The National Treasury Employees Union (NTEU) opposes the proposed rule, arguing it illegally removes administrative leave from the bargaining table, lacks a valid statutory basis, and unfairly locks employees into resignation decisions. While they oppose most aspects of the rule, they specifically support including physical fitness activities as an acceptable use of administrative leave.

The commenter, identifying as a private citizen, opposes the proposed rule because they believe it retroactively legitimizes a costly and ineffective deferred resignation program that lacks proper oversight. They argue that existing statutory tools like VERA and VSIP are superior for workforce reduction and criticize the rule for unfairly restricting employees' ability to withdraw resignations and prohibiting administrative leave for poll work.