Elimination of Time-in-Grade

IFPTE Local 777, a union representing federal employees, opposes the proposal to eliminate Time-in-Grade requirements because it replaces an objective standard with increased management discretion. They argue that removing this standard could undermine trust in the merit system and advocate for clear written promotion criteria and transparency if the change proceeds.

The commenter opposes the elimination of time-in-grade, arguing that it replaces objective fairness with manager discretion and risks favoritism. They request that OPM implement strict safeguards, audit agencies, and delay the rule's effective date to allow for the creation of objective review boards.

The commenter opposes the elimination of the Time-in-Grade (TIG) requirement, arguing that it lacks sufficient oversight, creates administrative burdens for HR, and risks inconsistent promotion standards. They propose a "Competency-Based Accelerated Promotion Waiver" (CBAPW) framework as a less burdensome alternative that maintains the 52-week baseline while allowing for specific, high-performing exceptions.

The commenter supports the elimination of the mandatory 52-week Time-in-Grade requirement, arguing that promotions should be based on merit and performance rather than time served. They recommend that OPM provide clear implementation guidance, supervisor training, and data monitoring to ensure consistency and fairness across agencies.

The commenter opposes the elimination of the 52-week Time-in-Grade (TIG) requirement, arguing that it serves as a necessary preventive control against favoritism and ensures sustained performance. They request that OPM provide empirical evidence that removing the requirement will not increase the risk of inequitable promotion practices.

An examiner at the USPTO supports the elimination of the Time-in-Grade requirement, arguing that it prevents high performers from being properly rewarded and may lead to turnover. The commenter suggests that removing these requirements will provide agencies with more flexibility to reward performance while cautioning that safeguards against sabotage should remain.

The commenter expresses a neutral/mixed stance, acknowledging the logic of the proposal but requesting more data, clearer safeguards, and consideration of middle-ground alternatives like graduated TIG relief before a full repeal. They also request better transparency regarding the public visibility of comments during the rulemaking process.

Adam L. Lewis, a Chief in the Air Force Global Strike Command, supports the proposed rule to eliminate Time-in-Grade restrictions for General Schedule positions. He argues that removing the 52-week waiting period will modernize the federal workforce by focusing on merit and capability, improving employee retention, and creating equity across different pay systems.