Docket ID: OPM-2025-0004
Submitted via Regulations.gov
May 22, 2025

Charles Ezell
Acting Director
U.S. Office of Personnel Management
1900 E Street, N.W.
Washington, D.C. 20415

Comments on Proposed Rule: “Improving Performance, Accountability, and Responsiveness in the Civil Service”

Dear Acting Director Ezell,

On behalf of Taxpayers for Common Sense, we write in strong opposition to the Office of Personnel Management’s proposed rule titled “Improving Performance, Accountability, and Responsiveness in the Civil Service.” Despite its title, the proposal revives and expands the deeply flawed “Schedule F” policy from the previous Trump administration, now rebranded as Schedule Policy/Career (Schedule P/C). This rule would not enhance performance or accountability—it would undermine the professional, merit-based civil service that taxpayers rely on. Instead, the administration should pursue meaningful reforms that strengthen the performance and integrity of the federal workforce.

Taxpayers for Common Sense was founded in 1995 to ensure that federal tax dollars are spent responsibly, transparently, and in the best interests of the American public. For nearly three decades, we have worked to expose and eliminate wasteful spending, promote fiscal accountability, and protect taxpayer investments across all areas of federal policy—from defense to energy to disaster response. Our analysis is grounded in facts, not ideology, and our advocacy is rooted in a commitment to efficient governance that delivers results for taxpayers. We engage with lawmakers, executive agencies, and the public to support common sense reforms that safeguard the integrity and effectiveness of federal programs.

Politicization of the Civil Service Harms Taxpayers

Schedule P/C would allow agencies to reclassify civil servants in vaguely defined “policy-influencing” positions, stripping them of statutory due process protections and rendering them at-will employees who can be dismissed without cause or appeal. As we noted in our public comments during the 2020 attempt to implement Schedule F, this reclassification could sweep in tens of thousands of employees across key agencies such as the Departments of Defense, Homeland Security, and Justice.[1]

From a taxpayer perspective, politicizing the civil service creates instability, inefficiency, and waste. Career public servants are critical to ensuring that government programs—designed and funded by Congress—are implemented consistently and effectively across administrations. Stripping away due process protections puts the stability of the federal workforce at risk. It invites costly turnover, drains institutional knowledge, and makes it easier for political pressure to override expertise—potentially distorting how laws are carried out and weakening the programs taxpayers rely on.

While the proposal avoids the name “Schedule F,” its substance remains the same—and in some ways, it is even more troubling. Under the proposed rule, positions may be reclassified into Schedule P/C at the President’s discretion, and agencies would be permitted to remove employees from these positions without evidence of misconduct or poor performance. This is not a legitimate performance management tool—it is a framework for mass at-will removals based on perceived political loyalty. It marks a return to the very “spoils system” the Pendleton Act of 1883 was enacted to eliminate.

Erosion of Internal Oversight and Whistleblower Protections

The proposed rule also weakens internal government oversight by undermining protections for career civil servants who report waste, fraud, or abuse. While the rule nominally bars removals based on political affiliation, stripping employees of due process and appeal rights removes the practical mechanisms that allow whistleblowers to challenge improper terminations. Federal employees have long played a critical role in exposing costly contracting failures, misappropriated funds, and gaps in policy implementation. Making them removable at-will would stifle such reporting, suppress accountability, and leave taxpayers more exposed to unchecked waste and mismanagement.

Contracting and Program Oversight Vulnerabilities

Many of the positions likely to be reclassified under Schedule P/C are central to overseeing billions of dollars in federal contracts and grants. Removing these individuals without cause—and without a pipeline of qualified replacements—jeopardizes the government’s ability to manage and enforce contractual obligations. Contract mismanagement, already a significant source of federal waste, would only worsen if oversight functions are gutted or politicized. The likely outcome: higher costs, missed deadlines, and less oversight of contractor performance—all at the expense of taxpayers.

Absence of Fiscal Impact Assessment

It is striking that a proposal of this magnitude includes no assessment of its implementation costs. If implemented, the proposed rule would inject chaos into the federal government every time the presidency changes hands. By reclassifying thousands of career civil servants as at-will employees under Schedule P/C, each new administration could remove large segments of the federal workforce based solely on perceived political alignment—effectively turning longstanding civil service roles into revolving political appointments.

This would trigger constant churn. The practical burden of recruiting, vetting, hiring, and onboarding thousands of new employees every four or eight years—many of whom fill specialized technical or regulatory roles—is not only unworkable, it is fiscally irresponsible.

Yet, there is no estimate of the administrative burden involved in reclassifying thousands of positions, recruiting and training replacements, or mitigating the disruption to agency operations. The lack of even a basic cost-benefit analysis should be disqualifying for a rule that would so fundamentally reshape the federal workforce. Taxpayers deserve transparency and fiscal accountability—particularly when a systemic overhaul is being proposed with the potential to destabilize entire agencies.

No Upside for Taxpayers

Taxpayers gain nothing from a federal workforce stripped of professional expertise and repopulated with partisan loyalists. On the contrary, politicization increases the risk of corruption, reduces transparency, and heightens the likelihood of programmatic failure—whether in national security, disaster response, or environmental enforcement. Rather than improving accountability, Schedule P/C would suppress the professional judgment and internal dissent that are essential for identifying waste, fraud, and abuse and ensuring that federal programs deliver results.

There is a real and pressing need for thoughtful, performance-based civil service reform. The federal workforce faces serious challenges—from outdated hiring systems and inflexible personnel policies to persistent skill gaps in key areas like cybersecurity, information technology modernization, and scientific and technical expertise. Agencies often struggle to recruit and retain qualified professionals, particularly in high-demand fields where the private sector offers more competitive pay and greater flexibility. At the same time, slow and cumbersome hiring processes make it difficult to adapt to evolving mission needs or bring in fresh talent. These are the issues that deserve focused attention and reform.

But instead of addressing these structural problems, the Schedule P/C proposal threatens to simply dismantle the career civil service. By weakening merit protections and introducing political litmus tests, it would exacerbate—not solve—the real personnel challenges facing the federal government.

Conclusion

Taxpayers should not be forced to bear the cost of rebuilding the federal workforce from scratch after every election, nor should critical government functions be jeopardized by politically driven purges of experienced professionals.

Schedule F was ill-conceived and rightly rescinded. Schedule P/C is no improvement. Taxpayers for Common Sense urges OPM to withdraw this proposed rule in its entirety. We call on the Administration to pursue meaningful reforms that strengthen the performance and integrity of the federal workforce—without sacrificing merit-based protections or injecting partisan politics into roles that should remain impartial and accountable to the public.

Sincerely,

Steve Ellis

[1] “Schedule F Federal Employees: What Will That Mean?” Taxpayers for Common Sense, July 27, 2022, https://www.taxpayer.net/national-security/schedule-f-federal-employees-what-will-that-mean/