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 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.

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.

The commenter opposes the proposed framework that emphasizes removal following a 30-day Performance Improvement Plan (PIP), arguing it limits agency flexibility. They recommend that the final rule allow agencies to consider alternative corrective actions, such as retraining or reassignment, to promote retention and efficiency.

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.

A federal employee supports the proposed rule, arguing that it is necessary to streamline the process for firing underperforming employees who have "checked out." The commenter states that the current system is demotivating and that the rule is long overdue.

The commenter, who appears to be a federal employee, argues that current deadlines are being abused by management to prevent proper responses and defense. They advocate for longer, more reasonable deadlines to allow employees time to gather evidence and seek professional assistance.

An individual opposes the proposed rule, arguing that it incorrectly identifies procedural protections as the primary obstacle to federal employee accountability. The commenter suggests that OPM should instead focus on improving supervisory training, addressing management failures, and providing the MSPB with more resources to handle appeals promptly.