Comment Template

COMMENT SUBMISSION INSTRUCTIONS: All submissions must include the agency name and docket number or RIN for this rulemaking. Please arrange and identify your comments on the regulatory text by subpart and section number; if your comments relate to the supplementary information, please refer to the heading and page number. All comments received will be posted publicly without change, including any personal information provided. To ensure that your comments will be considered, you must submit them on or prior to June 7, 2025 at online to the Federal Register. Before finalizing this rule, OPM will consider all comments within the scope of the regulations received on or before the closing date for comments. OPM may make changes to the final rule after considering the comments received. 

COMMENT STARTER: The example below is meant to get you started with your own comment. Feel free to use it with only minimal changes, to go a different direction, or anything in between. Because OPM has to consider each comment, unique comments add value to the process but all comments relevant to the proposed rule and grounded in thoughtful analysis or real experience are helpful.

[DATE]

RE: Public Comment in Response to Improving Performance, Accountability and Responsiveness in the Civil Service [Docket No. OPM–2025–0004]

I write to express my deep concern about reclassifing specific federal positions. This rule would erode necessary protections for staff in the federal statistical system, transforming positions which rely on specific expertise to political ones. The proposed rule would call into question the objectivity that both sides of the aisle rely on for needed evidence. Federal statistics play an essential role in improving the lives of all Americans and inform critical policy decisions with evidence that is timely, relevant, and accurate. Federal statistical agencies are particularly vulnerable to the proposed rule due to the following:

  • Politicization: Schedule Policy/Career could lead to the politicize of the federal statistical workforce. Federal statistics clearly influence public policy of all sorts: monetary, fiscal, regulatory, etc. Thus, a President could classify many statistical agency positions as Policy/Career. Then, for example, BLS leaders could be fired for releasing or planning to release jobs or inflation statistics unfavorable to the President’s policy agenda. They might also face pressure to change methodologies or reveal pre-release information. By making it easier to remove employees if a President determines that they are interfering with his or her policies, it increases the potential for passivity or political loyalty to be prioritized over expertise and experience. Politicization has had dramatic consequences for statistical agencies and their leaders in other countries, notably Argentina and Greece.

  • Importance of Trust, Impartiality and Objectivity: Statistical agencies need professional autonomy to provide impartial, objective, reliable data. Professional autonomy is the ability to act independently from political or other undue external influence regarding its operations. Erosion of professional autonomy in the statistical agencies would undermine public trust in the data they produce.

  • Importance of Norms: Schedule Policy/Career would deprioritize and thus weaken norms that uphold the ethical and professional standards that are critical to the success of statistical agencies. See Principles and Practices for a Federal Statistical Agency for examples of critical norms that leaders help craft, model and reinforce. These norms go beyond the laws, rules, and policy directives that govern agencies’ operations. Weaker norms threaten trust, efficient operations, and data quality.

  • Erosion of Expertise and Institutional Memory: Statistical agencies stand to lose unique technical experts who see their career paths as less secure and merit-based than before. Loss of these could disrupt agency operations, hinder long-term planning and impair the quality and accuracy of the data.

  • Decreased Employee Morale and Productivity: The uncertainty and fear of arbitrary dismissal could negatively impact employee morale, impairing productivity and the ability to attract and retain top talent.

  • Importance of Modernization, Research, and Data Continuity: To support their missions, statistical agencies must invest in long-term efforts such as critical modernization projects and efforts to ensure data access and continuity. Schedule Policy/Career could subject agencies to changing presidential priorities, increasing senior staff turnover and disrupting modernization, measurement of trends, and meaningful research.

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Schedule Policy/Career seriously threatens the effectiveness of federal statistical agencies and the integrity and quality of their products. By undermining the principles of merit-based employment and threatening job security of career civil servants, Schedule Policy/Career could lead to politicization, loss of trust and expertise, low morale, and disrupted agency operations.

On behalf of U.S. businesses, the American public, and policymakers I urge that the trustworthiness of federal statistics be protected by rejecting this rule or explicitly excluding statistical agency staff from Schedule Policy/Career.