Comment from Jady Inguanzo

Regarding the Proposed Changes to the Douglas Factors I respectfully oppose the proposed changes to the Douglas Factors. As a federal employee, I have personally experienced the importance of having fair disciplinary procedures that take into account the individual circumstances of each case. The Douglas Factors help ensure that disciplinary actions are not arbitrary and that employees receive due process before decisions that can significantly affect their careers and families. In my own experience, disciplinary matters can continue for years, creating uncertainty, emotional stress, and financial hardship. These protections exist to ensure that agencies carefully evaluate all relevant facts instead of applying discipline without meaningful consideration of mitigating circumstances. Weakening these long-standing protections would reduce fairness, increase the risk of inconsistent disciplinary decisions, and undermine employees’ confidence in the merit system. Civil servants deserve a transparent process, adequate time to respond, and the opportunity to have their individual circumstances fully considered. For more than four decades, the Douglas Factors have provided a balanced framework that protects both management’s ability to maintain accountability and employees’ right to fair treatment. I strongly urge OPM and the MSPB to preserve these important protections and reject the proposed changes. Thank you for considering my comments.