 Good afternoon,
On June 27, 2025, the U.S. Office of Personnel Management (OPM) sent “Answers to Frequently Asked Schedule C Pay-Setting Questions” to Chief Human Capital Officers (CHCOs) and Deputy CHCOs.
Subsequently, on July 29, 2025, OPM issued a guidance memorandum titled “Guidance on Executive Order Creating Schedule G in the Excepted Service.”
As Schedule G positions are like Schedule C positions, agencies may apply the pay-setting flexibilities referred to in the “Answers to Frequently Asked Schedule C Pay-Setting Questions” to Schedule G positions as well. It should be noted that in most cases, outside of the U.S. Department of Veterans Affairs, Schedule C appointments should meet agency needs.
OPM is also revising the question regarding quality step increases to align with the Guidance on Awards for Federal Employees issued on August 11, 2025.
A complete set of the revised answers is included below for your reference.
If you have any questions on this or other Schedule C or Schedule G staffing or pay matters, please contact your agency White House Liaison or the OPM Agency Operations and Services team via email at NCAP@opm.gov.
Frequently Asked Questions for the U.S Office of Personnel Management’s (OPM) Schedule C Pay-Setting Memo (4/10/25) and Chief Human Capital Officer Meeting (4/22/25 and 5/22/25) Guidance; Also Applicable to Schedule G Positions consistent with OPM’s Memo
Schedule C Appointment Process
Q: Does OPM’s White House Liaison need to approve all agency requests to make a Schedule C or Schedule G appointment?
A: Yes, agencies must submit a request to make a Schedule C or Schedule G appointment to OPM’s White House Liaison for approval. OPM’s Executive and Schedule C System (ESCS) is the central intake mechanism agencies must use for requesting approval to make a Schedule C or Schedule G appointment. As a matter of practice, each request for approval to make a Schedule C or Schedule G appointment should be advanced by HR only after coordination with the agency White House Liaison.
Q: Does approval of an agency’s request for OPM approval to make a Schedule C or Schedule G appointment require preclearance from the White House Office of Presidential Personnel (PPO), through the agency White House Liaison?
A: Yes. Agencies must coordinate and obtain preclearance from PPO before submitting a request for OPM approval.
Q: Does withdrawal of an agency’s initial request for OPM approval to make a Schedule C or Schedule G appointment require preclearance from the White House Office of Presidential Personnel?
A: Agencies should notify PPO of their intent to withdraw a candidate from consideration for appointment and subsequently notify OPM of the proposed withdrawal. Following OPM’s acknowledgement of the agency’s withdrawal notification, OPM will return the agency’s initial request via a “return without action” through ESCS.
Q: Should agencies review and, where appropriate, revoke delegations and sub-delegations provided to agency human resources offices for setting the terms for Schedule C appointment, including initial salary?
A: Yes. The goal is to bring about a uniform process of Schedule C appointment and management within the Administration under the leadership of PPO and the White House Liaison network.
Setting Initial Pay
Q: Do agency heads have the authority to determine the initial salary of a Schedule C or Schedule G employee?
A: Yes, subject to the authorities that apply to the pay system of the Schedule C or Schedule G position.
Q: How should an agency determine the initial salary of a Schedule C or Schedule G employee?
A: Agencies must work with their White House Liaison to determine initial pay rates. The standard practice for setting the pay of incoming appointees involves White House input through the OPM White House Liaison. For Schedule C and Schedule G employees under the General Schedule (GS), agencies will identify the employee’s GS grade level upon appointment and the step rate within the rate range for the grade that the employee will be paid (not to exceed step 10). Agencies should consider factors such as the candidate’s skills and competencies, the importance/criticality of the position to be filled, the effect on the agency if it is not filled or if there is a delay in filling it, and any White House guidance in determining the appropriate step rate. Governmentwide pay tables are available online.
Q: Are there any additional limits on setting the initial salary of a Schedule C or Schedule G employee?
A: General Schedule (GS) locality rates and special rates are subject to the rate for level IV of the Executive Schedule ($195,200 in 2025).
Setting Pay Upon Movement Within the Pay System
Q: Are GS Schedule C and Schedule G employees covered by the within-grade increase law and regulations?
A: Yes. See 5 U.S.C. 5335; 5 CFR part 531, subpart D; and OPM’s guidance.
Q: Are GS Schedule C or Schedule G employee eligible for quality step increases?
A: No. The freeze on discretionary awards, bonuses, and similar payments for Federal employees serving under political appointments remains in effect.
Q: May an agency increase a GS Schedule C or Schedule G employee’s pay if the employee moves to a different Schedule C or Schedule G position at the same grade level?
A: Yes, including temporary reassignments. Pursuant to 5 CFR 6.3(b), appointments and position changes in the excepted service are made in accordance with such regulations and practices as the head of the agency concerned finds necessary. This means that agencies have maximal flexibility in setting forth standards, qualifications, and pay for a Schedule C or Schedule G appointment, except when constrained by statute. Any pay increase or decrease is not mandatory, however, and should be discussed with the agency White House Liaison.
Q: Under what conditions may an agency promote a GS Schedule C or Schedule G employee to a higher grade within the GS pay system?
A: Promotion for Schedule C and Schedule G employees are limited to situations where significant changes to a position’s level of duties and responsibilities justify reclassification to a higher grade. These changes, however, might not be reflected in a changed position description, and can be accounted for in a change of office or supervisor. Schedule C and Schedule G positions, being in the excepted service, are not covered by the time-in-grade restrictions that apply to positions in the competitive service (5 CFR Part 300 Subpart F). Both White House and OPM approvals are required prior to effecting any change in grade level.
Q: How is pay set when a GS Schedule C or Schedule G is promoted to a higher-graded position within the GS pay system?
A: A promotion is a position change under 5 CFR 6.3(b) for a GS Schedule C or Schedule G employee who moves to a higher grade. As such, an agency has flexibility to set pay for a GS Schedule C or Schedule G employee upon promotion. However, when a GS Schedule C or Schedule G employee is promoted from a lower grade to a higher grade without a break in service the employee’s step rate in the higher grade must be set no lower than the rate determined by applying the statutory GS promotion rule in 5 U.S.C. 5334(b). (See also OPM regulations at 5 CFR 531.214.) In this case, if a GS Schedule C or Schedule G employee is in the same locality pay area before and after promotion, the new pay rate in the higher grade will be the lowest step rate that exceeds the pay rate at the lower grade resulting from increasing the existing rate by two steps within that lower grade. In the absence of more specific OPM guidance or rule, under an agency head’s authority in 5 CFR 6.3(b), a promoted GS Schedule C or Schedule G employee’s pay may be set at a rate higher than the rate resulting from application of the GS promotion rule, in practice done in consultation with agency White House Liaisons.
Overtime Pay and Other Types of Premium Pay
Q: Are GS Schedule C and Schedule G employees eligible for overtime pay and other types of premium pay?
A: Yes. GS Schedule C and Schedule G employees are covered by the same overtime and premium pay rules that apply to most other Federal employees. Schedule C and Schedule G employees are covered by either the overtime pay provisions of the Fair Labor Standards Act (FLSA) or title 5, United States Code (5 U.S.C. 5542), as administered and regulated by OPM. Schedule C and Schedule G employees may also earn compensatory time off in lieu of FLSA or title 5 overtime pay, compensatory time off for travel, night pay, holiday pay, and Sunday pay for qualifying work hours. Guidance on overtime pay and other types of premium pay can be found in the “Premium Pay Fact Sheets” section of OPM’s website, as well as in 2009 guidance from OPM.
However, under 5 U.S.C. 5547(a) and 5 CFR 550.105, GS employees and other covered employees may receive certain types of premium pay for a biweekly pay period only to the extent that the sum of basic pay and premium pay for the pay period does not exceed the greater of the biweekly rate payable for (1) GS-15, step 10 (including any applicable locality payment or special rate supplement) or (2) the rate payable for level V of the Executive Schedule. (FLSA overtime pay is excluded from this limitation.) In certain emergency or mission-critical situations, an agency may apply an annual premium pay cap instead of a biweekly premium pay cap, subject to the conditions provided in law and regulation. (See 5 U.S.C. 5547(b) and 5 CFR 550.106-550.107.) See OPM’s guidance for additional information on biweekly and annual premium pay limitations. (Note: Certain provisions of law may exempt selected categories of employees from these premium pay limits.)
U.S. Office of Personnel Management
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