Everything You Need to Know (and Ask!) About OPM’s New Schedule Policy/Career Role: Oversight Resource for OPM’s Schedule Policy/Career Rule
In February 2026, the Office of Personnel Management finalized a rule creating Schedule Policy/Career, a new category for certain career federal positions they deem as “policy-influencing.”
When the rule was initially proposed, FAS raised concerns that removing civil servant employment protections could place unnecessary and undesirable political pressure on highly specialized scientific and technical career professionals serving in government. While we appreciate the Administration’s revisions (such as those that clarify competitive service status), important questions remain about how the rule will be implemented in practice, and how it may affect agency operations, workforce motivation, and mission delivery. This is a complex change to a long-standing system, with significant implications for thousands of current and future public servants – with great potential for unintended consequences. Congress has both a responsibility and opportunity to understand the rule’s intent, implementation, and impacts as it works constructively to shape a better federal workforce system that meets the needs of the country.
This resource is designed to help Congressional members and staff (and other oversight bodies) with cross-cutting and agency oversight roles understand what implementation could look like, where discretion lives in implementation, what changes or risks may emerge over time, and what questions may be most useful to ask in oversight activities such as hearings, briefings, letters, commissioned reports, and GAO audits. Potential areas to watch and requests are aimed at specific implementation periods, as part ongoing engagement with individual agencies, or as part of more holistic review, with the goal of supporting practical, evidence-based oversight as agencies put the rule into effect.
Background
Under the rule, Schedule P/C positions remain career, merit-based roles, but employees in Schedule P/C roles:
- Move from the competitive service to the excepted service, with no appeal for such transfers
- Lose Chapter 43 (performance) and Chapter 75 (adverse action) due process protections under Title 5
- No longer have MSPB appeal rights
- Become effectively at-will for purposes of removal
- Retain protections from prohibited personnel practices (PPP) enforced internally instead of the U.S. Office of Special Counsel (OSC)
Importantly, career staff who had competitive status can transfer to a non-Schedule P/C role and regain competitive service protections. Staff who are hired into Schedule P/C roles under the merit system can likewise gain competitive status after 2 years and acquire competitive service protections if they move out of Schedule P/C.
This rule gives agencies significantly more authority over certain career policy roles. Whether that authority improves accountability or creates new risks depends almost entirely on how agencies interrupt and apply it.
If you’re interested in….
What the rule actually changes (and what it doesn’t)
Understand
- Schedule P/C are not political appointees. Under the new regulation, schedule P/C roles are policy influencing roles hired through merit processes and who retain their roles across administrations, vs. political appointments, which are selected through the White House and whose tenure ends when a president leaves office.
- The rule primarily changes protections and removal authority for staff moved to Schedule P/C, not hiring – though overseers should stay aware of hiring practices for these roles.
- Schedule P/C roles remain career, merit-filled positions and P/C employees have or can attain competitive service status (but this is worth continued engagement on)
- However, while in P/C roles, employees lose Ch. 43/75 process due process protections and MSPB appeal rights.
Ask agencies (now)
- How are you explaining this change to managers and staff?
- By what criteria will you decide what agency positions are determined to be “policy influencing” for approval by OPM?
- What written guidance have supervisors received?
Watch
- Confusion in agencies about what this is
- Implementers with different interpretations on breadth of the definitions
- Differential discussion of or treatment of Schedule P/C roles beyond this rulemaking
Why it matters: Early confusion or inconsistency may lead to uneven or overbroad designation of roles, uneven treatment across agencies, or morale challenges due to confusion about goals.
What is policy influencing (and what isn’t)
Understand: Agencies are supposed to identify roles based on whether the duties of the position meet the statutory test for being policy influencing – the role, not the person. Agencies are told to consider: roles that:
- Shape, write, or interpret regulations or policy
- Advise senior leaders on policy choices
- Translate presidential or agency priorities into action
- Direct the work of people doing the above
- Sit in policy offices, regulatory offices, or leadership advisory roles
- Have authority to influence how laws and directives are carried out
Agencies should not be considering:
- Performance
- Seniority
- Political beliefs
- Individual behavior
Ask (after agencies have made determinations):
- What criteria did you use to determine a role was policy-influencing?
- Did you conduct a role-by-role analysis? Are there instances where you designated whole offices?
- Which occupational series and functions were included? Were scientists, attorneys, grants officials, or program managers included?
- How did you treat supervisory roles?
- What written justification exists for each position?
Watch:
- Expansion or changing of definitions over time beyond the initial intent
- Use of office-wide or team-wide designations rather than position-specific analysis
- Application of the definition to roles that are primarily technical, scientific, legal, or delivery-oriented rather than policy-shaping
- Variation in interpretation across components or agencies
Why it matters: Good oversight here is about definitions and consistency.
How positions get put on the schedule
Understand: Agencies identify the roles, OPM vets the justification, and the President makes the final decision to place the positions into Schedule Policy/Career.
Ask (after agencies have made designations)
- What process did agencies use to identify positions? Are all such positions designated Schedule P/C?
- Who approved each designation at agencies?
- What documentation supports each decision at agencies?
- How are employees and job applicants notified about placement into Schedule P/C?
- How is OPM ensuring consistency between agencies?
- Given the volume of positions reviewed, what process exists to revisit or correct designations if needed?
Ask (on a rolling basis, or in a GAO review 1 year after implementation)
- How many positions were added after the initial designation?
- What justifications were used later, and did they change in scope?
- Whether the definition of “policy-influencing” is changing?
Watch
- Whether processes remain consistent and well-documented over time
- Patterns of employee questions or concerns about how decisions were made
Why it matters: Much of the practical discretion in this rule rests in how agencies conduct and document this step. Understanding this process is key to meaningful oversight.
What the loss of Chapter 43 & 75 protections really means
Understand: This removes performance improvement periods (PIPs), MSPB appeal rights, and statutory due process (notice and response) removal processes.
Ask
- How will agencies set standards for managers to meet before removing someone on Schedule P/C?
- What internal review happens before a removal decision is finalized?
Watch
- How frequently this authority is used across agencies
- Whether managers express uncertainty about when or how to use this authority
- Differences in how agencies apply this authority
- Situations where employees raise concerns related to PPP protections
Why it matters: The health of the civil service depends on disciplined, fair, and consistent implementation of workforce policies.
What replaces MSPB and OSC review and whistleblower safeguards
Understand: Schedule P/C employees cannot appeal placement or removal through MSPB or file complaints with the OSC. Instead, the rule requires agencies to create and enforce internal protections against Prohibited Personnel Practices (PPPs), including whistleblower reprisal.
Ask (when agencies have made designations)
- What PPP/whistleblower safeguards have you established for Schedule P/C?
- Who reviews allegations of misuse?
- Are these procedures public to employees?
- If an employee is separated, will they have access to these procedures?
- Will job applicants have access to these procedures?
- How are complaints tracked and reported?
- Will the confidentiality of whistleblowers be protected?
- What training have managers received on PPP risks when using Schedule P/C authority?
- What role do IG and OSC play?
- Are Schedule P/C related PPP complaints being flagged as a category?
Watch
- Whether employees understand where and how to raise concerns
- Whether safeguards are formalized in written procedures
- Whether managers demonstrate understanding of PPP responsibilities
- Patterns in complaint data that may indicate either effective safeguards or lack of awareness
- How seriously agencies operationalize these safeguards in practice
Why it matters: Under the traditional civil service system, MSPB provided an independent judge, formal record, public decisions, visible check on agency action. OSC safeguarded the merit system by protecting federal employees and applicants from prohibited personnel practices and provided a secure channel for federal employees to blow the whistle by disclosing wrongdoing. Under Schedule P/C, legitimacy depends on whether agencies build credible, transparent, and trusted internal safeguards. Visible safeguards are essential for preventing misuse of at-will authority; protecting whistleblowers and dissenters acting in good faith; maintaining workforce trust in policy offices; ensuring accountability does not become perceived politicization. Agencies need to have strong systems before problems arise.
Hiring and merit rules
Understand: Hiring for Schedule P/C roles must still follow merit procedures. New hires in Schedule P/C can gain competitive status in 2 years.
Ask (on a rolling basis)
- Are there any differences between traditional merit hiring and Schedule P/C hiring practices?
- As the rule is implemented, how many new hires have been made into these roles?
- Have any individuals previously serving in political roles been hired into Schedule P/C roles?
Watch
- Whether employees and managers clearly understand how competitive status is gained
- Public hiring announcements and transparency around these roles
Why it matters: Perceptions of politicization may arise here.
Workforce and mission impacts
Understand: These roles will sit in a wide range of functions across agencies. Early concerns about Schedule P/C highlighted risks to sensitive, scientific, technical, or high-demand roles where continuity and ability to “speak truth to power” are valued.
Ask (on a rolling basis)
- Have you seen retention or recruitment impacts in Schedule P/C roles?
- Have employees moved to Schedule P/C declined roles or departed Federal service?
- What Schedule P/C roles are in the national security, scientific, or health fields, or fields engaged in long-term risk work?
- How are agencies addressing concerns that Schedule P/C would stifle dissent or evidence-based policymaking?
- How many employees in Schedule PC roles have transferred or competed for non-Schedule PC roles? How many have sought to?
Watch
- Hollowing out of key policy offices
- Reluctance of experienced staff to serve
Why it matters: Accountability gains should not come at the expense of mission capacity.
Does this address the performance problem it’s meant to solve?
Understand: OPM justifies the rule using MSPB and FEVS data showing managers struggle to remove poor performers; however, the rule does not introduce a more mature performance management standard.
Ask (on a rolling basis, or through GAO review)
- What evidence do you have that those in “policy influencing” roles have performance issues, or that the impact of such performance issues is greater?
- Have you used this authority to remove employees for performance issues? Why could they not be addressed under prior mechanisms?
- Are managers finding it easier to address poor performance? What about to incent strong performance?
- What indicators are you watching for improved overall performance?
- What standards are being applied for performance? Are they consistent within or across agencies?
Watch
- Rule exists on paper but behavior doesn’t change
- Different definitions for poor performance arise from adverse action, conduct and performance as defined in Chapters 43 and 75
- Performance problems persist for other reasons
Why it matters: Congress should know if the remedy matches the diagnosis.
Data Congress should request via GAO for ongoing tracking and comparison
Request from agencies:
- List of all positions designated
- Written justifications
- Counts by grade, office, and occupational series
- Number of removals using this authority
- Number of PPP/whistleblower complaints related to it
- Number of hires into Schedule P/C roles
Why it matters: Early transparency prevents speculation and enables evidence-based oversight.
Biosecurity Modernization and Innovation Act of 2026 is a Major Step for U.S. Biosecurity
There are moments where biosecurity reform moves from thought to action. This week is one of them.
On Wednesday, Senators Tom Cotton (R-AK) and Amy Klobuchar (D-MN) introduced the Biosecurity Modernization and Innovation Act of 2026. Inspired in part by the National Security Commission on Emerging Biotechnology’s recommendation for foundational biosecurity and biosafety oversight reform, this bipartisan effort works to fix a basic problem: the United States still lacks clear, accountable oversight for biological risks.
This bill takes a first practical step. It gives the White House 90 days to assess the state of biosecurity oversight by clarifying roles, measuring effectiveness, listening to practitioners, and identifying gaps in resources and capability. Asking these basic accountability questions is essential to the growth of a strong and secure biotechnology landscape.
This assessment would feed directly into implementation, with executive actions where possible, legislative action where necessary, and structural reforms that could consolidate oversight mechanisms into a central oversight hub on biorisk matters.
Clarity is not just bureaucratic housekeeping. It is the critical foundation for national security, international competitiveness, and public trust in biotechnology. We have known for decades that the system needs modernization. This bill finally begins some of this critical work.
Ninety (90) days is ambitious for running an interagency process at this scale, but the urgency is needed.
For half a century, we’ve patched problems as they arose, building a culture of compliance, not curiosity. As an example, after the early-2000s anthrax attacks and a series of controversial experiments, the government created and tightened rules around select agents and created policies for “dual use” and pandemic research. Yet those policies were rarely evaluated or consistently implemented, and in some cases the measures would not have prevented the very incidents that prompted their creation. While part of the gap is technical, much of it comes from a paradigm that positions biosecurity and biosafety as a hindrance to innovation, and not its enabler.
This misalignment matters. The pace of advance in the last 50 years is dwarfed by the leaps in the last five. Biotechnology today is more diffuse and comes at a lower price point than at any point in history. It is digital, global, and increasingly powered by AI. Tools that once required specialized labs may now run from a laptop or are outsourced across borders.
This is the moment to move from fragmented compliance to modern governance: a system that is proactive, coordinated, and accountable. Senators Tom Cotton and Amy Klobuchar recognize that reality. Their bill creates the space to step back, clarify roles, and design biosecurity oversight on purpose – not by accident or after the next crisis.
By preparing credible, bipartisan options now, before the bill becomes law, we can give the Administration a plan that is ready to implement rather than another study that gathers dust.
At the Federation of American Scientists, this reform agenda builds on work already underway across the biotechnology landscape – from exploring and advancing practical governance approaches for AI-enabled and data-driven biology, strengthening domestic biomanufacturing and scale-up policy, identifying gaps and coordination challenges in federal oversight, and translating technical expertise into actionable options for policymakers.
FAS is expanding its role as a convener and catalyst over the coming months through additional gatherings, publications, and structured dialogues with government, industry, academia, and civil society leaders to help shape the present and future of biorisk policy.
This next phase will focus on foundational, cross-cutting reform. Many of the ideas on the table today are incremental; they target individual risks or technologies in isolation. However, the challenges we face are systemic. We need institutions and oversight tools that evolve alongside the science, and align innovation, economic growth, and security rather than treating them as tradeoffs. That’s the focus of our work. If you would like to engage, please reach out to any of us via email or on LinkedIn. We are actively working with practitioners, policymakers, and researchers to surface practical insights, align incentives, and ensure that oversight frameworks are both grounded in real-world practice and widely supported.
The Aftermath: The Expiration of New START and What It Means For Us All
The last remaining agreement limiting U.S. and Russian nuclear weapons has now expired. For the first time since 1972, there is no treaty-bound cap on strategic nuclear weapons.
On February 5th, Axios reported that following overnight negotiations between the two sides, there remains a possibility for the two countries to continue observing the central limits after the Treaty’s expiry, although it did not state whether such an arrangement would include verification, and also noted that it had not been agreed to by either President.
If the two sides cannot reach an agreement, we face a world of heightened nuclear competition fueled by worst-case planning and nuclear expansion, fewer transparency mechanisms, and deepening mistrust among nations with the world’s most powerful weapons. Addressing these challenges in the new nuclear era will require creative and nontraditional approaches to risk reduction and arms control.
How did we get here?
Even if the two sides manage to negotiate a last-minute band-aid arrangement, the fact that we have no long-term arms control solution ready to take New START’s place is the culmination of years of breakdown in diplomacy and arms control efforts. New START entered into force on February 5th, 2011, with a 10-year duration and the option to extend it for five additional years. Leading up to the treaty’s original expiration date in 2021, there was serious concern that the United States and Russia would not come to an agreement on extension. For the first three years of his first administration, President Donald Trump engaged in few constructive arms control discussions with Russia. Then, in the final months of 2020, he proposed a short-term extension contingent on Russia agreeing to new verification measures and a warhead freeze, which Russia rejected. At the 11th hour, just two weeks after his inauguration, President Joe Biden agreed to a full five-year extension of the treaty with Russian President Vladimir Putin.
The shaky status of New START further deteriorated in early 2023 when Putin announced that Russia was “suspending” its participation in the treaty, stipulating that resumption would require the United States to end its support for Ukraine, and that arms control talks would also have to involve France and the United Kingdom. As part of its suspension, Russia halted its exchanges of data, notifications, and telemetry information, and the United States subsequently followed suit with reciprocal countermeasures.
It is important to note that although the United States found Russia’s actions to constitute noncompliance with the treaty’s requirements, successive State Department reports following Russia’s suspension assessed that “Russia did not engage in any large-scale activity above the Treaty limits.” The 2024 compliance report, however, stated that “Russia was probably close to the deployed warhead limit during much of the year and may have exceeded the deployed warhead limit by a small number during portions of 2024.”
Ultimately, over years of growing tensions and mistrust between the two countries, the United States and Russia have barely managed to see New START through to its expiration, much less engage in talks for a new treaty to take its place. In September 2025, the Kremlin stated that “Russia is prepared to continue observing the treaty’s central quantitative restrictions for one year after February 5, 2026,” without verification. President Trump told a reporter that the proposal “sounds like a good idea to me,” but apparently did not respond to the proposal before the treaty’s deadline expired.
In addition to the worsening U.S.-Russia relationship, funding cuts at the U.S. Department of State, the Defense Nuclear Nonproliferation office at the NNSA, and the Office of the Director of National Intelligence mean less investment in and capacity for executing a follow-on agreement, even if the political environment allowed for it.
What could this mean for nuclear forces?
New START placed limits on the number of strategic nuclear weapons that each country could possess and deploy: each side could deploy up to 1,550 warheads and 700 launchers, and could possess up to 800 deployed and non-deployed launchers. Incorporating a limit on non-deployed launchers was intended to prevent either country from “breaking out” or quickly expanding deployed numbers beyond the treaty limits.
Over the past 15 years, the treaty restraints and respective modernization plans resulted in significant force reductions in Russia and the United States. Both countries have meticulously planned their respective nuclear modernization programs based on the assumption that neither will exceed the force levels currently dictated by New START. In the absence of an official agreement following New START’s expiration, however, both countries will likely default to mutual distrust and worst-case thinking about how their arsenals will grow in the future. This is a serious concern, considering both countries possess significant warhead upload capacity that would allow them to increase their deployed nuclear forces relatively quickly.
This kind of thinking has already been displayed by members of the House Armed Services Committee who, in 2023, called Biden’s agreement to extend New START “naive” and argued that Russia “cannot be trusted,” saying “if these agreements cannot be enforced, then they do nothing to enhance U.S. security, and serve only to undermine it.” Defense hawks in Congress and outside argued instead for upgrades and expansions to the U.S. nuclear force; the bipartisan Congressional Commission on the U.S. Strategic Posture in late-2023 recommended a broad range of options to expand the U.S. nuclear arsenal. The Biden administration also appeared to lay the groundwork for potential options to expand its deployed nuclear force following the end of New START: in June 2024, Pranay Vaddi, Special Assistant to the President and Senior Director for Arms Control, Disarmament, and Nonproliferation at the National Security Council, stated that “Absent a change in the trajectory of adversary arsenals, we may reach a point in the coming years where an increase from current deployed numbers is required. And we need to be fully prepared to execute if the President makes that decision—if he makes that decision.” The Biden administration’s Nuclear Employment Strategy published in 2024, however, did not direct an increase of U.S. deployed nuclear forces, effectively leaving that decision to the Trump administration.
If the United States decided to increase its deployed strategic forces, there are measures it could take to rapidly upload reserve warheads, while other options will take more time. For example, all 400 deployed U.S. ICBMs currently only carry a single warhead, but about half of them use the Mk21A reentry vehicle that could be uploaded to carry three warheads each if necessary. An additional 50 “warm” ICBM silos could also be reloaded with missiles, though this process would likely take several years. With these potential additions in mind, the U.S. ICBM force could possibly double from 400 warheads to up to a maximum of 800 warheads. In any case, executing such an upload across the entirety of the ICBM force would require significant resources, manpower, and time—none of which the United States has in excess, given existing constraints on its already-delayed nuclear modernization program.
Increasing the warhead loading on U.S. ballistic missile submarines could be done faster than uploading the ICBM force. Each missile on the submarines currently carries an average of four or five warheads, a number that can be increased to eight. Doing so could theoretically add 800 to 900 warheads to the submarine force, but loading each missiles with the maximum number of warheads onto each missile (and by extension, each submarine) would dramatically limit the submarine force’s targeting flexibility, as war planners will not want to lock themselves into a situation in which submarine crews would be forced to fire the maximum number of warheads, rather than having a range of more limited options at their disposal. As a result, executing an upload across the submarine force could more realistically result in an increase of approximately 400 to 500 additional warheads. Doing so would take many months, given that each ballistic missile submarine would have to return to port on a rotating schedule in order to load the additional warheads. In addition, the United States has the option to reopen the four launch tubes on each ballistic missile submarine that had been converted to non-nuclear status for New START compliance, and the July 2025 “One Big Beautiful Bill Act” provided $62 million for conversion activities to take place after March 1st, 2026; however, doing so would need to overcome significant internal opposition and would likely take several months, if not years, to complete.
The quickest way for the United States to increase deployed nuclear warheads would be to load nuclear cruise missiles and bombs onto its long-range B-2 and B-52 bombers. The bombers were taken off alert and their nuclear weapons placed in storage in 1992, but hundreds of the weapons are stored at the bomber bases and could be loaded within days or weeks; additional weapons could be brought in from central storage depots. Up to 800 nuclear weapons are estimated to be available for the bombers. Yet loading live nuclear weapons onto bombers would significantly increase the vulnerability of the weapons to accidents and terrorist attacks.
Russia also has a significant warhead upload capacity, particularly for its ICBMs, but is subject to similar constraints as the United States. Several of Russia’s existing ICBMs are thought to have been downloaded to a smaller number of warheads than their maximum capacities in order to meet the New START force limits. As a result, without the limits imposed by New START, Russia’s ICBM force could potentially increase by approximately 400 warheads.
Warheads on missiles onboard some of Russia’s SSBNs are also thought to have been reduced to a lower number to meet New START limits. Without treaty limitations, the number of deployed warheads could potentially be increased by 200-300 warheads, perhaps more in the future, although this number could be tempered by a desire for increased targeting flexibility, in a similar manner to the United States.
While also uncertain, Russian bombers could be loaded relatively quickly with hundreds of nuclear weapons, similarly to the United States.
Ultimately, if both countries chose to upload their delivery systems to accommodate the maximum number of possible warheads, both sets of arsenals could nearly double in size. While a maximum upload is highly unlikely, it is possible we will see immediate measures taken to upload certain systems, followed by gradual increases in other areas over the next few years. While defense hawks in Russia and the United States claim that more nuclear weapons are needed for national security, doing so would inevitably result in each country being targeted by hundreds of additional nuclear weapons.
Moreover, without the transparency and predictability that resulted from the verification regime and regular data exchanges stipulated under New START, nuclear uncertainty—and potentially confusion and misunderstandings—will increase. Russian and U.S. planners will rely more on worst-case scenarios in their nuclear programs, and both countries are likely to invest more in what they perceive will demonstrate resolve and increase their overall security, including nonstrategic nuclear forces, conventional forces, cyber and AI capabilities, and missile defense. These moves could also trigger reactions in other nuclear-armed states, possibly leading to an increase in their nuclear forces and the role they play in their military strategies. China has already decided to increase its nuclear arsenal to better be able to counter what it perceives is a growing threat from other military powers; Beijing rejects numerical limits on its nuclear arsenal and increasing U.S. and Russian nuclear arsenal will make it harder to change its mind.
Re-imagining the future: The end of fully “compartmentalized” arms control?
The future of arms control is certainly not dead, but it is likely entering a new era. For decades, the United States and Russia pursued arms control negotiations in isolation from other security issues, emphasizing that the unique destructiveness of nuclear weapons requires that the topic be segregated. Although such negotiations were never completely disentangled from politics or other geopolitical events—as demonstrated, for example, by the refusal of the U.S. Senate to ratify SALT II after the Soviet invasion of Afghanistan—this approach was largely successful as a framework for arms control during and immediately after the Cold War.
This fully compartmentalized approach, however, is likely no longer an option in a post-New START world. Russia has made it clear through both its actions—particularly its suspension of its treaty obligations primarily due to U.S. support for Ukraine—and its rhetoric that it will no longer engage in arms control negotiations absent a broader reboot of U.S.-Russia relations. And officials in the United States increasingly argue that bilateral nuclear limits on U.S. and Russian nuclear arsenals do not take into account the growing Chinese nuclear arsenal.
On February 3rd, Deputy Foreign Minister Ryabkov stated that in order to engage in strategic stability dialogue, “We need far-reaching shifts, changes for the better in the US approach to relations with us as a whole.” On numerous prior occasions, he had critiqued the United States’ approach to arms control: in 2023, he told TASS that Moscow cannot “discuss arms control issues in the mode of so-called compartmentalization, which means singling out from the whole range of issues some pressing ones which are of interest to the United States, and pushing to oblivion or taking off the table other points that are theoretically as important to Russia as those of interest to the Americans.”
It would appear that China thinks about arms control in a similar way. In 2024, China suspended strategic stability talks with the United States in response to U.S. arms sales to Taiwan and increased trade restrictions on China. A spokesperson from China’s Ministry of Foreign Affairs emphasized that in order to bring China to the table, the United States “must respect China’s core interests and create [the] necessary conditions for dialogue and exchange.” On February 5th, Chinese Foreign Ministry spokesperson Lin Jian reiterated that “China’s nuclear strength is by no means at the same level with that of the U.S. or Russia. Thus, China will not take part in nuclear disarmament negotiations for the time-being.” Even if it were possible to change China’s opposition to numerical limits on nuclear forces and join the arms control process, it is not clear what the United States would actually be willing to limit or give up in return for Chinese concessions. One such possibility would be the more ambitious and fantastical elements of Golden Dome, as a multi-layered, space-based missile shield is fundamentally incompatible with the idea of accepted mutual vulnerability.
Re-imagining the future: verification without on-site inspections?
Traditional nuclear arms control, including New START, relies on the availability of on-site inspections to verify compliance. Absent a significant shift in geopolitical relations, however, it is implausible to imagine some combination of American, Russian, or Chinese inspectors roaming around each other’s territories anytime in the near future. As a result, the next generation of arms control agreements faces a clear challenge: how can countries verify that the other remains in compliance when the political reality prohibits on-site inspections?
Traditionally, countries have used “National Technical Means”—a term used to describe classified means of data collection, such as remote sensing and telemetry intelligence—to verify compliance with arms control agreements. NTMs are used as a complement to other sources of verification, including on-site inspections, data exchanges and notifications, and the exchange of telemetric information. Despite on-site inspections and formal data exchange being preferable, NTMs can be very capable; for example, the U.S. assessment that Russia might briefly have exceeded the New START warhead limit was based on NTMs, not on-site verification.
Given the political implausibility of on-site inspections forming part of a future verification regime, one of the authors has recently co-authored a report with Igor Morić from Princeton’s Science & Global Security Program on the possibility of a future arms control arrangement based around “Cooperative Technical Means.” Under such an arrangement, it could be possible for states to use national or commercial remote sensing tools to monitor each other’s nuclear capabilities, verify the numbers of fixed and mobile ICBM and SLBM launchers, as well as track the number and location of their heavy bombers. For a more detailed explanation, the full report can be accessed here.
What Now?
As Axios’ reporting indicates, everything could change in a day, for better or for worse. Countries could take unilateral measures to either exercise restraint or refuse cooperation. Specifically, it is important that each side refrain from significant increases in its nuclear arsenal regardless of whether a new arrangement is concluded; such steps will almost inevitably increase the competition dynamic that would result in an arms race.
It is also imperative that the United States and Russia commit to engaging in arms control as a means of reducing the risk of nuclear use, whether intentional or by accident or misinterpretation. The United States, in particular, should reinvest in and reprioritize diplomacy and nonproliferation to prepare for and signal an intention to re-engage in arms control dialogues.
While new technology and creative approaches offer potential solutions to issues plaguing past arms control arrangements, progress will still require political will and motivation from both sides.
Here at FAS, we will continue to track the nuclear force status and modernization programs across the nine nuclear-armed states, paying close attention to cost and schedule overruns that relentlessly plague many of these efforts. In an era where nuclear transparency and access to reliable, public information are declining, we believe our work is more critical now than ever before.
Additional work from us on this topic:
- After Seven Years of Implementation, New START Treaty Enters Into Effect
- If Arms Control Collapses, US and Russian Strategic Nuclear Arsenals Could Double In Size
- Inspections Without Inspectors: A Path Forward for Nuclear Arms Control Verification with “Cooperative Technical Means”
- The Long View: Strategic Arms Control After the New START Treaty
- 2025 Russia Nuclear Notebook
- 2025 United States Nuclear Notebook
- For all Nuclear Notebooks, see here
The Nuclear Information Project is currently supported with generous contributions from the Carnegie Corporation of New York, the New-Land Foundation, Ploughshares, the Prospect Hill Foundation, and individual donors.
“Going Back to Cali” for AI Governance Lessons as States Take the Lead on AI Implementation
Imagine you are a state-level technology leader. Recent advancements in artificial intelligence promise to make approving small business licenses faster, or improve K-12 student learning, or even standardize compliance between agencies. All of which promise to improve the experience of your state’s constituents. Eager to deploy this new technology responsibly, you look to peers in other states for guidance. Their answers vary wildly, and in the absence of federal guidance, it quickly becomes clear that there is no standardized playbook. You must chart the path forward on your own, with far more limited resources.
This scenario is becoming increasingly common as AI systems are moving rapidly into consumer-facing services. Without federal action on AI, state government leaders are increasingly shouldering the responsibility for both protecting consumers from potential algorithmic harms and also supporting responsible innovation to improve service delivery to their constituents. States have structural advantages that position them to experiment with regulatory approaches: shorter legislative cycles that allow for quicker course corrections, authority to pilot programs, and the use of sunset provisions that make it easier to revise or retire early-stage governance models. This often places states as the most agile regulators who can swiftly set up guardrails for rapidly evolving AI technologies that impact their residents.
But this regulatory agility must be matched with the necessary government capacity in order to be a success. The current lack of federal action is forcing states not only to pass new AI laws, but also to take on huge implementation challenges, without the AI expertise typically found in federal agencies or major private employers. Building this capacity within state governments will demand resources and technical expertise that most states are only just starting to chart . Without deliberate investment in transparency and talent, even the most well-crafted legislation might not achieve their intended goals. As State legislative cycles start back up for the 2026 year, state policymakers should move forward with proposals that increase transparency, accountability, and bring new technical experts directly into government to meet the scale of need in the current moment.
Increased Transparency to Build Public Trust
One of the most immediate ways that state legislatures can move forward with transparency-improving legislation is with the passage and successful implementation of use-case inventories. A use-case inventory is a public-facing publication of algorithmic tools and their specific uses. They disclose when and where state governments are utilizing algorithmic tools in consumer-facing transactions such as applications for social programs and public assistance benefits. They are typically conducted by governments as a mechanism for transparency and to facilitate third-party auditing of outcomes.
The benefits of public-facing AI use-case inventories are far reaching: they increase government transparency into automated decision-making outcomes, can provide valuable insights to private-sector product vendors, facilitate third-party auditing and bias-testing, and can even increase interagency sharing of best practices when AI tools are effectively used. They are particularly important in high-risk decisions such as those related to government benefits and services. Alternatively, a lack of transparency in expensive acquisitions from private and third party vendors can mean that an agency or entity is unaware of what tools they have acquired and whether or not they are safe to deploy in consumer-facing settings without bias or other inaccuracies.
When increasing numbers of Americans are growing skeptical of the practical uses of AI tools, it is doubly important to design public systems that encourage transparency when algorithmic tools are deployed in the public and private sectors alike.
Despite a lack of federal legislation regulating responsible AI usage, one area where the federal government has led is in the production of regular AI use-case inventories since 2021. First requested via Executive Order 13960 in 2020 during the first Trump administration, and implemented in the Summer of 2021, the federal government provides a relatively transparent accounting of where AI is adopted within the federal enterprise. This policy has had bipartisan appeal, and the Biden administration continued the production of regularly updated inventories for the public. The Trump administration with its recently updated inventory now has the opportunity to use this tool to deliver increased public trust in AI, a clear administration priority.
Case Study: Implementation Challenges in California
While the federal experience demonstrates that AI use-case inventories can work, it also reveals an important limitation: transparency mechanisms rely on technical talent and focused implementation to be successful. California offers a cautionary example. In 2023, the state legislature passed Assembly Bill 302 requesting the State Department of Technology to “conduct a comprehensive inventory of all high-risk automated decision systems [ADS] being used by state agencies and submit a report to the Legislature by January 1, 2025, and annually thereafter.” Importantly, the bill covered systems that are “used to assist or replace human discretionary decisionmaking.” The bill was envisioned as a critical first step in gaining insight into the ways AI was being deployed in consumer-facing interactions by state government agencies. It was also in reaction to public reporting of biased technology being used on those applying for public services and benefits.
However, the initial implementation deadline for the bill passed in early 2025 and the only report provided to the public was a single document stating that there are “no high-risk ADS [tools] being used by State agencies”—a fact that is easily disputed by a simple Google search. For example, the state healthcare exchange uses automated document processing tools to gauge eligibility for affordable health insurance policies, the state unemployment insurance program uses an algorithmic tool developed by a private company to rate applicants on the likelihood of their application being fraudulent, and the state Department of Finance even plans to use generative AI tools as part of fiscal analysis and state budgeting work. These are significant decisions that can have real repercussions for California residents. Rather than creating a transparent use-case inventory that can tell Californians where AI is being used in consumer-facing interactions, we instead have a letter which incorrectly states —based on examples above—that there are no algorithmic tools being used. The table below has additional examples of publicly disclosed automated decision-making system use cases in California state government.
Results like this underscore the urgent need to embed technical talent within state governments to ensure that laws are implemented as designed. When implementing its use case inventories, the federal government provided guidance to reporting agencies and publicly released a final inventory for a majority of agencies. Even with substantial support during the federal government’s collection process, there were still notable implementation challenges faced when creating a federal use-case inventory. Most notably, many agencies initially failed to disclose all use-cases, and a promised template for agencies to use has yet to come to fruition. The State of California, by contrast, instead relied on an ad hoc process, polling state agency officials through two successive emails to conduct its inventory evaluation.
Scaling Government Talent to Bridge the Technical Capacity Gap
California’s experience implementing a use-case inventory is, unfortunately, not unique. Across the country, well-intentioned legislation is often passed into law only to falter during implementation. Once enacted, agency staff are tasked with operationalizing complex policies, often without the necessary technical expertise, staffing capacity, or financial resources to succeed. Without deliberate investment in these areas, the responsibility of properly regulating emerging technologies and protecting consumers from harm is shifted to government employees that are poorly equipped to handle the growing scope and technical complexity of their workloads. That is why, in addition to transparency, states need to find ways to quickly bring in technical talent and expertise in digital technologies to drive forward effective implementation of the coming onslaught of bills.
In the midst of massive layoffs within the federal government and private sector, individual states now have access to historic levels of human capital and can bring forward some of the innovations developed within the federal government in recent years. Methods like skills-based hiring to rapidly bring in technical talent and scale new teams within government have also been developed and thoroughly tested in recent years through entities like the United States Digital Service (USDS) and the Consumer Financial Protection Bureau’s in-house technologists. These initiatives brought skilled workers into government at less than half the recruiting cost of private sector hiring and saved hundreds of millions of dollars through reimbursable agreements with agencies in lieu of costly private sector consultancy contracts.
During periods of financial uncertainty it can be deeply challenging for state leaders to make the investments necessary to hire additional staff and build robust government teams. One other method to bridge the gap between policymakers and those who implement it is through the development of modernized policy fellowships that utilize endowments or other private funds to bring cutting-edge researchers and experts directly into government. California has most recently unveiled a revamped science and technology fellowship that will place additional AI experts within state agencies or the legislature to propel forward-thinking and informed policymaking.
Conclusion
With no federal framework in place, state governments will be the primary drivers of accountability and transparency needed to ensure AI serves the public rather than erodes democratic norms. This presents us with a crucial window for state policymakers to establish both processes that further transparency and robust talent pipelines that can manage responsible deployment in order to restore public trust and prevent harms before AI systems become further entrenched in critical public services. States that build transparent AI use-case inventories and invest in technical expertise will be best positioned to translate lofty regulatory principles into real protections for their citizens—while also fostering a fairer, more trustworthy environment for innovation to thrive.
Gil on the Hill: January 2026
2026’s Roaring Start
We’re back! So much has happened in the first month of 2026. So much. January brought a jolt of game-changing national political events and government funding brinksmanship. If Washington, D.C.’s new year resolution was for less drama in 2026, it’s failed already.
As we reflect on 2025 and head into 2026, the question now is less about whether science and technology will stay rhetorically important (we saw that it will). Rather, it’s whether policymakers are willing to go beyond the platitudinous “China competition” or “AI leadership” talking points and invest in the unglamorous infrastructure that makes scientific and technological progress possible in the first place.
Appropriations and Shutdown Watch
So, what’s happening? Did Congress fund science? Will we shut down? What does it all mean for us? Here is where things stand at the time of writing.
Status. In November, Congress ended the longest government shutdown in history by extending its deadline for a funding deal to January 30th, 2026. That date has fast arrived, and Congress has fully passed 6 of 12 appropriations bills – Agriculture, Military Construction & Veterans Affairs, Legislative Branch, Commerce, Justice, & Science, Energy & Water Development, and Interior & Environment. No one wants a shutdown, least of all the agencies that are forced into a contingency mode that disrupts operations and destabilises long-term planning.
Things Were Going Well for a Minute. After a string of successive compromises on bundles of appropriations bills (“minibuses”) and final passage into law of the minibus for Commerce, Justice, and Science, Energy and Water Development, and Interior and Environment (CJS-E&W-Int), Congress finds their momentum abruptly halted ahead of voting on the remaining 6 bills with urgent calls for more Department of Homeland Security (DHS) oversight in the wake of the killing of Minneapolis ICU nurse Alex Pretti by a U.S. border patrol agent.
75% of Fed Funding Still at Stake. Furor over the Trump Administration’s immigration crackdown which now includes the killings of American citizens and other high-controversy incidents by DHS agents, on top of brewing tensions over the conflict in Venezuela and diplomatic standoffs over Greenland, have threatened an already-strained process that still needs the final passage of the full Congress for six bills which account for more than 75 percent of federal discretionary spending.
Oof, another shutdown…? Probably. There is a serious likelihood of a partial government shutdown as the Senate takes up its next votes on remaining funding bills ahead of the Jan 30th deadline. The House did its part, and 6 funding bills remain for final passage in the Senate – Defense, Labor-Health and Human Services-Education, Transportation-Housing and Urban Development (THUD), Financial Services, Homeland Security, and National Security-State. Republicans will need Democratic votes to pass it, and so far, not enough have indicated they will support it without DHS oversight.
Dems DHS Oversight Demands. DHS Oversight Senate Minority Leader Chuck Schumer wants DHS funding legislation changed, but the other five pending appropriations bills passed in the meantime. Several Democrats who crossed over with Republicans to end the previous shutdown plan to vote against the funding bills without the inclusion of more oversight for Immigration and Customs Enforcement (ICE) and Customs and Border Protection (CBP) in the bill.
Republican Concerns. Senate Republican leadership wants to vote on the six-bill package, including DHS, with no changes, and is pushing back against calls to “defund DHS.” President Trump has entered the negotiations with a push forRepublicans to pass a bill to “END Sanctuary Cities.” Republicans are voicing concerns about DHS actions and calling for an investigation.
Earmarks at Stake. A shutdown will have state and local communities anxiously awaiting the fate of their earmarks, or congressionally directed spending that sends federal funds directly to local projects. Part of the package (agreed to, but not voted on) includes $16 billion worth of earmarks for everything from construction projects to new police equipment to wastewater infrastructure.
Bottom Line. Midnight on Saturday, January 31, may yet see us hit another government shutdown, albeit partial yet substantial.
Science in Approps
There is positive news for the science and tech community as Congress passed and President Trump signed into law a full-year appropriations package that included accounts critical to science and technology at federal agencies. It may not be everything the science community wanted, but considering the Republican-controlled Congress and White House and their pledges to massively cut spending, the modest cuts in the final bill can be received in that context as a reprieve from the worst-case scenarios. It also means that these accounts (such as the National Science Foundation, Department of Energy, etc.) will not be directly impacted by the potential government shutdown. The funding bill, including the Department of Education and its programs, however, is still at risk, as well as countless other programs that touch the scientific enterprise.
Proposed Cuts vs Final in Minibus. In the bill considered most directly important for scientific research, the CJS-E&W-Int minibus rejected the Trump Administration’s cuts for the National Science Foundation by 57%, for the Department of Energy’s (DOE) Office of Science by $1.1 billion, and for NASA’s science budget by 47%. Instead, the package sustains research funding for NSF, provides $160 million more for the DOE Office of Science (which supports critical research being conducted by 22,000 researchers at our 17 national labs and over 300 universities), and provides $7.25 billion for NASA’s science budget.
Funding Oversight. The final CJS-E&W-Int minibus included hundreds of specific policy provisions to accompany the funding that detail how the funding should be spent. This is in response to the misuse of funds by the Trump Administration that many agree amounted to illegal impoundment. We’ll have to wait and see if it has the desired effect…
Indirect Costs. The minibus includes language blocking the imposition of a 15% cap on indirect cost reimbursement at the federal science research agencies funded in the package (NSF, the National Institute of Standards & Technology, NASA, and the Department of Energy’s Office of Science). This is on top of a federal appeals court ruling blocking the NIH from moving forward with a cap on research indirect cost payments. The administration has not announced whether it intends to appeal this ruling.
NDAA and Science
Appropriations is taking up a lot of attention, but it’s not all that Congress is up to. Most importantly, Congress passed the 2026 National Defense Authorization Act (NDAA), which includes important provisions for science, R&D, and national security. Maybe more importantly, it omitted several controversial provisions, too.
Research Security. The NDAA contains some controversial new restrictions on research collaborations with China and other “countries of concern.” It also drops other research security proposals that had drawn objections from the U.S. scientific community, and blocks a unilateral reduction of overhead payments to DOD grantees. Notably, the SAFE Research Act did not pass with the NDAA, and neither did a Senate provision to prohibit any higher education institution conducting research funded by DOD from entering into contracts with a covered nation or foreign entity of concern.
AI. Renewed efforts to restrict state regulation of AI landed flat once again as they did not make it into the final NDAA. It does, however, direct the Secretary of Defense to establish one or more AI research institutes, known as National Security and Defense Artificial Intelligence Institutes, at higher education institutions that conduct DOD-sponsored research.
Indirect Costs. (again!) Similar to language in the CJS-E&W-Int minibus, the NDAA blocks the Secretary of Defense from changing or modifying the indirect cost rates for DOD grants to research institutions until the Secretary certifies that DOD has developed an alternative model in consultation with the extramural research community that reduces the rate for all institutions and allows “adequate transition time” for affected institutions to adjust.
Executive Branch Highlights
Genesis Mission. A recent executive order from the White House establishes a “Genesis Mission” that aims to “mobilize the Department of Energy’s 17 National Laboratories, industry, and academia to build an integrated discovery platform.” According to the DOE press release, the platform will draw on the expertise of roughly 40,000 DOE scientists, engineers, technical staff, and private sector innovators.
NSF Tech Labs. We are thrilled about NSF’s launch of a new “Tech Labs” program that represents a new federal science funding paradigm: team-based, outcome-driven, independent labs, each targeted to receive between $10M and $50M a year. Overall, NSF expects to put up to $1B into this new program.
FAS is particularly excited about this, as it played a central role in introducing this concept in 2020 in the form of a proposal for Focused Research Organizations. Several FAS teammates have spent years evangelizing the concept across research agencies and Congress. Check out what FAS is saying about it:
- Team Science needs Teamwork: Universities should get in on the ground floor in shaping the vision for new NSF Tech Labs (from Erica Goldman)
- NSF Plans to Supercharge FRO-style Independent Labs. We Spoke with the Scientists Who First Proposed the Idea. (from Daniel Correa)
Higher Ed Watch
Universities and higher ed continue to deal with the dynamic state of politics and federal policies, yet a new R&D survey reminds us how valuable they remain to the nation’s research enterprise – $117 billion worth.
Education and Approps. The House passed the Labor-HHS-Education package by a margin of 341-88. Now we await Senate passage of theeducation funding bill that would allot $79 billion in discretionary funding. The legislation would flat-fund the Pell Grant, Federal Supplemental Educational Opportunity Grant (FSEOG), Federal Work-Study (FWS), the federal TRIO, and Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP) programs at FY 2025 levels. The legislation also included a provision that would block funding for ED from being transferred to other agencies, unless specified in the appropriations law.
Higher education R&D expenditures reach $117 billion in FY 2024. The smart folks at SSTI have taken an informative look at Higher Ed R&D expenditures.
Higher Education R&D expenditures jumped 8%, or nearly $9 billion, from fiscal year (FY) 2023 to 2024, reaching an all-time high of over $117 billion, according to new Higher Education R&D (HERD) survey data. The funding sources of HERD expenditures remain proportionally unchanged from the prior year, with all sources increasing, and the federal government ($5 billion) and institution funds ($2.5 billion) accounting for the largest dollar increases.
Adjusted for inflation, overall HERD expenditures increased by 5%—the second largest year-over-year increase in the past decade—while all sources of funds except business increased.
source: Higher Education Research and Development (HERD)
Ta Ta for Now!
2026 will be another landmark year for how we make an affirmative, public-interest case for science amidst turbulent political times. We’re looking forward to making that case together with you.
Right now, the premium is less on splashy tech announcements and more on signals of institutional commitment like stable funding, durable governance, and a willingness to invest in systems that do not produce immediate political wins.
Reach out for any shutdown questions or requests for topics next month! It’s going to be a fun year.
Introducing Digital Service Retros: Back to the (Digital) Future
On January 20, 2025, the U.S. Digital Service, 18F, and much of the Technology Transformation Service were disbanded or fundamentally reshaped. The institutions that once rebooted HealthCare.gov, expanded access to care for millions of Veterans, and launched Direct File were transformed overnight, marking a dramatic shift in how the federal government delivers critical services to the American people.
In parallel—governments at the state and local levels have made landmark investments in digital teams and innovation, which has already generated real results and cost savings.
This is not the first disruption in public-sector digital capacity. But the scale of this moment, colliding with rapid advances in AI, new procurement models, and evolving expectations of government, creates a rare opportunity. It is a moment to look back in order to build for the future. To pause, together, as a community, and ask what we’ve learned—and what comes next.
The Federation of American Scientists, in partnership with Georgetown University’s Beeck Center for Social Impact + Innovation and the Better Government Lab at Georgetown University and the University of Michigan, is launching a national series of digital service retrospectives. These convenings will capture hard-won lessons, surface what truly worked, be clear-eyed about what didn’t, and bring digital service experts together to imagine next-generation models for digital government.
How might we redesign digital service capacity—its operating models, authorities, and talent—based on over a decade of progress in civic technology? What drew you to this work? What accelerated impact, and what slowed it down? What was missing? What was overbuilt? What made partnerships and deployments succeed—or fail?
We are inviting participation from across the U.S. digital government ecosystem: current staff and alumni of USDS, 18F, and TTS, digital teams across federal agencies, states, and cities, and the lawyers, procurement and talent specialists, data leaders, congressional staff, and policy experts who worked alongside them. There are lessons here that must be captured and shared.
Through a series of virtual and in-person workshops, participants will share experiences, ideas, and aspirations. At each session, we will synthesize what we hear, ultimately building toward a public set of insights and recommendations for the future of digital capacity in government. From there, we will take these recommendations to policy makers on the Hill to inform future legislation, executive branch champions, as well as to state and local leaders across the country to see which ideas and concepts they can start piloting now. This is policy entrepreneurship—building innovative ideas and bring them to life with key partners and talent—is what FAS does well and, with Beeck and BGL, we look forward to fighting for your ideas.
We have some great partners: we’re building on work already underway through the Federal Civic Tech Exit Project, run by the Better Government Lab and the Beeck Center, which has already conducted in-depth interviews with nearly 50 former federal digital service professionals. This next phase expands the contributions of the Beeck Center and BGL, drawing on Beeck’s national network of state and local digital service leaders and BGL’s focus on identifying and putting the world’s best research into practice to improve how government functions.
The work begins soon. If you’re interested, please complete this interest form and you’ll hear from us.
Start by expressing your interest in the form. You’ll be able to choose one or more ways to engage:
- Join a virtual workshop on February 10, 12, or 25 (register online)
- Attend an in-person workshop in DC on March 3 or 4 (register online)
- Contribute through an open-ended, anonymous survey
- Refer a colleague or friend who should be part of this conversation
- Follow along for updates, insights, and announcements
This initiative is hosted by the Federation of American Scientists (FAS) and Merici Vinton, with support from the FAS Government Capacity team, led by Loren DeJonge Schulman and Leya Mohsin.
We are launching this work in partnership with Georgetown University’s Beeck Center for Social Impact + Innovation, leveraging its extensive relationships with state and local digital leaders and the 10,000+ practitioners that participate in its Digital Government Network and the Better Government Lab at Georgetown University and the University of Michigan. We are also drawing on a small group of trusted advisors from across the digital government community.
- We will protect your identity. Our goal is to surface and publish the best ideas, not attribute individual comments.
- We intend to synthesize what we learn and share it with federal leaders, congressional staff, state and local digital teams, and future candidates and appointees. Participants who are excited to help shape, champion, or implement next-generation digital service models will have clear opportunities to engage in what comes next.
- Anyone who is or has been part of a government digital service ecosystem, or a close partner to one. This includes:
- Current or former staff of the U.S. Digital Service, 18F, or Technology Transformation Services
- Members of digital teams at federal agencies, states, and cities
- Congressional staff and policy experts who worked alongside these teams
- Partners, champions, and enablers who helped this work succeed
- If you’ve built, supported, funded, or depended on modern digital government, your perspective belongs here.
The Pentagon’s (Slimmed Down) 2025 China Military Power Report
On Tuesday, December 23rd, the Department of Defense released its annual congressionally-mandated report on China’s military developments, also known as the “China Military Power Report,” or “CMPR.” The report is typically a valuable injection of information into the open source landscape, and represents a useful barometer for how the Pentagon assesses both the intentions and capabilities of its nuclear-armed competitor.
This year’s report, and particularly the nuclear section, is noticeably slimmed down relative to previous years; however, this is because the format of the report has changed to focus on newer information, rather than repeating and reaffirming older assessments. As a result, this year’s report includes no mention of China’s ballistic missile submarines and their associated missiles, and includes only cursory mention of China’s air-based nuclear capabilities. It also excludes analyses of several types of land-based missiles entirely. However, this does not reflect changed assessments on the part of the Pentagon, but rather a lack of new information to report. Going forward, this means that analysts will need to read multiple years of CMPR reports in order to ensure that they are accessing the complete range of available information.
In addition, this year’s CMPR did not include any mention of China’s September 2025 Victory Day parade––which featured multiple new weapon systems––as the parade took place too recently; it will very likely be analyzed in next year’s report. The maps of missile base and brigade locations also appear to be out of date: the information is listed as “current as of 04/01/2024.”
While this year’s report did not include any earth-shattering headlines with regards to China’s nuclear forces, it provides additional context and useful perspectives on various events that took place over the past 12 months.
Stockpile growth
The CMPR states that China’s nuclear stockpile “remained in the low 600s through 2024, reflecting a slower rate of production when compared to previous years.” However, it reaffirmed previous years’ assessments that China “remains on track to have over 1,000 warheads by 2030.” China’s nuclear expansion over the past five years is now making this projection increasingly plausible, although even if it came to pass, China would still maintain several thousand warheads fewer than either the United States or Russia. Previous CMPRs had assessed that if China’s modernization pace continued, it would likely field a stockpile of about 1,500 warheads by 2035; however, this assessment has not been included in the CMPR since the 2022 iteration.
The dramatic expansion of China’s stockpile is primarily being prompted by the large-scale development and modernization of China’s next-generation intercontinental ballistic missile (ICBM) forces. In 2021, multiple non-governmental organizations (including our team at the Federation of American Scientists) publicly revealed the existence of three new ICBM silo fields capable of hosting up to 320 launchers for solid-propellant DF-31 class ICBMs. China is also more than doubling its number of silos for its liquid-fuel DF-5 class ICBMs, which the Pentagon assessed in its 2024 CMPR will likely yield about 50 modernized silos. Many of these missile types will be capable of carrying multiple warheads.
While the previous year’s CMPR indicated that China “has loaded at least some ICBMs into these silos,” the 2025 edition offers a valuable update: that China has now “likely loaded more than 100 solid-propellant ICBM missile silos at its three silo fields with DF-31 class ICBMs.” Our team continues to regularly monitor developments at the three silo fields using commercial satellite imagery and has not yet found sufficient evidence to corroborate this assessment; however, it is possible that the Pentagon’s assessment is primarily derived from other sources of intelligence, including human (HUMINT) and/or signals intelligence (SIGINT).
If China plans to continue its nuclear expansion, it will likely require additional fissile material, as China does not currently have the ability to produce large quantities of plutonium. The Pentagon assesses that China’s ongoing construction and planned commissioning of two new CFR-600 sodium-cooled fast breeder reactors at Xiapu “will reestablish China’s ability to produce weapons-grade plutonium.” However, the 2025 CMPR assesses that the first unit “is probably still undergoing testing,” and that “the second reactor unit is still under construction.” It is possible that this information is now out of date, as recent commercial satellite imagery now suggests that the first reactor unit may be operational.
Low-yield warheads
Previous editions of the CMPR had indicated that China was “probably” seeking low-yield warheads for escalation control during periods of small-scale nuclear crisis and/or conflict; however, the 2025 iteration is the first to offer an estimated yield value for such weapons, of “below 10 kilotons.” A recent technical history by Hui Zhang offers highly valuable data points for historical Chinese nuclear weapons tests, and suggests that China likely has the ability to produce smaller, low-yield warheads. Additionally, recent open-source reporting by Renny Babiarz with Open Nuclear Network (ONN) and researchers from the Verification Research Training and Information Center (VERTIC) found that China has been overhauling and expanding its warhead component manufacturing capabilities. Coupled with the expansion of the Lop Nur test site, this could indicate plans to upgrade China’s existing warheads, improve its ability to build more, or both.
The CMPR notes that the DF-26 intermediate-range ballistic missile (IRBM) and the air-launched ballistic missile (ALBM) carried by the H-6N bomber “are both highly precise theater weapons that would be well suited for delivering a low-yield nuclear weapon.” While the DF-26 had previously been identified as a likely carrier for a low-yield warhead, this is the first time that the H-6N’s ALBM has also been listed as a potential carrier.
Missile designations
It is often a complex endeavor to try and match China’s own missile designations to the names that are given to various systems by the Pentagon. This year’s CMPR, however, provides valuable confirmations for some of these missile designations. In particular, it confirms that both the DF-31A and DF-31AG ICBM are known to the Pentagon as CSS-10 Mod 2, which aligns with our understanding that both systems carry the same missile. It also strongly hints at the alignment between the CSS-18 and the DF-26 IRBM, as well as the CSS-10 Mod 3 and the DF-31B ICBM––a missile that was confirmed in the 2025 CMPR as the same missile that was launched from Hainan Island into the Pacific Ocean in September 2024 for the first time since 1980. This was the first mention of the DF-31B in the CMPR since the 2022 edition, and the first time that the missile’s existence under that designation has been confirmed.
The acknowledgement of the DF-31B’s existence coincides with the recent reveal of a likely silo-based version of the same missile during China’s September 2025 military parade. During that event, China unveiled a vehicle carrying a canister with the designation “DF-31BJ;” it is possible that the vehicle was a missile loader and the “J” likely indicates a silo basing mode, as the Chinese character “井” or “jing” means “well” and is used by the PLA to describe silos. We can therefore assume that the DF-31B ICBM has both a mobile and a silo basing mode, with the latter adding the J suffix to its designation.
Doctrinal shifts, arms control, and early warning
Beyond tweaks to China’s force posture and nuclear stockpile, the CMPR also offers some additional details with regards to its assessment of China’s nuclear doctrine. In particular, it expands on its previous assessments of China’s pursuit of an “early warning counterstrike (EWCS) capability,” which it calls “similar to launch on warning (LOW), where warning of a missile strike enables a counterstrike launch before an enemy first strike can detonate.” For the first time, the CMPR offers details into the capabilities of China’s early warning systems, stating that “China’s early warning infrared satellites [Tongxun Jishu Shiyan (TJS), also known as Huoyan-1] can reportedly detect an incoming ICBM within 90 seconds of launch with an early warning alert sent to a command center within three to four minutes.”
It also notes that China’s ground-based, large phased-array radars “probably can corroborate incoming missile alerts first detected by the TJS/Huoyan-1 and provide additional data, with the flow of early warning information probably enabling a command authority to launch a counterstrike before inbound detonation.” If this is accurate, it would appear that China is developing an early warning capability that functions in a similar manner to those of the United States and Russia, which rely on dual phenomenology to confirm the validity of incoming attacks before authorizing retaliatory launches.
The report also notes that “Beijing continues to demonstrate no appetite for pursuing […] more comprehensive arms control discussions,” including those related to a potential US-China bilateral missile launch notification mechanism.
Corruption
The CMPR focuses quite a bit on China’s ongoing measures to combat corruption, which has led to the removal of dozens of senior officials from their posts across the PLA Air Force, Navy, and Rocket Force. The report notes that “[c]orruption in defense procurement has contributed to observed instances of capability shortfalls, such as malfunctioning lids installed on missile silos”––a story which Bloomberg first reported in January 2024. The report notes that “these investigations very likely risk short term disruptions in the operational effectiveness of the PLA.”
Missiles and delivery systems
The 2025 report included a detail that in December 2024, “the PLA launched several ICBMs in quick succession from a training center into Western China.” Contrary to the launch from Hainan Island, there was very little public reporting about this salvo launch.
The CMPR also indicates an estimated growth in China’s ICBM and IRBM launchers by 50 each, although it is unclear whether these numbers include both finished launchers as well as those still under construction.
The following graph indicates the growth of China’s launchers and missiles, as assessed by the Pentagon, over the past 20 years. It is important to note that many of these missiles, including China’s short- and medium-range ballistic missiles and its ground-launched cruise missiles (GLCMs), are not nuclear-capable.
Our 2025 overview of China’s nuclear arsenal can be freely accessed here.
The Nuclear Information Project is currently supported with generous contributions from the Carnegie Corporation of New York, the New-Land Foundation, Ploughshares, the Prospect Hill Foundation, and individual donors.
What’s New for Nukes in the New NDAA?
At the time of publication, the NDAA had passed both chambers of Congress but had not yet been signed by the president. The Act, S. 1071, was signed into law on December 18.
Congress’ new annual defense spending package, passed on December 17, authorizes $8 billion more than the Trump administration requested, for a total of $901 billion. The FY2026 National Defense Authorization Act (NDAA) paints a picture of a Congress that is working to both protect and accelerate nuclear modernization programs while simultaneously lacking trust in the Pentagon and the Department of Energy to execute them. Below is an overview of provisions of note in the new NDAA related to nuclear weapons.
Sentinel / Intercontinental Ballistic Missiles
Every year since fiscal year (FY) 2017, Congress has inserted language into the NDAA prohibiting the Air Force from deploying fewer than 400 ICBMs (an arbitrary requirement put in place by pro-ICBM members of Congress fearful of any reductions in the force). The FY26 NDAA does not break this streak; in fact, it entrenches the requirement deeper into US policy. Rather than repeating the minimum ICBM requirement as a simple provision as previous NDAAs have done, Section 1632 of the new legislation inserts the requirement into Title 10 of the United States Code (the US Code is the official codification by subject matter of the general and permanent federal laws of the United States. Title 10 of the Code is the subset of laws related to the Armed Forces). This change means that Congress will no longer have to agree to and insert the requirement into the NDAA year after year. Instead, the requirement becomes the permanent standard and will require an affirmative change in a future NDAA to undo. Beyond requiring the Air Force to deploy at least 400 ICBMs, the new defense spending act additionally amends Title 10 of US Code to prohibit the Air Force from maintaining fewer than the current number of 450 ICBM launch facilities (essentially meaning that the Air Force cannot decommission any of the 50 extra launch facilities in the US inventory).
This change is indicative of a desire by Congress to bolster its protection of the ICBM program in response to increased scrutiny prompted by the ever-growing budgetary and programmatic failures of the Sentinel ICBM program. Interestingly, a provision in the Senate version of the defense authorization bill that would have established an initial operational capability (IOC) date for the Sentinel program of September 30, 2033, did not make it into the final text, suggesting a lack of confidence in the Air Force’s ability to achieve the milestone. With an original IOC of September 2030, the September 2033 date would have aligned with the Pentagon’s 2024 announcement that the Sentinel program was delayed by at least three years. The omission may thus indicate Congress’ anticipation of potential further delays to Sentinel’s schedule beyond the Air Force’s most recent estimate.
Nuclear Armed Sea-Launched Cruise Missile (SLCM-N)
In addition to protecting the most politically vulnerable nuclear weapons programs, the FY26 NDAA also aims to speed up US nuclear modernization and development, in some cases even beyond the requests of the administration. Despite the fact that the Pentagon’s FY26 budget request requested no discretionary funding for the nuclear-armed, sea-launched cruise missile (SLCM-N), the NDAA authorized $210 million for the program — on top of the $2 billion to the Department of Defense and $400 million to the National Nuclear Security Administration (NNSA) included in the July 2025 reconciliation package to “accelerate the development, procurement, and integration” of the SLCM-N missile and warhead, respectively.
Most notably, the new defense authorization act speeds up the SLCM-N’s deployment timeline by two years. Section 1633 of the act repeats the IOC date of September 30, 2034, established by the FY24 NDAA, but also requires DOD to deliver a certain number of SLCM-N — a number to be determined by the Nuclear Weapons Council — by September 30, 2032, to achieve “limited operational deployment” prior to IOC.
Future nuclear development
In addition to speeding up the deployment timeline for SLCM-N, the FY26 NDAA initiates and accelerates the development of new nuclear weapons by creating a new NNSA program in addition to the stockpile stewardship and stockpile responsiveness programs: the rapid capabilities program. The new program — established by section 3113 of the NDAA via insertion into Title 50 of the US Code (War and National Defense) — is tasked with developing new and/or modified nuclear weapons on an accelerated, five-year timeline (compared to the traditional 10-15 year timeline for new weapons programs) to meet military and deterrence requirements.
Numerous provisions in the new NDAA reflect a lack of trust by Congress in DOD and DOE’s ability to execute and deliver nuclear modernization programs. The creation of stricter and more detailed reporting requirements and action items for making progress on various nuclear weapons related programs constitute an increased effort by Congress to micromanage nuclear modernization programs.
One example of nuclear micromanagement in the act are Sections 150-151 regarding the B–21 bomber. Section 150 mandates the Air Force to submit to Congress:
- An annual report on the new B–21 nuclear bomber including:
- An estimate for the program’s average procurement unit cost, acquisition unit cost, and life-cycle costs,
- “A matrix that identifies, in six-month increments, plans for and progress in achieving key milestones and events, and specific performance metric goals and actuals for the development, production, and sustainment of the B–21 bomber aircraft program” (with detailed requirements for how the matrix should be subdivided and what information it must include),
- A cost matrix (also in six-month increments and including specified subdivisions),
- A semiannual update on the aforementioned matrices.
In addition, the provision requires the US Comptroller General to “review the sufficiency” of the Air Force’s report and submit an assessment to Congress. The following section of the NDAA additionally requires the Air Force to submit to Congress — within 180 days of the act’s enactment — “a comprehensive roadmap detailing the planned force structure, basing, modernization, and transition strategy for the bomber aircraft fleet of the Air Force through fiscal year 2040” (once again, including detailed requirements for what information the roadmap must include).
In a similar fashion, Sections 1641 and 1652 lay out strict reporting and planning requirements for sustaining the Minuteman III ICBM force and developing the Golden Dome ballistic missile defense program, respectively.
Such efforts by Congress to increase its management of US nuclear weapons programs could be in response to repeated and ongoing delays, cost overruns, and setbacks, or could simply reflect Congress’ desire to seize more control over the nuclear enterprise to get what it wants (or, likely, a bit of both). To be clear, Congressional scrutiny into nuclear programs is welcome amidst a trend of over-budget and behind-schedule procurement of unnecessary weapon systems by the Pentagon. Congress can and should play an important role in ensuring that the Departments of Defense and Energy are not handed blank checks for nuclear modernization.
That said, with this legislation, Congress authorized nearly $30 billion in spending for select nuclear weapons programs in FY26 alone. The tables below, developed by the Center for Arms Control and Non-Proliferation, show a breakdown of Congress’ authorizations for these programs:
This article was researched and written with generous contributions from the Carnegie Corporation of New York, the New-Land Foundation, Ploughshares, the Prospect Hill Foundation, and individual donors.
“I’ve always been around people who make a living by caring”: an interview with Impact Fellow John Whitmer
The Federation of American Scientists was founded on November 30th, 1945. For our 80th birthday, we have been reflecting on the innovation and impact the organization has made in the world. One of the ways we have made tangible contributions in the realm of science and technology is with the FAS Talent Hub’s Impact Fellowship.
Since its launch in March 2021, the Impact Fellowship has provided a pathway for federal leaders to access leading industry experts interested in a “tour of service” in the federal government. Our first Impact Fellow to serve in the federal government was Dr. John Whitmer. Dr. Whitmer served the Director of the Institute for Education Sciences (IES), the research and development agency for the U.S. Department of Education, evaluating the potential for using Artificial Intelligence (pre-ChatGPT!) for automated scoring of the NAEP exam, among other projects.
For Dr. Whitmer, working in public service was natural. “I’ve always been around people who make a living by caring. My mother was a Psychiatric Nurse, and my wife is a social worker,” he said, “while I’ve always been a ‘techie.’ I’ve also been interested in work that has an impact to improve people’s lives.”
However, for Dr. Whitmer, working in education was a surprise. “I didn’t like school when I was younger, I wasn’t engaged until I started studying computer engineering – Turbo Pascal.” During the “dot-com boom,” he took an alternative route, teaching computer software in a low-income housing community and teaching the queer and trans community how to build websites. This work nurtured his interest in the intersection of data, learning, and societal impact.
In addition to receiving his Master’s Degree in Sociocultural Anthropology and his Doctorate in Educational Leadership from UC Davis, Dr. Whitmer then spent over 20 years working in the EdTech industry. Then he came across an opportunity that he saw as a perfect next step – an Impact Fellowship within the Department of Education’s Institute of Education Sciences (IES).
At IES, Dr. Whitmer focused on generating actionable policy insights from ED’s data sources that can support evidence-based policy on tutoring, learning acceleration, and identifying effective strategies to address interrupted learning due to the COVID-19 pandemic. One of the first, and most important lessons he learned as an outsider entering public service? He learned that the Department of Education had always been doing innovative work, and there was no shortage of that work happening.
“My time at IES gave me insight into how decisions are made within government systems, and the very real barriers to innovation and change that are often rooted in good intentions and concerns to mitigate harm. They also showed me that there are pockets of innovation where you might least expect it, and to not underestimate the resilience of federal employees and civil servants.”
Dr. Whitmer is currently Senior Research Scientist & founder of Learning Data Insights, a technical services and software product agency providing support to education technology companies, philanthropic foundations, and other organizations seeking to build and evaluate AI-powered applications and solutions in education. Additionally, John co-chairs the AI in Measurement Subcommittee of the National Council of Measurement in Education.
Team Science needs Teamwork: Universities should get in on the ground floor in shaping the vision for new NSF Tech Labs
It has been 10 years since the National Academies of Sciences (NAS) published its 2015 consensus report on Enhancing the Effectiveness of Team Science, recognizing then that the growing trend toward collaborative and team-based research required guidance on organizational and funding structures, leadership, and team composition. In the decade that followed, the U.S. scientific enterprise experimented with different models for delivering on the promise of “team science”—from university-based centers to new mission-focused government agencies (e.g. ARPAs) to more recently Focused Research Organizations (FROs). Each approach has converged on both the challenge and the opportunity—that team-based science is a critical engine of discovery for complex national problems—but its success depends far more on incentives, leadership, governance, and institutional reward systems than on scientific talent alone.
Today, the Directorate for Technology, Innovation and Partnerships (TIP) of the National Science Foundation (NSF) announced its plan for an ambitious pilot “Tech Labs program,” a $10 to 50M per year initiative designed to harness a team-based approach to tackle national scientific priorities, such as quantum technology, artificial intelligence, critical materials, semiconductor manufacturing, and biotechnology. Though we now have multiple examples of philanthropic and venture capital-funded entities, NSF’s Tech Labs will be the first predominantly federally funded entity, similar to a Focused Research Organization (FRO), structured to harness foundational science in high leverage teams in ‘independent organizations’ to execute on outcomes-based initiatives aligned with a federal science agenda. This initiative promises to fill a critical gap in the federal science and innovation ecosystem, making a space for rapid, high-risk, system-level capabilities that could prove foundational in building national technical capabilities—things that markets, universities, and philanthropy cannot do on their own. The Federation of American Scientists applauds this significant milestone for the U.S. scientific enterprise, but also offers several considerations to ensure that diverse scientific talent, from universities and the private sector, can fully see themselves in this emerging vision.
A central feature for NSF-funded Tech Labs is that they must be “independent,” meaning that they must have organizational and operational autonomy, as well as the freedom to act outside of academic or corporate constraints. This is an intentional design feature that ensures teams can operate like a mission-driven applied R&D organization, with their own authority, hiring, IP strategy, and operational systems. Universities have a key role to play. They can serve as a key source of ideas, facilities, personnel, and future talent, but their ingrained “publish or perish” culture and the existing incentive structure for tenure and promotion may systematically limit participation of university faculty and students in a potential NSF Tech Lab project. At a time when universities are already facing intense pressure to re-envision their role in the science and technology (S&T) ecosystem, we encourage both universities and the NSF to take steps to ensure complementarity and co-benefit, providing pathways for ambitious research acceleration that can leverage expertise and infrastructure that universities can contribute. We offer the following ideas to consider:
Create Intentional Pathways for Talent Mobility between Universities and Tech Labs
- Students. Tech Labs could become a rich training ground for future scientists and entrepreneurs and students could become critical components of “portable research teams.” For example, graduate students and postdocs could be embedded full-time at a Tech Lab but tuition could still flow to the university and salaries be co-funded. Joint deliverables could include academic publications and also milestone-based efforts that align with research goals.
- Faculty. Similar to the NSF Rotator model, consider the creation of a short-term appointment category (e.g. “Tech Lab Program Scientist”) that creates a hybrid tour-of-service model for tenured faculty to participate in a Tech Lab team.
Align financial incentives and share critical infrastructure
Independent NSF Tech Labs could develop milestone-based, block grant, subcontracts to university labs to leverage the use of critical equipment and physical space. This will help reduce administrative burden to universities and counter potential loss of indirect expenses.
With the comment period that opens today, NSF is inviting broad stakeholder input into this ambitious vision. This launch of the first federally funded FRO could mark a transformational moment for the U.S. science enterprise, changing what kinds of science and engineering become possible at all and enabling the execution of innovation at scale. But success will depend on broad buy-in and willingness to test this model. Please share your thoughts by January 20th about how to set this bold experiment up to deliver on the decade-long promise of “team science” and set the scientific research enterprise up to embark on a new era of innovation.
NSF Plans to Supercharge FRO-style Independent Labs. We Spoke with the Scientists Who First Proposed the Idea.
Today, the Directorate for Technology, Innovation and Partnerships (TIP) of the National Science Foundation (NSF) announced its plan for an ambitious pilot Tech Labs program, a “new initiative designed to launch and scale a new generation of independent research organizations” for up to $1 billion. FAS CEO Daniel Correa recently spoke with Adam Marblestone and Sam Rodriques, former FAS fellows who developed the idea for FROs and advocated for their use in a 2020 policy memo. This conversation has been lightly edited.
Daniel Correa: In 2020, you both published the initial blueprint for Focused Research Organizations (FROs). A lot has changed since then. How far has this idea come in the years since?
Adam Marblestone: FROs are now a commonly discussed concept among scientists thinking about how to structure and fund new tools, systems, dataset or scientific infrastructure moonshots. This has arguably increased the level of ambition in the community and created more incentive to imagine and roadmap larger, more systematic and ambitious projects.
The high level of interest in FROs across many fields has shown us that they can help fill an important category of gap or bottleneck in the scientific landscape.
Convergent Research, a nonprofit incubator and parent organization for FROs, which I lead, has launched 10 FROs and counting in fields as diverse as brain mapping, non-model microbes, ocean carbon modeling, software for math, and faster-cheaper-better astronomy.
There are also other FROs that have emerged outside Convergent, such as Bind Research in the UK. Also in the UK, ARIA has funded Convergent to run a FRO residency, which will likely lead to 1-2 new UK based FROs in 2026. We are really excited to see the NSF announcement!
DC: What are some of the biggest successes?
AM: Early FROs are in full swing doing science.
They have released major datasets such as the largest map of the “pharm-ome” (drug target interactions) and a global atlas of ocean alkalinity enhancement efficiency.
They’ve published many preprints on new tools and methods, including new self-driving labs for DNA delivery to speed research in novel organisms and new approaches for capturing biological protocols for translation to robotics.
They’ve improved the cost-performance of proteomics by 27x already, and built software that has underpinned new industries like AI for math where there are now unicorn companies emerging partly as a result of these tools.
They’ve introduced new methods for brain circuit mapping that could help make mapping entire mammalian brains cost effective and put new neural interface devices in human studies with unprecedented speed and safety.
A small number of FROs have transitioned into new nonprofits as well, and we will also soon see the first major commercial spinouts of their technologies.
Perhaps most importantly, extremely talented scientists, engineers, operators and leaders have been joining FROs, proving that these distinct institutions can indeed attract and retain top talent. These people span a huge range of academic and industrial backgrounds and career stages. Much more top talent has reached out with interest in starting their own ambitious FROs. A lot of that top talent wants to work on big goals in a tight-knit, fast moving team setting.
In the process, more than 30 philanthropic organizations of many kinds, and several government organizations, have put funding into FROs at various stages.
DC: Let’s back up. Can you remind us about where the independent labs model is most potent – the kinds of applications where we should expect to see CEO-led, team-based, time-bound focused research will deliver breakthrough results? I’m talking about about those that are not properly incentivized by more traditional research structures. Infrastructural technologies that enable other research, for example. What else?
Sam Rodriques: As I covered in an overview of the private lab landscape, there are actually many kinds of independent labs, some focused and milestone driven like FROs, others more exploratory, and with many different sizes. FROs are one sub-type of this menagerie. (FutureHouse, for example, which I co-founded, is a private lab but is a bit different from a canonical FRO.)
This is also clear from IFP’s excellent X-Labs proposal.
“X02 X-Labs” sound a bit like how we see FROs: they are execution focused and develop well defined tools, systems, datasets or other products that can un-block progress in an entire field. Things like 100x cheaper proteomics for biology, or a verifiable programming language for expressing mathematics. These projects are too large and coordinated for the individual-focused incentive structures of academia, and require professional technical and operational staff all working together on the same system with tight engineering coordination. They function in many ways like deep tech startups, except with greater focus on public goods creation, longer timescales and a primary goal to accelerate R&D versus make money for investors.
But there are other kinds of proposed X-Labs that would be more like open ended institutes concentrating talent and resources on a broader problem area and generating more serendipitous discovery versus goal directed system building. This is more like the “X01 category” in the IFP X-Labs proposal.
There is also a need for meta-level organizations like Convergent Research which are more like “X03s”, they roadmap fields, identify and incubate promising teams to solve bottlenecks, and oversee and act as parent organizations or regrantors for a set of projects.
DC: It should be obvious, but is still important to note, that not everything should be an FRO. There is still a very key role for academic research and training, for startups and companies, for individual fellowship support, for ARPA style coordination, for other kinds of labs and institutes, and so on. The key is to have a diverse ecosystem containing many complementary strengths. In no way are FROs “better” than other mechanisms in any generic sense – they just fill one important category of gap in the system as it otherwise exists.
SR: There is also a very real sense in which the FRO model is still early in its evolution and still an experiment, or really many experiments.
DC: Despite all of the progress, federal support for independent lab models to date has been limited, though it’s been exciting to see their inclusion in America’s AI Action Plan from earlier this year. This week’s announcement suggests that’s changing. What role can federal funding play in the evolving ecosystem?
SR: Philanthropy has prototyped the model, and we are beginning to see federal support.
Federal support can change the game in a few ways, beyond the obvious but important aspects of capitalizing the emerging ecosystem at a larger scale to allow more to be done overall.
First, while philanthropic funding can be fast, federal funding can be more systematic and predictable. Rather than a somewhat ad hoc process of “match making” between goals, projects, teams and philanthropists, federal agencies can back broad open calls for FROs in specific areas or across fields. Clear backing to be made available at the end of an open and regimented selection process will ultimately drive creation of the highest quality FROs, providing predictability and clear timelines and milestones for all involved stakeholders.
Second, the convening power of the federal government is huge, which is important for setting up FROs from day one with top partnerships, scientific community input and scalable dissemination paths. We’d love to see FROs nucleated deliberately as a step on the way to larger government programs and projects, e.g., a technology development FRO could reduce the cost of key data collection for a subsequent federal data collection or foundational model training moonshots.
Federal agencies could also approach FROs programmatically, funding directed projects to remove not just one but many key bottlenecks to progress in an area systematically.
It would be great to see federal agencies back not only individual FROs, but also some FRO creation and support organizations, in line with the idea of “X03s” in the X-Labs proposal.
DC: Any advice for NSF and other federal agencies hoping to play a catalytic role? What kinds of funding and support can the federal government most usefully provide? How much of a culture change will this require for funders who typically operate on a peer-review, hypothesis and publication-centric model?
AM: Convergent has learned that the role of the “X03 style” meta level organizations can be a potent one. It provides operational support, stable and experienced governance, best practices, and a strong community of other FROs, among other things. New potential FROs don’t have to do it on their own. They can work with others who have done it before to help get started and to manage change.
Convergent recently published some “field notes” on learnings from running an incubator and parent organization that has launched many of the early FROs.
Tactical learnings include the importance of balancing specificity and flexibility in internal and funder facing milestones; the dynamic nature of startup-like founding teams and the benefits of good governance structures; the importance of having a scaled revolution in mind beyond the FRO itself with a strong theory of change for transformation of an entire field; the need for executive coaching for project leads, and so on.
FROs are what would typically be called “high risk, high reward” projects (although we think this terminology has some conceptual problems), and they should not be designed by committee nor can risk be eliminated from them. “Empowered program manager” models could potentially be helpful in implementing FRO programs to get at sharp, non-consensus ideas and people. But we have in fact extensively peer reviewed all of Convergent’s FROs and received valuable input in the process – the question is how peer review feedback is used and whether the peer reviewers and program officers understand the nature of these ambitious and radical projects.
Certainly this requires going beyond what we currently think of as the standard hypothesis driven research funding model. FROs aim for broad technological enablement of entire fields, allowing more rapid search through wide spaces of hypotheses, rather than answering narrow or incremental questions. We’ve tried to illustrate this broad category with the Convergent “Gap Map” where we summarized conversations with many scientists into an incomplete and preliminary list of potential opportunity areas for this kind of project.
Traditional journal publication is probably too slow a mechanism to be integral to a FRO lifecycle during its active sprint. FROs are using preprints and other forms of dissemination a lot in practice, to get things moving and out there faster.
DC: NSF’s Tech Labs announcement contemplates a variety of potential applications. Do you have any reflections on where NSF’s support could be most useful?
SR: There are a lot of efforts to drive commercialization and entrepreneurship. A FRO mechanism should allow maximum catalysis of a field through advanced research and technology, even if that is deeply pre-commercial or open source and public goods focused. That will likely be most distinct from what the private sector is doing well already.
DC: Any advice you’d give to someone hoping to start one of these independent team-based science organizations, such as mistakes to avoid?
AM: Try to be as concrete as possible about what you’ll build, and about the theory of change for how that will be used – a very clear North Star. Don’t just propose to solve a general area, investigate a question or form a strong collaboration. What will you build? Why is it massively and disruptively better than the state of the art? How will this reach at scale adoption and ultimately drive profound and otherwise unachievable transformation?
Carve out the FRO shaped problem. If it can be done in an existing institution, just with more money, it probably isn’t a FRO. If it is too broad, it probably isn’t either.
Think about creating a well rounded founding team with scientific, technological, management and other expertise. Don’t come in with too many presumptions about exactly what the roles will be within it as the team gels. There will be a lot of entrepreneurial learning at the individual and group levels.
Importantly, make sure everyone on your founding team has absolute clarity about what the North Star of the project is and is “all in” on the endeavor. It’s a big commitment. Don’t dilute the concept by making it generic, and make sure what you’re proposing has the potential to be as disruptive as, say, next-generation sequencing was for biology or the ImageNet dataset was for deep learning.
And consider reaching out to others who have started to pursue the FRO path.
SR: From my perspective, the most important thing is that the form of the organization must be derived from the organization’s mission. When we wrote down the FRO proposal originally, we enumerated some best practices, such as the notion that FROs should be funded for 5 years up-front, and that they should spin down or spin out at that point. These are good general guidelines that are useful for funders to orient around. However, founders need to figure out what works for them and their mission: if your mission is going to take three years or seven years, that’s fine. If your mission requires three separate projects rather than a single unified effort, also fine. Funders should have flexibility to adapt their funding to the needs of the project.
Another common failure mode I observe among FRO founders is the notion that the alternative form of funding that FROs receive means that they can just put their heads down and focus on research, rather than worrying about publishing their results, fundraising, or so on. I strenuously disagree with this. FROs should publish early and often, and should engage regularly with funders, even when they do not immediately need funding. Publishing your work and talking to funders are two ways you get feedback on the work you’re doing. The faster you get feedback, the more quickly you can iterate to higher quality.
Finally, FROs are indeed closely inspired by startups. You should learn about and consider all of the standard advice given to startup founders. Iterate quickly. Remember that execution is virtually always more important than concept. And, in particular: avoid big egos on your team. They are very challenging to manage, and are also very challenging when it comes to building team cohesion. This is especially important advice for FRO founders who may come from and have strong ties to academia, which is sometimes home to big egos.
Demystifying the New President’s Management Agenda
By design, the Office of Management and Budget’s (OMB) work follows a predictable, seasonal rhythm: budget guidance to agencies in the spring, strategic management reviews in the late summer, passback in the fall, shutdown saber-rattling in late September, release of the president’s budget request in the winter, and so on. A giant novelty clock in the building counts down the days until the end of the fiscal year, each year, whether Congress has done its work to appropriate money for the next one or not. Presidents, Congresses, crises, political movements – all of these come and go, but OMB’s work largely continues to cycle.
This week, OMB completed one such ritual: it released the President’s Management Agenda (PMA). The PMA–closely watched by federal employee groups, contractors, public administration academics, and the handful of general-public bureaucracy-enjoyers–is the vehicle with which each president outlines policy priorities on how the government manages itself. Each 21st-century president has had one, after George W. Bush’s Administration issued the very first one in August of 2001–and President Trump is the first to have issued two discrete ones.
Not familiar with this ritual? You’re not alone. Though not statutorily required, a PMA is meant to be a blueprint for improving how the federal government delivers policy, whether hiring, buying, designing services, listening to Americans, measuring performance, or delivering financial assistance. A PMA is also load-bearing, one of the few levers capable of coordinating action across the enormous machinery of government, aligning budgets, capacity, and accountability behind long-term modernization rather than the short-term crisis response that often drives management changes.
In a year when management issues like human capital, IT modernization, and improper payments have received greater attention from the public, examining this PMA tells us a lot about where the Administration’s policy is going to be focused through its last three years. As we did for a major policy release on hiring earlier this year, the Federation of American Scientists and the Niskanen Center are teaming up to break down and contextualize this year’s PMA.
The Structure of the PMA
As OMB noted in an accompanying memo to this PMA release, the core of the PMA has for many years, been a set of cross-cutting “priority goals” that OMB is required to establish under the Government Performance and Results Act Modernization Act (GPRAMA) of 2010, which codified much of what the Bush and Obama Administrations had done to focus on performance-based goal setting and reporting. Over the years, the PMA has grown to be the organizing principle for these priority goals, explaining how they relate to one another and are part of a broader coherent whole.
This current iteration of the PMA (reproduced below) is organized – like the Biden Administration’s was – as something of a nesting doll. It has three broad priorities, each with a few goals, and a series of objectives within each of those goals:
Unlike previous iterations of the PMA, it appears this new one won’t be accompanied by the type of long narratives and explanations typical of the Bush, Trump I, and Biden PMAs. It also differs somewhat from the Obama Administration’s approach, which focused on a series of detailed “Cross-Agency Priority (CAP) Goals that largely cohered into a formal PMA after the fact as GPRAMA was passed during the term and codified the modern process mid-stream.
Regardless of how they start, however, previous administrations have largely committed to providing ongoing reporting on their progress towards achieving each objective or goal throughout the remainder of the term. It is not yet clear whether the second Trump Administration intends to do this–Congress should inquire about their GPRAMA obligations–but in general this practice has been valuable both to keep agencies accountable for making progress and so that interested third parties can get a window into how the government is changing over time.
In the meantime, this week’s release gives us enough insight into the contours of this term’s PMA to assess how it compares with previous efforts and with what we’ve learned from observing and managing past PMAs.
What’s Promising: A Renewed Focus on Some Hard Problems
Normally, the PMA contains two types of initiatives. The first are evergreen topics —such as the perennial need to hire federal employees more quickly and efficiently—which have appeared in every PMA to date. The second category consists of more idiosyncratic or extremely timely “hard problems” that either haven’t received attention or where past reform has stalled. In the Biden PMA, for instance, this included integrating lessons from the pandemic’s disruption of work life. In the first Trump Administration, it included an ambitious overhaul of personnel vetting transformation on the heels of the massive OPM security clearance data breach in 2015.
Occasionally, these hard problems “graduate” out of the PMA once sustained focus produces results. The PMA’s emphasis on personnel vetting, for example, has largely given way to a multi-year, bipartisan Trusted Workforce 2.0 strategy that has and is making progress despite its challenges.
This year’s PMA includes several such issues, offering the second Trump Administration an opportunity to spotlight underappreciated but consequential aspects of federal management, including:
- Offloading unnecessary leases and buildings: Federal facilities and real estate have never truly been managed as a portfolio with all the transparency, tradeoffs, accountability and management that entails. Before the pandemic, many agencies had significant excess office space and struggled to offload unneeded square footage, even as the average age of federal facilities climbed north of 50 years old and many buildings are no longer suitable for modern work. Rationalizing and right-sizing this portfolio is a worthy and important initiative but it will be difficult: Congress has historically underfunded agencies that are aiming to reconfigure or move, and individual members of Congress frequently oppose specific office closures among their constituents. Any effort to responsibly modernize these real estate holdings will take a lot of patience and willingness to take on sacred cows, but has the potential to earn significant savings and efficiencies.
- Holding contractors and grantees accountable for performance: Most indirect federal spending flows through intermediaries and, too often, the outcomes agencies define for their work are unclear, don’t meet intent, cost more than they should, or aren’t set up for other stakeholders to learn from. Many agencies are captured technologically, intellectually, and psychologically by vendors, leading to a type of learned helplessness where their inability to technically manage contracts leads to an inability to hold them accountable for their performance. Fighting these entrenched forces and inertia is not easy, however, and will require arming agencies with the federal experts, tools and training necessary to change their approach to vendor and grantee management but also give them top-cover to push back on powerful, politically-connected awardees that fail to deliver again and again without consequence.
- Eliminating data silos: While data protections necessarily inhibit privacy and security violations, too much federal data sits in silos built by habit, culture, or old technology. Driving responsible interoperability could have a meaningful impact on service delivery, including for two of the thorniest issues in public service delivery: identity regulation and eligibility verification. However, prior actions and whistleblower complaints about misuse of personal citizen data put an imperative on the Administration demonstrating its commitment to data security under this PMA initiative. It presents an opportunity to right the ship and build the type of trust that will be required from Congress and the public to make good on the transformative power of better data management.
- Removing poor performers: The federal government has long struggled to swiftly remove poor-performing employees. The system we have today was never intended to be permanent or perfect—it was meant to provide incremental improvements toward processing removals quickly but fairly. Nearly every former deputy secretary, in administrations of both parties, has wished they could establish a simple, actionable, repeatable framework for performance management that includes reasonable safeguards. This Administration has an opportunity to chart that path. But proceeding without those safeguards—particularly protections against arbitrary or partisan dismissals—risks undermining good-faith reforms that are crucial for cross-partisan credibility and for helping managers manage well.
- Building the most agile and efficient procurement system: The Revolutionary FAR overhaul underway at OMB and the General Services Administration (GSA) is a concrete opportunity to modernize federal buying at its foundations by paring back the FAR to just its “statutory” requirements and allowing agencies to buy more flexibly. But the regulation update is at best only half the battle: the administration will need to dedicate time, people, and championship to making them stick in training, norms, culture, and leadership. It also needs to resist the temptation to add back its own non-statutory clauses, an impulse that led to the FAR’s bloated and unwieldy state in the first place.
Ideally, success in these areas means they will eventually fade into the background of standard management practice. Agency leaders may not earn themselves splashy press coverage or public adulation by improving procurement or tackling data silos. No agency head wants to spend time grappling with underutilized buildings. Genuine progress here, however, would allow future leaders to remain focused on mission delivery.
What’s Returning: Places to Learn from the Past
This brings us to the evergreen PMA topics. To GPRA veterans, some of the things in here are expected and represent the evolution of years of work by Republicans, Democrats, and nonpartisan civil servants to make the government run better. Many of these reflect years–or even decades–of work to address some of the core challenges of managing a large organization in any sector (how to hire the right people, how to buy effectively, how to build and secure systems, etc.)
But there’s a deeper reason these issues recur, beyond aspirations for bipartisan comity. Adding an item to the management agenda is only a starting point. Meaningful progress requires far more than a talking point, executive order, or regulatory tweak. Leadership attention and cover, technical capacity to actually understand, teach, and monitor reform, oversight partnerships that orient their activities to the new model, administrative data that’s accurate, real-time, and actionable, and central funds to resource pilots too edgy to get agency support or toolkits that no one agency wants to own.
In this PMA, some of these evergreen topics include ones this Administration can learn from its predecessors and accelerate towards success, including:
- Tackling improper payments, fraud, waste, and abuse: The Trump Administration inherits a solid foundation in this area from its predecessor, which invested serious effort into tackling the surge in improper payments in the COVID-19 era. That work included investing in upfront controls, fraud prevention, and collaboration between agencies and their oversight communities. The Government Accountability Office, Agency Inspectors General, and others have also long offered suggestions about how to continue to reduce the government’s improper payments rate. Groups like the Payment Integrity Alliance are developing new technology-powered tools to support this work from outside government. These are evidence-based solutions that are likely to work, as opposed to arbitrary, highly-partisan, and ultimately untrue declarations of fraud that marked the early days of this Administration, in addition to counterproductive efforts to cut or constrain the oversight community. As OMB looks towards 2026, it should take into account these models.
- Streamlining the federal workforce and eliminating duplicative programs: While this year’s efforts are the first in a couple decades to seek to dramatically reduce the size of the federal workforce, they are not without precedence in American history. Following both World Wars (and especially through the late 1940s), the federal government had to demobilize hundreds of thousands or millions of civilian employees in a way that both treated them with dignity and economized on taxpayer dollars. More recently, in the 1990s, the Clinton Administration also conducted large-scale downsizing, with decidedly mixed results because the cuts came before changes to agency to-do lists that never materialized. It will be important for this Administration to learn lessons from the past to avoid some of the long-term damage wrought by the Clinton years, for which agencies are still paying.
- Hiring exceptional talent for key presidential priorities based on skills and merit: All presidents have priorities and many of those involve some kind of hiring surge: following 9/11, the Bush Administration had to rapidly create and staff up the Department of Homeland Security for new mission sets–for example, like airport security. More recently, the Biden Administration conducted several surges around topics like the Bipartisan Infrastructure Law and artificial intelligence. To make this work, previous efforts have succeeded by setting up dedicated teams that focused on specific, measurable goals and bought-in mission area leadership to champion the effort. As OMB and OPM consider their efforts this time, they should explore common data standards to ID bottlenecks, interagency approaches to share resources and talent, and investing in all the accoutrement to new and updated career paths and roles – and doing their best to embed these practices in the system, not just as part of a special effort.
They might also consider reactivating networks and programs that were successful in previous eras, like Tech to Gov, which worked across sectors to hire technologists into government. On merit and skills based hiring, implementation appears to be under way with a variety of initiatives that have promising goals, but will require significant investment of resources and leadership attention to complete, as we’ve written about.
- Buy as one entity: smarter, faster, cheaper: Successive administrations, dating back several decades, have tried to strike the right balance between decentralized and centralized procurement. The Clinton team, for example, called for greater decentralization to agencies because it “allows strangers-often thousands of miles away-to make purchasing decisions.” More recently, however, administrations have gone in the other direction, including a discrete goal to drive category management in the first Trump PMA, though agencies often still complain about being forced to use government-wide vehicles that don’t meet their exact custom needs.
To avoid the pendulum swinging back and forth between centralization and decentralization, efforts to implement this PMA should learn from efforts to achieve savings by transparent use of procurement data that were pioneered in the Biden Administration like the Procurement Co-pilot, Hi-Def initiative, and the strategic acquisition data framework. Rather than mandates from above, these initiatives help drive savings and get “spend under management” by solving information asymmetries and transparently helping agencies understand “what’s in it for them” when they use best-in-class contracts.
- Consolidate and standardize systems, while eliminating duplicative ones: The federal government has long operated on a system of both shared, government-wide, and also bespoke agency systems. The Bush, Obama, and first Trump administrations had OMB focusing on consolidating duplicative systems across government through shared services. This model, while promising in many cases, is difficult to pull off in practice – of those initiatives, the Bush Administration’s payroll consolidation is far and away the most successful, while efforts to adopt standard payment system (e.g., e- and g-invoicing) and innovative payroll solution have languished, as did GSA’s NewPay program.
This PMA should take to heart the lessons of its predecessors: agencies must be resourced up front to execute their part of any migration to shared systems, and OMB must ruthlessly prioritize and rigorously validate any requests for deviations from the standard product. In most cases, it will be far easier—and considerably cheaper—to adjust policy to fit a modern, standard solution than to customize that solution to accommodate every agency’s unique requirements.
Leaders should also address the internal politics of these transitions directly. Champions of bespoke systems often have deep attachment to their legacy tools, and their resistance can be stronger and more personal than expected.
- Defend against and persistently combat cyber enemies: Reactive and proactive cybersecurity has been a central federal government focus as long as government systems have been connected to the internet. Of all the discussed areas, continuity is perhaps most crucial to cybersecurity, with the need for sustained attention to legacy system replacement, identity management, continuous monitoring, secure architectures, and the significant talent demands that come with all of those. This Administration should heed the lessons of its predecessors, which lost valuable time to bureaucratic reshuffling and inconsistent “carrot vs. stick” approaches in its engagement with the private sector.
It’s never going to be possible to truly “solve” these issues that are core parts of ongoing management in any large enterprise. However, because progress is incremental, this PMA can accelerate its own impact by learning from what has and hasn’t worked in the past.
What’s Missing: Outcomes for Americans
There is, however, one “evergreen” PMA topic that we’re surprised to see missing from this iteration: Customer Experience (CX).
The previous two PMAs featured big customer experience pushes to modernize and centralize how the government designs, delivers, and updates benefits based on customer needs. These delivered favorable results for veterans’ benefits, disaster survivors, new families, travelers and more, and fostered innovative approaches to benefits delivery like the cross-agency “life experience” program that reconceptualizes the way the government engages with people who need its support. In recent years, the bipartisan success of these initiatives has led to four straight years of improvements in the industry-standard American Consumer Satisfaction Index, with the government closing out last fiscal year at an impressive 19-year high.
While this PMA does mention “digital-first services” that are “built for real people, not bureaucracy,” that principle sits inside a technology-and-efficiency frame rather than a clear commitment to outcomes for the public. What’s missing is an explicit stance that service delivery, burden reduction, and trust-building are core measures of government performance and are not encompassed by a positive government IT experience or a more fetching website design. Plenty of core users of government services–seniors, for example–do not interface with the government in a “digital-first” way, further complicating this as a focus for customer experience.
Hopefully this absence will still allow for the bipartisan CX agenda to continue in other spaces, such as the new National Design Studio. It’s not enough to declare that the government will deliver high-quality services to the people who rely on them. Agencies need the ability to collaborate and know that the White House will back them when they need to request incremental funding to conduct user research or A/B test a new form before rolling out.
A real test of any PMA isn’t how well it modernizes, it’s whether people notice government working better on their behalf. In that way, CX is what we might call the “love language of democracy” and it’s important that OMB is attentive to building that.
What’s Concerning: The Culture War is Coming for Management
The Biden Administration received criticism for attaching progressive goals from environmental standards to equity to labor onto every possible management tool (procurement, grantmaking) until the weight of implementation is slow, diffuse, or nearly impossible. Its PMA embodied that instinct: broad, values-aligned expansive goals that had great intentions but struggled to operationalize.
The new PMA both reacts against and mirrors that instinct: it pairs standard management reforms with culture-war directives that seek single-minded discipline, accountability, and ideological alignment.
At times, it reads like two agendas stitched together: one technocratic, aimed at federal administrators, and one ideological, aimed at unofficial commissars and social media. Alongside modernization goals you might find in any PMA sit directives to:
- Eradicate woke and weaponized programs across government, which is a sweeping slogan with unclear scope at odds with the usual evidence- and performance-based mandates embedded in GPRAMA and past PMAs.
- End discrimination by government, which is a superficially unobjectionable shibboleth, but incorrectly implies that the government has been discriminating in how it carries out its management functions, despite the fact that its equity programs largely only follow the rules Congress has set out in offering employment preference to veterans or procurement preference to certain categories of small businesses.
- Defund DEI, gender ideology, K-12 indoctrination, child mutilation, and open borders, which are culture war buzzwords with no obvious relation to government performance or management issues.
And scope creeps further into territory historically outside PMA (or OMB) control, such as a set of general goals with choose-your-own-adventure interpretation and murky implementation paths, written at a strange distance from the government the Administration oversees:
- Find and annihilate government censorship of speech, which is perhaps the first time annihilate has ended up in an OMB memo and implies that there are “hidden” examples of censorship while the administration pursues overt censorship in other areas.
- Reverse malicious schemes to hide information from Americans, which gestures at a conspiratorial approach to government management that seems at odds with the Administration’s claim that it’s fully in control of the executive branch. It’s difficult to simultaneously claim that there are truths hidden from the public while also deprecating transparency, as in Federal data sets.
- Abolish abusive intelligence activity targeting unwitting Americans, which is certainly a laudable goal for any civil libertarian in a democracy but doesn’t necessarily have any resonance with normally much-duller management functions like HR and finance, which have struggled to accomplish even their overt functions in recent years, nevermind anything more nefarious.
As we’ve written before, hijacking these normally low-temperature operational processes to fight the culture war not only raises the partisan pressure on normally bipartisan issues, but it also “needlessly politicizes our institutions, snarls our civil servants in red tape, and usually fails to achieve even those unrelated objectives.”
Nowhere is this danger greater than in implementation of the PMA’s objective to “[p]ut political appointees in control of grant process to deliver results,” which supposes that political control and, by implication, alignment with the President’s partisan priorities is a main factor in how Congressionally-authorized grants are executed. The President certainly gets to set some overall parameters for grantmaking across the federal government, and politically-appointed agency heads are ultimately accountable for the money they spend.
But this priority implicates a much more arbitrary and politically-motivated process for determining how public funds are spent that strikes at the heart of what makes government action legitimate: the fair application of rules that are defined ahead of time and apply equally to all. Like a similar requirement in the Merit Hiring Plan, this also creates an obvious bottleneck in agency processes as recommendations stack up for political review, reducing efficiency and elongating the path to “results.”
Perhaps including these initiatives–which largely fall outside of the normal OMB management purview–was the price OMB had to pay to get the rest of the PMA through the hyper-partisan (even in normal order) communications processes of the White House. If that’s the case, agencies should be able to largely proceed with the rest of the agenda unbothered by also having to separately organize around these initiatives. But if not, it will be critical to ensure that directing agencies into partisan goose chases does not pull time and attention away from the harder—and ultimately more rewarding—work of genuine management reform.
Declaration is not Implementation
Publicly releasing the PMA is the easy part. The real work goes into changing government. As the Bush Administration’s first PMA noted: “Government likes to begin things—to declare grand new programs and causes. But good beginnings are not the measure of success. What matters in the end is completion. Performance. Results. Not just making promises, but making good on promises.”
Many of the objectives outlined in the PMA are sound ideas with long track records across different administrations. We largely agree with many of them and they echo our policy priorities and those of partner organizations. But their appearances on multiple PMAs underscores how hard these problems are to solve. Category management,real property portfolio rationalization, and cybersecurity, were problems for many years because of the inherent difficulty of tackling them.. This is doubly true for the ideas that are fresh from the front lines of the culture war, which lack both a track record of successes and failures to learn from and the bipartisan support that more established issues—like improper payments or IT modernization—typically receive in Congress.
To actually impact the entire government – one of the largest and most complex enterprises in human history – it’s not enough to just declare that it’s the policy of the Administration that X or Y happens, or even convene regular gatherings of deputies. We’ve seen that approach fail repeatedly: agencies cannot and will not implement a PMA just because OMB issues it.
Real success requires disciplined implementation. That means selecting strategies that genuinely move the needle; setting aggressive but achievable measures and timelines; incentivizing leaders to invest time, attention, and talent in relentless follow-through; maintaining up-to-date metrics and feedback loops to know what’s working and what isn’t; and sustaining clarity of focus all the way to the finish.Without that, it becomes all too easy for OMB and agencies to skate by on superficial changes that check boxes but result in no real systems change–a PMA of performance art, where everyone claps but nothing changes. Amid all the swirl of any White House, this work of sticking the landing is the hardest part.
That’s because the PMA – like any strategy – itself isn’t really valuable on its own. It can, however, cut through the noise, clarify what the priorities are, and provide a framework for holding agencies and leaders accountable as they do their work. Any PMA will rise and fall based on how well it manages to do this. The way this term’s PMA is structured at the outset makes this task supremely difficult because it’s pulling in several directions all at once: it’s trying to simultaneously pass as a deeply partisan political document, a check-list for agencies of recent EOs, and a sober management policy agenda.
The real danger is that this lack of clarity and flurry of culture war buzzwords means nothing changes. That the same broken systems of human capital, procurement, IT modernization, security clearances, and user feedback, that have contributed to what OMB refers to as “accumulating perils” persist for yet another presidential term because OMB’s own management approach mistook a policy memo for progress and failed to chart a path forward. “Declare success and move on” is how these hard problems survive for decades.
This failure mode is easy to imagine: as humbling as it is to admit when you sit at OMB, reform requires changing the habits of work in agencies, sub-agencies, offices, and teams for whom policy memos about HR and procurement are the last thing on their mind (or even in their inbox). This is the hardest work of governance – rewiring workflows, seeding change in budgets, resetting culture – and demands management be treated as a core, can’t-fail function rather than a sideshow of dashboards and Powerpoint.
As they should be, agency implementers are more focused on the day-to-day administration of their programs: achieving their particular program objectives, responding to requests from Congress, serving the public, tracking their own budgets, and managing their own chaotic work lives. If the PMA can’t provide them with clarity, a limited number of clearly articulated goals, and a simple on/off ramp for change, it will be hard to change the direction of travel – not because of some deep state conspiracy, but because they don’t know what to focus on or how they’re going to be measured. What gets implemented, and what people experience, is what counts; everything else is decoration.
What We’re Watching
As with all broad, whole-of-government strategies like this, it will only be obvious in retrospect whether this administration is successful at achieving those goals. However, there are some things to watch out for that will clue close-watchers in about how things are going:
- First, will OMB continue the type of detailed, quarterly status reports that were the hallmarks of previous PMAs and allowed the public to see how things were progressing?
- Second, are there key metrics that OMB and its partner agencies will commit to tracking, reacting to, and publishing to measure their success?
- Third, are agencies resourced to actually accomplish many of these ambitious goals and what do they prioritize (and indeed, since agencies are not mentioned in the PMA itself, what ownership do agencies feel over it)?
Finally, and more abstractly, we’re also going to be looking out for how OMB and others engage with the rest of the PMA-interested community, including career federal employees, good government groups, congressional staffers, think tanks, academics, and others who have trod this same path. The permanent institutions of the federal government don’t serve any one president exclusively; instead, they represent a deep and important investment that the American people have made in themselves as a bedrock of our democracy. While reasonable disagreements about how to do so will certainly always exist, this community can, should, and will embrace a government asking for help. OMB would do well to welcome them in.