve the mission. A skilled, prepared, and engaged federal employee can have an outsized impact on a program’s success.

In the machinery of national security decision-making, innovation is the first casualty of consensus. At the heart of this process lies the National Security Council’s multi-layered committee structure to develop policy recommendations for the President. While this process ensures broad interagency coordination, it also means that agencies can effectively veto options that challenge their interests. The result is that the President often only sees consensus recommendations that preserve institutional status quo, rather than the full range of viable policy options that might better serve national interests. The new National Security Advisor, Congressman Mike Waltz, should reshape the NSC process to provide better foreign policy advice for the President.

The Current Process: Design vs. Reality

The NSC’s decision-making process follows a carefully structured path. At the working level, Interagency Policy Committees (IPCs) bring together Assistant Secretary-level officials and subject matter experts to develop initial policy options. These recommendations then move to the Deputies Committee, composed of deputy heads of relevant agencies, for refinement and further analysis. The Principals Committee, consisting of Cabinet-level officials, then reviews and shapes final recommendations before they reach the President through the National Security Advisor.

In theory, this layered approach should ensure thorough vetting while preserving diverse viewpoints. In practice, however, the system often produces the opposite effect. Each level of review tends to narrow options rather than expand them, as agencies work to protect their institutional interests and avoid conflict with other departments.

The Consensus Trap

The emphasis on interagency consensus, while well-intentioned, has become a structural impediment to bold or innovative policy options. Former National Security Advisor H.R. McMaster warned about this in his book Battlegrounds stating, “Presenting a single option designed to either tell the President what he or she wants to hear, or to present the consensus position of the cabinet is doing him or her a disservice.” He argued that it is “important to provide the President with multiple options.”

When every agency effectively holds veto power over proposals, the path of least resistance becomes maintaining existing approaches with minor modifications. This dynamic is particularly problematic in rapidly evolving security situations where status quo responses may be inadequate.

Consider, for example, how options that might gore the ox of the Defense Department’s budget are quietly culled, or how proposals that ruffle the diplomatic feathers of the State Department rarely survive the process. While both of the Department’s perspectives may have merit, the current system often leads to their mutual neutralization, rather than producing either a creative outcome or an advancement of an option with dissents.

The Cost of Lost Alternatives

The consequences of this consensus-driven approach are significant. The President is often presented with artificially limited choices, typically framed as minor variations on existing policy rather than genuinely distinct alternatives. This narrowing of options can be particularly problematic in crisis situations where innovative approaches might be most needed. 

More concerning is what the President doesn’t see: options that challenge conventional wisdom, propose significant departures from existing policy, or require substantial institutional compromise or change. These alternatives, while potentially valuable, often don’t survive the gauntlet of interagency review.

Potential Reforms

During the Obama NSC we identified several reforms that could help address these structural limitations. Some of these ideas included:

1. Mandate a presentation of competing options: Require that multiple, genuinely distinct policy alternatives reach the President’s desk, even if they don’t have unanimous agency support.
2. Create independent analysis channels: Borrow the Intelligence Community’s Red Cell process and establish mechanisms for policy options to reach senior decision-makers without requiring consensus at every level.
3. Strengthen the NSC staff’s role: Empower NSC staff to develop independent options that might challenge agency preferences.
4. Reform the Deputies Committee process: Modify procedures to focus on developing multiple viable options rather than driving toward consensus.

The NSC’s current decision-making process, while sophisticated in design, often fails to provide the President with the full range of policy options needed for effective decision-making. The system’s emphasis on consensus, while valuable for implementation, has become an impediment to innovative policy development.

Reform is possible without dismantling the valuable coordination functions of the current system. By modifying procedures to ensure that diverse options reach senior decision-makers, the NSC can better fulfill its core mission: providing the President with the best possible range of choices for addressing national security challenges.

The goal isn’t to eliminate interagency coordination but to prevent it from unduly constraining presidential options. In an increasingly complex security environment, the President needs access to the fullest possible range of policy alternatives, not just those that survive the consensus-building process.

Jim Thompson is the Director of Government Capacity at the Federation of American Scientists. He served as a Director on both President Obama’s and President Biden’s National Security Councils.

“There really are fewer unicorn positions out there than we all imagined” – Bob Leavitt, HHS CHCO on shared PDs and certificates for common positions

Creating a job announcement that attracts high quality applicants is critical to the hiring process. For hiring managers, finding a balance between identifying the unique details of the position and managing the time and resources required is a challenge. When defining a position, there are many potential “off-ramps.” While these diversions are sometimes necessary, they often result in significant time delays and demand scarce resources from both hiring managers and HR staff. Improvements over the past few years offer hiring managers opportunities to accelerate the process while improving applicant quality, primarily done through collaboration within and across agencies that requires a level of standardization.

In our previous blog posts, we outlined the hiring process and dove into the first phase – Getting Hiring Right from the Start. This post discusses the second phase of the process: planning for and announcing the job. This phase includes four steps:

1. Review Position Description and Confirm Job Analysis 
2. Classify or Reclassify the Position
3. Confirm Job Analysis and Assessment Strategy
4. Create and Post the Job Opportunity Announcement (JOA)

Our insights shared in this post are based on extensive interviews with hiring managers, program leaders, staffing specialists, workforce planners, and budget professionals as well as on-the-job experience. These recommendations for improvement focus on process and  do not require policy or regulatory changes. They do require adoption of these practices more broadly throughout HR, program, and permitting managers, and staff. Additionally, our insights here are not unique to permitting, rather they apply broadly to federal government hiring. These insights should be considered both for streamlining efforts related to environmental permitting, as well as improving federal hiring.

Breaking Down the Steps

For each step in this phase, we provide a description, explain what can go wrong, share what can go right, and provide some examples from our research, where applicable. 

Review Position Description and Confirm Job Analysis

The Position Description (PD) is core to the hiring process. It describes the occupation, grade level, job duties, qualifications, and any special skills needed for the job and agency. In hiring, it is used to develop the job announcement, review the position’s classification, and establish a  foundation for assessing candidates. Outside of hiring, it is used in performance management, position management, probation period evaluation, and serves as a reference for disciplinary action. 

At this step, a hiring manager reviews the position description to make sure it is an accurate, current depiction of the job requirements, which may require a review of the past job analysis, or the evaluation of the knowledge, skills, abilities, behaviors, and experience needed for the positions (i.e., the competencies). The PD can be inaccurate due to dynamic changes in the job: core duties, technologies used, process changes, and supervisory responsibilities. These updates can range from simple wording changes to major changes that require additional work. 

In our interviews, we heard from hiring managers and HR specialists that updating position descriptions had been a challenge and bottleneck in their hiring process. One hiring manager shared that they chose to not change their positions even if they wanted a different role because of the anticipated time delays. Other participants shared that they have begun moving towards standardized PDs within their agency to reduce redundancies and enable more collaboration.

What Can Go Wrong

• Based on hiring manager feedback to the HR specialist, a significantly out-of-date PD can result in major revisions that require a job analysis and/or reclassification of the position. This can delay the hiring process by weeks, or even months. If the grade level or other key aspects of the position need to be changed, the position requisition (SF-52 form) needs to be revised, adding even more time. 
• Overzealous staffing specialists or classifiers may perceive major job changes where they do not exist in practice, causing delays for additional reviews and revisions.
• Too much specificity in job task descriptions will require additional job analyses, causing further delays. Whereas not enough specificity provides insufficient guidance for developing the assessment strategy, JOA, and other management actions dependent on the PD (e.g., performance management, development plans, or disciplinary action).

What Can Go Right

• With permission from their Chief Human Capital Office (CHCO) office, a hiring manager can use a current PD from elsewhere in the agency that accurately describes the job. A number of agencies have created PD libraries that bring together common PDs from across the organization. One HR Leader we interviewed described having a library of available positions that hiring managers are encouraged to look through when creating a new position. Hiring managers can even include specialized skills in an existing PD to augment the fundamental job duties, avoiding reclassification.
• Hiring managers can offer flexibility in location, where possible. Based on our interviews, agencies are seeing greater success attracting strong applicants with flexible locations, remote work, or telework options.
• The HR staffing specialist can search for and find a shared certificate of eligibles (i.e., a list of eligible candidates) for their PD already available through their own agency HR talent systems or through the USAJOBS Agency Talent Portals. As long as the job and grade match, the hiring manager can bypass much of the hiring process and move quickly to identifying applicants. 
• Many agencies require managers to review and if needed, revise position description every year during the performance management process. This can make sure the PD is ready to go for the hiring process. In our interviews, we heard that this is required, but may not be regularly completed.

Classify/Reclassify the Position

Position classification is a structured process in every Cabinet agency in which an expert assesses the requirements of the job by evaluating factors such as knowledge, skills, abilities, complexity, and supervisory controls/responsibilities. The process is initiated when a PD is deemed inaccurate due to changes in the role. The HR staffing specialist will ask a classification expert to assess the role. This is done by reviewing the PD, existing job analyses, past classifications, and classification audits. They will also gather and review data from the hiring manager and others working in similar roles. Based on their assessment, the classifier can recommend changes to the grade level and/or the occupational series. These changes could be simple revisions or a more extensive reclassification. This process can take days or weeks to complete and can delay the hiring process significantly.

What Can Go Wrong

• HR staff and classifiers sometimes do not explain the need for classification and its benefits. This makes the process opaque and leaves the hiring manager wondering how long it will take to complete.

• HR staffing specialists and classifiers vary widely in how they apply the classification standards. Some seek greater specificity, and therefore insist on a full classification review when it may not be needed.
• Agency HR functions frequently lack workforce capacity for classification and job analyses. As a result, they have to prioritize requests, which can cause further delays.

What Can Go Right

• Collaboration and transparency between hiring managers, staffing specialists, and classifiers can lead to rapid approval of a PD and classification review. If there cannot be a quick approval, this close engagement leads to clearer expectations and realistic timelines.
• If the same position, at the same grade level, has recently completed a classification audit in a different part of the agency, the hiring team can use it. This can also be done across agencies with CHCO approval.
• Hiring managers who invest time to understand the position well and articulate the roles, duties, relationships, and complexity to the classifier can improve the outcomes and make the process more efficient. 
• Agencies that lack classification resources frequently engage with outside contractors or retired annuitants to provide more capacity for the classification and job analysis work. 

Develop Assessment Strategy

A critical, but sometimes overlooked step in hiring is developing the assessment strategy for the position. This determines how the HR staff and hiring manager will evaluate applicants and identify candidates for the certificate list, or the list of eligible applicants. The strategy needs to assess candidates based on the defined job duties and position criteria, and it plays a major role in determining the quality of candidates.The assessment strategy consists of three parts:

1. How job applications and resumes are reviewed
2. How the applicants demonstrate the required skills and abilities
3. How the hiring manager makes the final selection

Recently, agencies have moved toward evaluating applicants by assessing their skills, spurred on by the Executive Order and guidance on skills-based assessments and now reinforced by the Chance to Compete Act. This shift aims to move away from relying on education and/or self-assessments. Skills-based assessments can include online tests, skills-based simulation exercises, simulated job tryouts, as well as the Subject Matter Expert Qualifications Assessment (SME-QA) process developed by OPM and USDS/OMB. This improves the quality of assessments and aims to ensure the candidates on the certificate list are qualified for the job.

What Can Go Wrong

• If a hiring manager and HR staffing specialist bypass this step, this frequently results in a certificate list with unqualified candidates. Without a strategy, many default to using a resume review and self-assessments. Unfortunately, our research indicated that many agencies are still using self-assessments.
• Most of the time, resume screening is left solely to the HR staff. Lack of alignment between HR specialists and hiring managers on essential qualifications results in an inaccurate screening, leading unqualified candidates to make the cut. Too often, HR staff will only screen applications for the exact phrases that appear in the job announcement. Applicants know this and revise their documents accordingly.
• When a skills-based assessment does not exist for the position and specific grade level, it needs to be created. This takes time and expert resources, thus delaying the hiring process.
• Inaccurate resume screenings and self-assessments frequently lead to a high number of unqualified Veterans making the top of the certificate list due to Veterans preference. Unfortunately, this leads to a negative perception of Veterans preference. 

What Can Go Right

• Working with HR staffing specialists to find existing assessments can save time and improve candidate selection quality. In addition, USA Hire, Monster, and other HR talent acquisition platforms are offering compendiums of assessment strategies and tools that can be accessed, usually for free. 
• Deep engagement between hiring managers, staffing specialists, and assessment professionals in developing an assessment strategy and selecting tools pays off. This can lead to enhanced resume and application screening, stronger alignment between candidate and position needs, and higher quality certificate lists of eligible candidates.
• Engagement with staffing specialists and assessment experts can also help the hiring manager understand and make tradeoff decisions related to the speed and ease of administration. For example, an online test may be easier to utilize, while embedding Subject Matter Experts into the selection process may increase the efficacy.

Create and Post Job Opportunity Announcement

Though creating and posting the JOA is relatively straightforward, lack of attention to this step can reduce the number of attractive candidates. The HR staffing specialist usually creates the JOA in consultation with the hiring manager to ensure that it not only accurately reflects the job duties, but also sells the job to potential applicants. The JOA is an opportunity to showcase the importance of the role and its contribution to the agency’s mission. 

The JOA outlines applicant eligibility, job duties, job requirements (e.g., conditions of employment, qualifications, etc.), education (if needed), assessment strategy, and application requirements. It also lists the occupation, grade level, location, and other details. See USAJOBS for examples.

What Can Go Wrong

• Some hiring managers and staffing specialists are under the misapprehension that the JOA needs to contain the exact language from the PD in both the title and description. This can include jargon and terms that are unfamiliar to those not within the organization. 
• Unintentionally, a hiring manager may lock the job location in a specific city or metropolitan area when the job could be remote or in multiple locations. To correct this, the JOA will need to be taken down and re-posted if no suitable applicants can be found.

What Can Go Right

• JOAs need to be tailored to the target applicants, and working with those currently in the job or in a related-discipline can help in crafting an attractive JOA.
• Using plain language in the job title and description instead of jargon will attract more candidates. OPM has published plain language guidance to help hiring managers and staffing specialists do this effectively.
• Earlier in the hiring process, successful hiring managers and staffing specialists define recruiting and sourcing strategies to attract candidates. This can include posting the job on alternative sites (e.g., agency websites, LinkedIn, Handshake, Indeed, etc.) in addition to USAJOBS to reach a broader audience. One agency’s HR team described leveraging multiple platforms for outreach and was able to successfully recruit many qualified candidates for their open roles. Strategies can also include asking hiring managers, peers, agency leaders, and recruiters to message highly qualified candidates to expand the applicant pool and bring in more qualified applicants. 

Conclusion

Throughout this phase of work, there are many actions hiring managers and staffing specialists can take to streamline the process and improve the quality of eligible candidates. Most importantly, hiring managers and staffing specialists can collaborate within and across agencies to expedite and simplify the process. Using an existing PD from another part of the agency, finding an assessment tool for the job and grade level, pooling resources on a common job announcement with a peer, and using shared certificates to move straight to a job offer are all ways you can find a well-qualified hire faster. More tips and techniques to improve hiring can be found in OPM’s Workforce of the Future Playbook.

Changes that can be made to improve efficiency and promote collaboration. These center on moving to standardized PDs, where appropriate, leveraging shared certifications with those standardized PDs, and investing in skills-based assessments, which are now required by law in the Chance to Compete Act. 

Making these actions common practice is one of the key challenges to improving hiring. The Executive Order on skills-based hiring states “in light of today’s booming labor market, the Federal government must position itself to compete with other sectors for top talent.” It is critical we take advantage of these collaboration tools that can improve the hiring experience for all those involved.