Comment from Anonymous
AnonymousOpposeIndividual
Summary: The commenter opposes the proposed rule "Promoting Employee Accountability," arguing that it exceeds statutory boundaries, compromises due process protections, and harms working-class employees. They contend that existing performance management systems are sufficient and that any changes must remain within explicit statutory limits.
I am submitting this comment in opposition to the Notice of Proposed Rulemaking (NPRM) regarding "Promoting Employee Accountability" (OPM-2025-0012-0001). It by far exceeds statutory boundaries: Fails the Loper Bright standard by expanding agency removal authorities beyond the single, best reading of the Civil Service Reform Act (CSRA).It also Compromises Due Process Protections: Dilutes procedural baselines for adverse actions and limits necessary penalty mitigation assessments. It harms the Working-Class: Erases vital workplace protections for middle-class employees. The problem is that the machinery for managing poor performance already exists. Chapters 43 and 75, the ODAP requirement, performance improvement plans, progressive discipline, and MSPB review are the existing system. Any adjustments to federal adverse action or performance frameworks must remain within explicit statutory limits and preserve robust protections for working-class and middle-class public servants.