 Dear Agency Heads, CHCOs, Deputy CHCOs, and HR Directors,
Today the U.S. Office of Personnel Management (OPM) is providing agencies with the following additional* answers to novel Schedule Policy/Career questions to further assist with implementation. In case of any follow up questions, agency headquarters-level human resources offices may email employ@opm.gov for assistance. Note that employees should direct any follow up questions to their Human Resources office.
*OPM's June 8, 2026 Schedule Policy Career FAQs are also included within this note per your convenience.
OPM Workforce Policy and Innovation
Agency Notification Templates and Employee Acknowledgements
Q: What is the effective date for processing conversions into the excepted service under Schedule Policy/Career?
A: Agencies should process an SF-50, Notification of Personnel Action, with an effective date of June 3, 2026, and should have completed the transition documentation by June 10, 2026. In the event agencies missed that deadline they should complete these actions as soon as possible.
Q: Are agencies required to issue acknowledgment forms to employees, and if so, what method is acceptable?
A: Agencies are required to notify employees of their placement into the excepted service under Schedule Policy/Career. A signed acknowledgment is not required to effectuate the placement, but agencies should document that the employee was notified. Agencies have discretion to determine the method of notification and acknowledgment, including electronic methods such as Microsoft Forms, provided the process creates an adequate record of notice.
Q: Can an agency use its own acknowledgment template instead of OPM's?
A: Yes. OPM's templates are guides and samples. Agencies may adapt them to fit agency-specific needs, provided the notification clearly informs employees of their placement into Schedule Policy/Career and the impact on their conditions of employment.
Q: Does the agency head have to sign employee notifications?
A: No. Agencies have discretion to determine who signs employee notifications. Appropriate signatories may include the CHCO, Human Resources Director, or another designated official.
Q: Who is responsible for initiating the SF-52 to reassign employees into Schedule Policy/Career?
A: The SF-52 should be initiated by the same designated individual or office that normally initiates comparable personnel actions for the agency.
Q: How should tenure (box 24) and position occupied (box 34) be coded on the SF-50 for employees converted to or newly appointed under Schedule Policy/Career?
A: For a current employee converting into the excepted service under Schedule Policy/Career, the Tenure designation in Box 24 remains "1" (permanent). However, Box 34 - Position Occupied will change from "1" to "2" to reflect the move into the excepted service. If the employee was serving a probationary period immediately before the conversion, the Tenure designation in Box 24 would change from "2" to "1," as Schedule Policy/Career employees do not serve probationary or trial periods. For a new appointee selected for a Schedule Policy/Career position, Box 24 - Tenure should reflect "1" and Box 34 - Position Occupied should reflect "2."
Position Description Changes
Q: How should agencies handle positions where their internal records do not align with the Executive Order?
A: The Executive Order controls the movement of positions and agencies are responsible for ensuring their internal records align with it. Before processing any conversion, agencies should reconcile their position data — including Position IDs and position description (PD) numbers — against their own official records and the OPM listing to confirm an accurate match. Positions have only been moved into Schedule Policy/Career and employees converted to the excepted service if the positions match the title, agency/component, and PD number as listed in the Appendix of the Executive Order.
Where an agency's base PD number covers multiple positions — some of which meet the criteria and some of which do not — the agency should promptly review those PDs. Employees whose duties are not substantially the same as the listed policy-influencing position should be placed on an appropriate non-Schedule Policy/Career PD. Agencies should coordinate with OPM on any such adjustments. Organizational discrepancies identified during implementation, including situations where a subagency was listed incorrectly but the PD number is correct, should not be used as a basis to move the position. Such corrections should be addressed through the appropriate correction process or a subsequent submission.
Q: Are agencies allowed to make pen-and-ink changes to OF-8s associated with these PDs, or are they required to change PD numbers and complete a new OF-8?
A: Agencies may make minor administrative changes to OF-8s, including PD numbering suffixes or prefixes or organizational realignment, without affecting the Schedule Policy/Career designation, provided the duties and policy-influencing character remain substantially unchanged. If a change reflects different duties or a non-policy-influencing position, the agency should complete the appropriate classification documentation, which may require a new PD number and OF-8 under agency procedures.
Q: Do agencies have authority to remove positions from Schedule Policy/Career, and is supplemental guidance planned on the review process?
A: No. An agency must first petition the OPM Director recommending why a position should be removed from Schedule Policy/Career. As part of any petition, agencies should provide the same information requested as part of their position reviews for placing positions into Schedule Policy/Career accompanied by a detailed explanation supporting their request. OPM will transmit this recommendation to the President for his consideration.
Hiring and Staffing
Q: If an agency was actively recruiting for a competitive service position placed into Schedule Policy/Career on June 3, must the agency cancel the recruitment?
A: Not necessarily. Agencies may determine whether to continue or cancel an in-progress recruitment based on the stage of the hiring process. If the announcement is still open, or recently closed and no certificate or list of eligibles has been generated, the agency must readvertise the position and align the recruitment with the merit hiring procedures in 5 CFR 213.3601. If applicants have been assessed and a list or certificate has been or is about to be created, the agency may proceed, provided it clearly informs selectees before appointment that the position is in the excepted service under Schedule Policy/Career — including any differences in appointment conditions or tenure implications.
Q: Are Schedule Policy/Career employees eligible to apply for Senior Executive Service (SES) positions?
A: Yes. Schedule Policy/Career employees may apply for SES positions if they meet the qualifications and any applicable eligibility requirements.
Q: Are there restrictions on applying for or obtaining a non-Schedule Policy/Career federal position if the employee was previously terminated from a Schedule Policy/Career position?
A: There is no automatic bar solely because an individual previously served in or was terminated from a Schedule Policy/Career position. Eligibility for future federal employment depends on the nature of the termination, suitability or fitness for duty determinations and how such factors relate to the requirements of the position being filled.
Q: If an employee is on a voluntary detail when their permanent position moves into Schedule Policy/Career, how are the employee and the acting incumbent affected?
A: The employee's permanent position of record moves into Schedule Policy/Career, and the employee moves with it. The employee may then be detailed again to the position to which they were previously detailed, subject to any approval required for details from the excepted service to the competitive service. The acting incumbent may continue in the acting capacity if otherwise permissible.
Q: How are return rights and time-limited promotions affected for employees in positions moving into Schedule Policy/Career?
A: Return rights for time-limited promotions in the competitive service under 5 CFR part 335 have not changed. However, a time-limited promotion from the competitive service into Schedule Policy/Career is not covered by part 335, as that part applies to competitive-service internal placement actions. For employees on time-limited promotions in positions moving into Schedule Policy/Career, the agency has two options: terminate the time-limited promotion and return the employee to the position held before the promotion or to a position of equivalent grade and pay; or make the time-limited promotion permanent and then move the employee into the Schedule Policy/Career position.
An agency may not allow an employee to take a time-limited promotion from a non-Schedule Policy/Career competitive-service position to a Schedule Policy/Career excepted-service position under part 335, even with the employee's written agreement. A time-limited promotion from a competitive-service position to a Schedule Policy/Career excepted-service position is not authorized under part 335.
Q: Does conversion to Schedule Policy/Career affect an employee's progress toward competitive status or career tenure?
A: Employees serving a probationary or trial period at the time of conversion to Schedule Policy/Career will obtain competitive status after satisfactory completion of one year of continuous service in that position — time already served does not reset. For example, an employee with two months remaining in their probationary period at conversion would acquire competitive status after completing those two remaining months.
Regarding career tenure, an employee who moves from the competitive service to Schedule Policy/Career will receive service credit toward career tenure for time spent in a Schedule Policy/Career position, but only if the employee subsequently returns to the competitive service. Service under Schedule Policy/Career is not, by itself, creditable toward career tenure.
Q: The Quick Reference Guide for Employees states that Schedule Policy/Career positions are at-will unless the employee completed a probationary or trial period or an exception applies. Does completing a probationary or trial period mean an employee is no longer at-will?
A: No. OPM updated the Quick Reference Guide for Employees following the issuance of Executive Order 14410. Schedule Policy/Career employees are at-will at all times and are not required to serve a trial period. Prior completion of a probationary or trial period may be relevant to competitive status or other employment history, but it does not make the employee covered by title 5 chapters 43 and 75 while serving in a Schedule Policy/Career position.
Q: Are Schedule Policy/Career employees subject to OGE Form 278 financial disclosure requirements?
A: In March 2026 (and updated in June 2026), the Office of Government Ethics provided guidance on financial disclosure filing extensions for Schedule Policy/Career employees. Agencies should work with their Designated Agency Ethics Official or Alternate Designated Agency Ethics Official for guidance on financial disclosure requirements and timelines applicable to Schedule Policy/Career employees.
Q: Does Schedule Policy/Career designation affect Outside the Continental United States (OCONUS) relocation benefits or return rights?
A: Schedule Policy/Career designation does not, by itself, eliminate statutory or regulatory eligibility for OCONUS relocation benefits or return rights. However, return rights and noncompetitive appointment eligibility depend on the specific authority, appointment, agreement, and position involved. Eligibility for noncompetitive appointment to a competitive service position is not the same as a mandatory placement entitlement.
Termination Procedures
Q: Should agencies consult with OPM prior to terminating a Schedule Policy/Career employee?
A: Yes, agencies should contact OPM at employ@opm.gov before terminating a Schedule Policy/Career employee.
Q: Must an agency provide advance notice before terminating a Schedule Policy/Career employee?
A: Yes. Agencies should provide advance notice before effectuating a termination, provided the employee did not commit serious misconduct warranting immediate separation. Advance notice is appropriate for unacceptable performance, misconduct that in the agency's judgment does not warrant immediate termination, and actions not based on performance or conduct — such as loss of a security clearance or medical disqualification. Agencies should provide a single termination letter consistent with OPM's sample template, with an effective date that is a reasonable time in the future. During the period between issuance of the termination notice and the effective date of separation, agencies may place the employee on administrative leave rather than requiring the employee to continue reporting to the workplace, particularly where continued presence in the workplace may be disruptive to agency operations. In doing so, agencies must comply with applicable OPM regulations and agency policies governing administrative leave. Agencies will not utilize the two-step process used for performance-based or adverse actions under 5 U.S.C. Chapters 43 and 75 and OPM's implementing regulations.
Q: Can an agency remove a group of Schedule Policy/Career employees collectively, such as for failing to meet an agency-wide goal?
A: If a group of Schedule Policy/Career employees failed to meet expected performance, an agency should consider whether it is necessary to take an action based on each individual’s performance and not solely on the failure of the group to meet an agency-wide goal. Agencies must process actions on an individual basis as is required for all personnel actions.
Q: OPM policy indicates agencies can terminate Schedule Policy/Career employees for performance, conduct, or mission-based reasons. What constitutes a mission-based reason for terminating a Schedule Policy/Career employee?
A: Mission-based reasons are reasons other than performance or conduct that support appropriate administrative action up to and including termination and removal from the federal service for the good of the Federal service. Examples include loss of a required security clearance, medical disqualification, failure to maintain a condition of employment such as a mandatory certification or license, failure to accept a directed geographic reassignment.
Retirement and Benefits
Q: Does placement into Schedule Policy/Career change an employee's retirement eligibility, minimum retirement age, or Federal Employees Health Benefits (FEHB) coverage?
A: No. Placement into Schedule Policy/Career does not change an employee's retirement eligibility, minimum retirement age, or FEHB rights. Retirement eligibility continues to be determined under the applicable retirement system based on age, years of creditable service, and other statutory requirements. FEHB continuation into retirement depends on meeting the normal FEHB eligibility requirements.
Q: What are the retirement implications if a Schedule Policy/Career employee is terminated?
A: If an employee is terminated for cause, including a performance-based removal, they are not eligible for discontinued service retirement or early retirement under the Voluntary Early Retirement Authority (VERA). However, they may still be eligible for other retirement options — such as an immediate voluntary retirement or a deferred retirement — if they meet the applicable age and service requirements. Placement in Schedule Policy/Career does not itself alter these retirement eligibility rules. For guidance on how agencies should handle retirement requests submitted following an advance notice of termination, see the Q&A addressing future retirement effective dates below.
Q: Are agencies required to offer the Deferred Resignation Program (DRP), VERA, or other separation incentives as an alternative to Schedule Policy/Career placement?
A: No. Schedule Policy/Career placement does not require agencies to offer DRP, VERA, or any other separation option. VERA may be offered only when authorized and in accordance with applicable OPM approval and agency procedures. Any DRP or similar program would need to be authorized under separate agency or governmentwide guidance and would not be an automatic alternative to Schedule Policy/Career placement.
Q: If an employee submits a retirement request following advance notice of termination, can they request a future retirement effective date?
A: When an employee who has received advance notice of termination submits a retirement request, agencies are encouraged to honor requests for a future retirement effective date of up to 30 days. However, agencies should not permit employees to use a retirement request to indefinitely delay a pending termination. Where an employee seeks a retirement effective date more than 30 days from the date the agency intended to effectuate the termination, the agency should consider whether doing so is in the public's best interest. Under no circumstances should an agency continue to employ an individual for more than 90 days solely to accommodate a future retirement request.
Agencies must retain records documenting that a termination was proposed and that the employee subsequently retired in lieu of termination, consistent with the Guide to Processing Personnel Actions. Such documentation ensures that other agencies are properly notified of the circumstances surrounding the separation when making future hiring decisions.
Do not reply to this unmonitored govDelivery send-only email address.
|
