Comment from Elizabeth Gonzalez
AnonymousOpposeOther
Summary: The commenter argues that the proposed rule could be used as a tool for permanent downsizing and the loss of specialized expertise in critical fields like epidemiology and maternal health. They request that OPM clarify that administrative leave should not be a routine workforce reduction strategy and that agencies must prove mission requirements can still be met.
Loss of expertise is difficult and expensive to rebuild
This is especially important for specialized topics and areas of work
For example:
* birth defects surveillance
* epidemiology
* laboratory science
* risk communication
* maternal and infant health
These are specialized disciplines that often require years of training and relationship-building.
Once lost, rebuilding that expertise takes much longer than hiring new staff.
Administrative leave should not become an incentive for permanent downsizing
The proposed rule presents administrative leave as a tool to facilitate workforce restructuring.
OPM needs to clarify that :
* administrative leave should not be used as a routine workforce reduction strategy
* agencies should first demonstrate that mission requirements can still be met