The Calm Before the Storm

A Long Wait for Schedule P/C.

Anticipation.  Dread.  Impatience. 

This is how I imagine most of us feel as we wait on Schedule Policy/Career (P/C) to drop.  We have known it was coming since the Presidential election results were announced in November 2024, but it does not make the wait any easier.  While no federal employees have been officially transitioned to Schedule P/C, news outlets are reporting that some federal agencies are starting to message the upcoming change.

Let’s take a deep dive into what we know so far, and why this is taking so long.

The Origin of Schedule P/C.

Schedule P/C can be traced back to the first Trump Administration – where it was called “Schedule F.”  Schedule F was a late term initiative issued by President Trump in October 2020. Executive Order 13957 established this new classification for career federal employees that occupied positions of “a confidential, policy-determining, policy-making, or policy-advocating character.”  (President Trump’s 2020 Executive Order) The order stated that these positions would be excepted from competitive hiring procedures, and employees occupying these positions would be excepted from adverse action procedures, making them easier to fire. 

According to a 2022 Government Accountability Office (GAO) report, no federal agencies actually placed any positions into Schedule F before it was revoked by President Biden through Executive Order 14003 on January 22, 2021.  (President Biden’s 2021 Executive Order) The Office of Personnel Management (OPM) instructed agencies to review positions, but the deadline to submit recommendations was three days prior to the issuance of President Biden’s Executive Order and OPM did not complete its review.  GAO noted only a few agencies completed the assignment.  For example, the Office of Management and Budget (OMB) asked to place 136 positions into Schedule F.  Had this action been approved, it would have impacted 415 employees, which is 68% of OMB’s workforce. (2022 GAO Report)  

In addition to revoking the Schedule F Executive Order, President Biden (through OPM) also issued new regulations that would make reinstating Schedule F harder for future administrations. These new regulations were effective on May 9, 2024.  They clarified that the phrase “confidential, policy-determining, policy-making, or policy-advocating” referred to political appointments only and not career positions, and they established an appeals process for federal employees who were involuntarily transferred from the competitive service to the excepted service or from one excepted service schedule to another.  (OPM’s May 2024 Regulations)

The Resurrection of Schedule F.

After the new regulations were issued, Schedule F lay dormant for about eight months - until President Trump was re-elected in 2025.  To no one’s surprise, President Trump reinstated Schedule F (albeit under a new name) with Executive Order 14171 on January 20, 2025.  (President Trump’s 2025 Executive Order)

The Schedule P/C executive order has the same core purpose as Schedule F – to reclassify career employees to the excepted service and remove civil service job protections – but there are a few differences in this version. Most notable is the name change from Schedule F to Schedule P/C. President Trump also shifted the final authority to approve positions for Schedule P/C to himself.  Schedule F gave this power to OPM. The Schedule P/C order also does not include the exception to competitive hiring procedures that was included in Schedule F. The order states that Schedule P/C positions should be filled under the same hiring procedures used prior to the transition. The Schedule P/C order also directed OPM to rescind the May 2024 regulations, canceling the final layer of protection that the Biden Administration put in place prior to the 2024 elections. 

The Slow Walk to Implementation.

Since January 2025, OPM and federal agencies have been slowly working towards making Schedule P/C a reality for the federal workforce. 

Most significantly, OPM issued new regulations on February 6, 2026, and they were effective on March 9, 2026.  (OPM’s March 2026 Regulations) These new regulations formally implement Schedule P/C, and they were likely the biggest hold up to implementation.  When a federal agency issues new regulations (like OPM did here), they must follow the lengthy rule-making process that is laid out in the Administrative Procedure Act (APA).  For example, agencies must first issue a “proposed rule” that outlines the new regulations and gives the public an opportunity to comment.  The Schedule P/C proposed rule was issued on April 23, 2025 (only three months after the Executive Order was issued), and the comment period was open for a total of 45 days (closing on June 7, 2025).  (OPM’s April 2025 Proposed Rule) OPM received 40,500 comments during the 45-day period.  94% of those comments opposed the proposed regulations.  From June 2025 to February 2026, OPM had to review and adjudicate this massive number of public comments, and they issued their final regulations (called the “final rule”) on February 6, 2026.  Once final regulations are issued, agencies must generally wait a minimum of 30 days before the new regulations are effective.  This brings us to our March 9, 2026 effective date.  However, keep in mind that these rules did not actually move any positions to Schedule P/C.  They only created the framework.  

Since early March, we have been waiting for the President to issue the Executive Order that will move the first group of positions into Schedule P/C.  Remember that the President reserved the authority to move positions to Schedule P/C for himself.  Presumably, federal agencies have already reviewed their positions, and they are preparing to submit (or have already submitted) their recommendations.  Most agencies seem to be rather close-mouthed about what positions they are recommending for transition.  However, on Friday, May 15, 2026, Reuters first reported that the Chief Human Capital Officer of the U.S. Department of Health and Human Services (HHS) emailed a group of supervisors, stating that the department had identified hundreds of GS-15 positions to be reclassified to Schedule P/C.  (Reuters’ HHS Article) He called this an “initial tranche” and stated that there will be more to come.  This is one of the first reports of employee notifications since OPM’s final rule went into effect in March.  Could this signal that implementation is imminent?  

What Does This Mean for Me?

If your position is transitioned to Schedule P/C, you can expect the following changes:

•  Exclusion from due process requirements of 5 USC Chapter 43 and Chapter 75.  (This means your agency can fire you for any conduct or performance issue without advance notice or opportunity to respond, and you have no right to appeal that action to the Merit Systems Protection Board (MSPB).)

• Exclusion from Office of Special Counsel (OSC) reporting and corrective action processes. (This means that you cannot report prohibited personnel practices (PPPs), including whistleblowing, to OSC or seek corrective action through OSC; You will be encouraged to report PPPs to your agency.)

• Exclusion from recruitment, relocation, and retention incentives.

• Exclusion from student loan repayment programs.

It is also worth noting that there are multiple legal challenges to Schedule P/C. Several labor unions, including the American Federation of Government Employees (AFGE) and the National Treasury Employees Union (NTEU), have filed lawsuits, seeking to block implementation.  The outcome remains to be seen, but this could be yet another hurdle that the Administration must clear before they can make Schedule P/C a reality.

Unfortunately, the best advice is to wait, watch, and educate yourself so that you are ready when the day comes. The road has been long, but the journey is far from over.