Comment from Anonymous

I submit this comment as a private citizen who strongly supports the merit-based, nonpartisan civil service established by Congress. I oppose this proposed rule because it expands executive discretion in ways that risk undermining the principles that have governed the career civil service for more than a century. Although presented as an administrative clarification, the practical effect is to provide agencies with additional mechanisms to sideline career employees during reorganizations and workforce realignments. Such authority should be approached with great caution. Congress established a merit-based civil service to replace the patronage system. The merit system principles codified in 5 U.S.C. § 2301 require that federal employees be treated fairly and equitably, protected against arbitrary action, personal favoritism, and political coercion, and retained based on performance rather than political considerations. Those principles are not administrative preferences—they are foundational to the legitimacy and effectiveness of the federal government. A professional civil service exists to ensure continuity of government regardless of which party controls the Executive Branch. Career employees swear an oath to support and defend the Constitution, not to serve the political interests of any President or administration. Their value lies in providing objective expertise, preserving institutional knowledge, and faithfully executing laws enacted by Congress. This proposed rule moves in the opposite direction by increasing executive discretion without adding meaningful safeguards to ensure that discretion cannot be used in ways that are inconsistent with the merit system principles established by Congress. Even if such authority is exercised responsibly by one administration, regulations should be written to withstand misuse by future administrations of any political affiliation. Public confidence in government depends on knowing that career officials are selected, retained, and managed because of their competence and integrity—not because they are viewed as politically aligned or politically expendable. Expanding the government’s ability to remove employees from their duties during reorganizations without strengthening corresponding protections risks creating exactly that perception. The federal civil service is one of the nation’s enduring institutional strengths. Weakening its independence ultimately harms the American public, which depends on a stable, experienced, and politically neutral workforce to administer programs, safeguard public resources, protect national security, and implement the laws enacted by Congress. For these reasons, I urge OPM to withdraw this proposal or substantially revise it to ensure that any workforce management authority remains firmly anchored to the merit system principles in 5 U.S.C. § 2301 and preserves the independence, professionalism, and nonpartisan character of the career civil service.