On April 21, 2025, the Office of Personnel Management (OPM) published a proposed rule to the Federal Register that would allow the President and OPM to fire a whole class of federal employees without warning, reason, or due process. OPM estimates that around 50,000 federal workers will be placed in the new job category.
The proposed rule intends to codify “Schedule Policy/Career” (formerly Schedule F) as a new class of civil servants in policy-influencing roles who would serve at-will and no longer be covered by traditional civil service protections under federal law. OPM’s proposed regulations seek to implement President Trump’s Amended Executive Order 13957 (January 20, 2025).
Frequently Asked Questions
❓What is the Schedule Policy/Career proposal?
A: The Office of Personnel Management (OPM) rule is proposing a new category of federal jobs called Schedule Policy/Career—a type of excepted service role for career employees in policy-influencing positions. If your job is reclassified under Schedule P/C, the government can fire you without notice and without cause.
❓Who could be affected?
A: If your job involves the following characteristics, the rule would allow your agency to move your job into the Schedule Policy/Career:
- Policy development or analysis
- Regulation drafting
- Strategic or budget planning
- Supervising policy staff
- Public communication or external advocacy of agency policy
❓Will I be notified if my position is being reclassified?
A: Under the proposal, agencies would not be required to notify you that you are being moved to Schedule P/C. You cannot challenge or appeal if your position is reclassified into Schedule Policy/Career. Your job may become at-will without your knowledge or consent.
❓What rights would I lose if my role is moved?
A: Most non-probationary employees in the Executive branch are entitled to the following rights due process rights prior to be being fired, demoted or suspended. You will lose these rights if your position is shifted to Schedule Policy/Career.
❓Would I still be a career federal employee?
A: Yes, but under the proposed rule, if your position is reclassified, you’d be at-will, with no right to retain your position—even with good performance. The rule gives the government the option to fire you at any time, without notice, and without cause.
❓Can I appeal if I’m fired from a Schedule Policy/Career position?
A: No. The proposal removes appeal rights for adverse actions, including removal, suspension or demotion, for anyone serving in a Schedule Policy/Career role. If you are moved to Schedule P/C, your job protections will evaporate.
❓Can I prevent my job from being reclassified?
A: Not directly. The President—not OPM—will ultimately determine which positions are moved into Schedule Policy/Career. However, you can:
- Review your position description
- Engage with your union or HR for updates
- Submit a public comment during the open comment period on regulations.gov on or before June 7, 2025
❓Will I lose my EEO rights?
A: No. Employees in Schedule Policy/Career positions retain the ability to file EEO complaints if they believe they have been subjected to unlawful discrimination or retaliation for engaging in protected EEO activity.
❓Will I lose my whistleblower protection rights?
A: Possibly. Under the Whistleblower Protection Act, positions of a confidential, policy-determining, policy-making, or policy-advocating character are not “covered position[s]”. See, 5 U.S.C. § 2302(a)(2)(B). But the 2020 version of Executive Order 13957 prohibits prohibited personnel practices, including retaliation against whistleblowers. Section 6 of the 2020 Executive Order forbids taking personnel actions prohibited by 5 U.S.C. § 2302(b), which generally includes protections for whistleblowers. Agencies are required to establish internal procedures to ensure compliance with this directive.
❓What happens next?
A: OPM rulemaking is in the public comment period. After that, OPM may finalize the rule. Agencies will then begin reviewing roles for possible reclassification. We recommend:
- Staying alert to internal communications
- Attending briefings
- Asking questions via HR or your union representative
The public has until June 7, 2025, (previously May 23, 2025) to submit comments about the proposed rule to OPM. Comments can be submitted at https://www.regulations.gov/commenton/OPM-2025-0004-0001.