Comment Template

COMMENT SUBMISSION INSTRUCTIONS: All submissions must include the agency name and docket number or RIN for this rulemaking. Please arrange and identify your comments on the regulatory text by subpart and section number; if your comments relate to the supplementary information, please refer to the heading and page number. All comments received will be posted publicly without change, including any personal information provided. To ensure that your comments will be considered, you must submit them on or prior to May 23, 2025 at online to the Federal Register. Before finalizing this rule, OPM will consider all comments within the scope of the regulations received on or before the closing date for comments. OPM may make changes to the final rule after considering the comments received. 

COMMENT STARTER: The example below is meant to get you started with your own comment. Feel free to use it with only minimal changes, to go a different direction, or anything in between. Because OPM has to consider each comment, unique comments add value to the process but all comments relevant to the proposed rule and grounded in thoughtful analysis or real experience are helpful.

[DATE]

RE: Public Comment in Response to Improving Performance, Accountability and Responsiveness in the Civil Service [Docket No. OPM–2025–0004]

I am writing to express my deep concern regarding the effort to reclassify specific federal positions, which would erode necessary protections for those serving within the federal statistical system and could transform positions which rely on specific expertise to political ones. The proposed rule, “Improving Performance, Accountability and Responsiveness in the Civil Service,” would call into question the objectivity that both sides of the aisle rely on for our economic indicators, public health assessments, energy utilization and many other statistics. The federal statistical system plays an essential role in improving the lives of all Americans as well as informing critical policy decisions with evidence that is timely, relevant, and accurate. Federal statistical agencies are particularly vulnerable to the proposed rule due to the following:

  • Politicization: Schedule Policy/Career could lead to the politicization of the federal statistical workforce. Official federal statistics clearly influence public policy of all sorts: monetary, fiscal, regulatory, etc. Thus, a President could classify many statistical agency positions as Policy/Career. Then, for example, Bureau of Labor Statistics’ leaders could be fired for releasing or planning to release jobs or inflation statistics unfavorable to the President’s policy agenda. They might also face pressure to change methodologies or reveal pre-release information. By making it easier to remove employees if a President determines that they are interfering with his or her policies, it increases the potential for passivity or political loyalty to be prioritized over expertise and experience. Politicization has had dramatic consequences for statistical agencies and their leaders in other countries, notably Argentina and Greece.

  • Importance of Trust, Impartiality and Objectivity: Statistical agencies, such as the Bureau of Labor Statistics, the Census Bureau, and the National Center for Health Statistics, need professional autonomy to provide impartial, objective, reliable data. Professional autonomy is the ability to act independently from political or other undue external influence regarding its operations, such as data collection and analysis, staffing, and publications. Erosion of professional autonomy in the operations of statistical agencies would undermine their perceived or actual independence, leading to a loss of public trust in the data they produce.

  • Importance of Norms: Schedule Policy/Career would deprioritize and thus weaken the norms that uphold the ethical and professional standards that are critical to the success of statistical agencies. Senior leaders help craft, model and reinforce norms within their agencies and between their agencies and other parts of the government.  Examples include how agencies interact with staff, data users, data subjects, outside experts and host agencies. See Principles and Practices for a Federal Statistical Agency for examples of these critical norms. These norms reflect and go beyond the laws, rules, and policy directives that govern agencies’ operations. Weaker norms threaten trust, efficient operations, and data quality.

  • Erosion of Expertise, Loss of Institutional Memory and Increase of Turnover: These agencies rely on highly specialized professionals, including statisticians, economists, and data scientists, who possess unique technical expertise and long-term institutional memory. Statistical agencies stand to lose experts who see their career paths as less secure and merit-based than before. The loss of these experts or frequent turnover in key positions could disrupt agency operations, hinder long-term planning, undermine the agency's ability to fulfill its mission, and impair the quality and accuracy of the data.

  • Decreased Employee Morale and Productivity: The uncertainty and fear of arbitrary dismissal could negatively impact employee morale, leading to decreased productivity and difficulty in attracting and retaining top talent.

  • Importance of Modernization, Research, and Data Continuity: To support their missions, statistical agencies must invest in long-term efforts such as extensive research, critical modernization projects, and efforts to ensure data access and continuity. Schedule Policy/Career could subject to agencies to changing presidential priorities, increasing senior staff turnover and disrupting modernization efforts, measurement of trends, and meaningful research.

[INSERT own language here, if desired] 

Schedule Policy/Career poses a significant threat to the effectiveness of federal statistical agencies and to the integrity and quality of their products. By undermining the principles of merit-based employment and threatening job security of senior career civil servants, Schedule Policy/Career could lead to politicization, loss of trust and expertise, decreased morale, and disruption of agency operations. On behalf of U.S. businesses, the American public, and policymakers I am speaking up to protect the trustworthiness of the federal statistics we all rely on.