Public Employees for Environmental Responsibility (PEER) opposes the proposed "Promoting Employee Accountability" rule, arguing it weakens civil service protections and creates a "spoils system" by making it easier to fire employees without due process. They request that the OPM and MSPB withdraw the rule entirely, citing concerns over shortened performance-improvement windows, the removal of the Douglas Factors, and the narrowing of comparison pools for fairness.

A former high-level federal supervisor supports the proposed amendments to streamline the disciplinary process for poor-performing employees. The commenter argues that the current system is overly burdensome for managers and advocates for expanded training for HR and attorneys, as well as restrictions on using government time for union representation.

The commenter, a federal employee, opposes the proposed changes to the Douglas Factors. They argue that the factors provide essential protections for fair disciplinary procedures and that weakening them would undermine employee confidence and lead to inconsistent decisions.

Staff at the FCC Hazelton correctional facility oppose the proposed rule, arguing that it reduces procedural protections and job security for correctional officers. They contend that the rule would lead to arbitrary discipline, worsen recruitment and retention issues, and compromise safety within the facility.

Staff at FCC Hazelton oppose the proposed representative-restriction language in 5 CFR Part 432, § 432.105(d)(3). They argue that the rule would limit employees' ability to choose advocates who understand the unique operational pressures and risks of a correctional environment, potentially harming morale and safety.

The commenter, a federal employee in labor and employee relations, supports the proposed rule to reform the Douglas factors. They argue that the current factors make it too difficult to remove detrimental employees and advocate for a system that better promotes the efficiency of the federal service.

The commenter, a prospective federal employee with a disability, opposes the proposed rule because it may force employees to undergo improvement periods without resolved accommodations or independent reviews. They argue for specific safeguards, including a 90-day opportunity period and independent review, to protect disabled and probationary employees from erroneous separation.

A current federal employee commenting in an individual capacity opposes the proposed rule, arguing it would undermine fairness and transparency in the disciplinary process. The commenter expresses concern that removing the Douglas factors and limiting performance improvement plans would lead to arbitrary outcomes and disproportionately harm certain employees.

The commenter suggests that the proposed rules should be expanded to include supervisors and managers, who are often responsible for fraud, waste, and abuse. They also express concern regarding the potential impact on whistleblowers and the need to address retaliation.