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.

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 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.

A Bureau of Prisons employee opposes the proposed changes, arguing that eliminating the Douglas factors removes necessary safeguards for consistent discipline. The commenter also expresses concern that the 30-day limit on Performance Improvement Plans is unrealistic and that the "voluntary abandonment" standard is concerning.

The commenter opposes the proposed actions, arguing that the provisions regarding PIPs, settlements, and voluntary abandonment are arbitrary and could lead to discrimination. They advocate for a transparent, fair process for civil servants that includes union representation and adequate response time.

The commenter opposes the proposed rule because it replaces the established Douglas Factors with a vague "totality of the circumstances" standard, which they argue increases agency discretion and risks inconsistent discipline. They also express concerns regarding the inadequacy of the proposed response periods, the lack of flexibility for job-specific performance improvement periods, and the removal of medical waiver protections.

The commenter, identifying as a citizen with professional management experience, opposes the removal of the Douglas factors framework from the proposed rule. They argue that removing these factors will lead to pretextual firings, arbitrary enforcement, loss of institutional knowledge, and increased litigation.