Comment from Anonymous

I strongly oppose this proposed rule because it significantly weakens long-standing due process protections for federal employees while giving agencies broader authority to impose discipline without adequate safeguards. For more than 45 years, the Douglas factors have provided a balanced framework to ensure that disciplinary actions are fair, consistent, and proportionate to the circumstances of each case. Eliminating these factors increases the risk of arbitrary and inconsistent disciplinary decisions and undermines merit system principles. Limiting Performance Improvement Plans (PIPs) to 30 days fails to recognize that many performance issues require more time for meaningful improvement, particularly when employees must complete training, adapt to new procedures, or address complex job requirements. A rigid 30-day limit does not provide employees with a genuine opportunity to succeed. The proposal's prohibition on "clean record" settlements will discourage resolution of disputes and likely increase litigation and appeals, resulting in higher costs for agencies, greater burdens on the Merit Systems Protection Board, and longer delays in resolving cases. I am also concerned about the proposed "voluntary abandonment" provision. Employees experiencing medical emergencies, disabilities, family crises, or other unforeseen circumstances could be unfairly penalized without sufficient consideration of the facts. This change appears inconsistent with the federal government's obligations under disability and employment laws to engage in individualized assessments and provide appropriate due process. Finally, reducing employees' procedural rights, including limiting access to union representation during disciplinary proceedings, undermines fundamental principles of fairness and accountability. Employee representation helps ensure that disciplinary actions are based on facts, agency policies are applied consistently, and workplace disputes are resolved fairly. Federal employees are entrusted with serving the public and deserve a disciplinary system that is transparent, balanced, and consistent with merit system principles. This proposal shifts that balance too far away from fairness and accountability. I respectfully urge OPM and MSPB to withdraw the proposed rule and preserve the procedural protections that have served the federal civil service for decades.