Second Verse, Same as the First

Suitability determinations used to be something you dealt with once — before your first day on the job — but not anymore. OPM's new regulations expand the suitability process to reach current federal employees for their post-appointment conduct, add new grounds for action (including tax delinquency and refusal to sign OPM's forthcoming non-disclosure agreement), and put debarment on the table long after you've already been hired. Here's what changed, why it matters, and what could be coming next.