Comment from USAF

The Air Force Civilian Personnel Directorate (AF/A1C) recently solicited feedback from the human resources community across our headquarters offices and commands regarding the proposed elimination of time-in-grade (TIG) requirements. I want to state clearly up front that AF/A1C definitively supports the elimination of TIG. Removing this arbitrary barrier is a necessary modernization step that will allow us to advance top talent based on proven capability, performance, and merit, rather than mere tenure. However, transparent communication is critical to a successful rollout. While there is broad support for this initiative, several offices have raised valid operational challenges and risks that we must be prepared to navigate during implementation. I am sharing these overarching concerns so we (OPM/DoW/AF) can address them proactively: 1. Legal Liability & Perceptions of Favoritism: Removing the objective 52-week "floor" creates a risk of inconsistent promotion practices among hiring managers. AF/JACL and AF/A1CT warn this shift could lead to appearances of favoritism, potentially resulting in a surge of Prohibited Personnel Practice claims at the Office of Special Counsel and discrimination complaints at the EEOC. Defending these fact-dependent cases will require significant resources. 2. Preserving Veterans' Preference: Under the VEOA, external preference-eligible veterans compete for merit promotions. AFPC/DPCPB notes that without TIG standards serving as a pacing mechanism, agencies could rapidly accelerate favored internal "status" employees. We must ensure this policy change does not inadvertently shut out highly qualified external veterans or compromise fair, open competition. 3. Labor Relations & Collective Bargaining: Promotion procedures and eligibility criteria are highly sensitive and subject to mandatory collective bargaining under 5 U.S.C. Chapter 71. Eliminating TIG will trigger immediate, decentralized statutory bargaining obligations across multiple MAJCOMs, components, and bargaining units. A clear transition window (e.g., 90–180 days) is highly recommended to prevent disruptions to hiring operations while we navigate active union negotiations. 4. Technical & Administrative Inconsistencies: The proposed rule currently contains multiple drafting errors, including duplicate paragraph numbering, incorrect citations, and mismatches between the preamble narrative and the actual amendatory regulatory instructions. If finalized as written, these technical discrepancies will cause administrative gaps in our HR and staffing execution. The Path Forward: Despite these challenges, we are confident in our ability to execute this transition successfully. The Air Force already successfully utilizes merit promotion plans for excepted service positions, which operate efficiently without TIG requirements. Furthermore, our standard use of hiring panels serves as a strong safeguard against favoritism. In our experience, because the AF enforces thoroughly documented merit hiring practices, claims of favoritism by competing applicants are consistently defeated. Ultimately, the AF has a robust foundation in place to support this modernization, and we anticipate that only minor revisions to our current policies will be required. I am happy to discuss this further at your earliest convenience. More details available via CRM by request. V/R John John Carbone, SES, DAF Director, Civilian Force Management DCS, Manpower, Personnel and Services P# 703-571-1734