Schedule Policy/Career: What the Final Rule Means for Federal Workers and the Public They Serve

Summary

On February 6, 2026, U.S. Office of Personnel Management (OPM) finalized a regulation titled “Improving Performance, Accountability and Responsiveness in the Civil Service.” The rule revives the first Trump administration’s Schedule F initiative under a new name: Schedule Policy/Career (Schedule P/C).

Despite the new label, the core idea is the same – the administration has created a pathway to convert large numbers of career federal jobs into positions that lack any protections and whose incumbents can effectively be fired for any reason at all.

This is one of the most significant changes to the civil service in generations. It threatens longstanding merit-based protections, increases political pressure on career staff, and risks weakening the government’s ability to serve the public.

Below is what federal workers and the communities they serve should know right now.

What the Rule Does

Creates a new “excepted service” category for so-called “policy-influencing” jobs

Most civil servants are hired into the “competitive service” (requiring examinations and other processes), the “excepted service” (which generally has fewer requirements), and the Senior Executive Service (top level managerial and supervisory positions). 

Schedule P/C is a new category within the excepted service for positions the administration labels “confidential, policy-determining, policy-making, or policy advocating” (OPM uses the shorthand “policy-influencing” to describe these positions). This is important because, by statute, these types of positions do not have civil service protections. When Congress created this exception, it intended for it to apply only to political appointees, the relatively small group of the president’s appointees who change from one administration to the next. Until President Trump, this exception to civil service protections has never applied to career positions, which are hired through merit-based processes and serve across administrations. Schedule P/C now blurs the line between these career positions and political appointments and will strip career positions of their civil service protections.

OPM estimates roughly 50,000 positions could be moved initially into Schedule P/C, but it is unclear how far Schedule P/C could reach. It could potentially reach lawyers, analysts, scientists, economists, program managers, procurement specialists, and many others if their roles interact with agency policy.

What Changes for Employee Rights

Schedule P/C positions will no longer have civil service protections

OPM emphasizes that Schedule P/C roles will still be filled through the nonpartisan, merit-based hiring procedures that would otherwise apply to a particular position. But the due process protections for civil servants in Schedule P/C will now end:

• If your position is placed into Schedule P/C, you generally lose the statutory due-process rights governing removals and discipline under Title 5 of the U.S. Code. The usual adverse action processes (under 5 U.S.C. Chapter 75) and performance processes (under 5 U.S.C. Chapter 43) do not apply.  In short, agencies can remove Schedule P/C employees without having to follow the protections Congress built into civil service law.
• Related appeal rights to the Merit Systems Protection Board tied to those frameworks generally no longer apply.
• OPM says certain baseline safeguards remain, including prohibitions on political retaliation and other prohibited personnel practices. Complaints of prohibited personnel practices would traditionally go to the Office of Special Counsel but the rule now bars that avenue for those in Schedule P/C – such complaints by Schedule P/C employees will now be handled by the respective agency’s Office of General Counsel. The rule replaces independent, external guardrails with agency-controlled internal policies, shifting power decisively toward management.
• Veterans’ preference and merit-based hiring technically continue to apply.

What This Means for Collective Bargaining

Being moved into Schedule P/C does not automatically eliminate union representation.

OPM’s guidance states that reclassification alone does not remove employees from collective bargaining units. 

However, OPM guidance also instructs agencies to seek unit clarification for positions deemed “policy-determining” or “policy-making.” Those categories may be excluded from bargaining under federal labor law. Agencies are directed to file petitions with the Federal Labor Relations Authority (FLRA) to clarify whether such positions should remain in bargaining units. Unless and until the FLRA rules, existing bargaining obligations remain in place for these positions. 

In practice, Schedule P/C risks shrinking bargaining units over time and builds on a broader campaign by this administration to weaken collective bargaining and federal labor protections. 

**Effect of the Rule on Student Loan Repayment and the “3 Rs” (Recruitment, Relocation, Retention) **

Schedule P/C is designed to capture positions deemed “confidential, policy-determining, policy-making, or policy-advocating.” That designation matters for certain benefits and incentives limited by existing federal law.

Under current statutes, employees in positions excepted for those reasons are generally not eligible for new student loan repayment benefits (_see _5 U.S.C. § 5379) or new recruitment, relocation, or retention incentives (the “3 Rs”) (_see _5 U.S.C. §§ 5753–5754). In other words, once a position is moved to Schedule P/C, agencies typically cannot approve new agreements for these benefits.

OPM’s implementing guidance indicates that existing agreements are expected to continue through their current service periods, but employees moved into Schedule P/C should not expect these benefits to be renewed or newly offered afterward.

OPM has directed agencies to handle student loan repayment and incentive questions through internal HR and pay policy channels, so employees should watch for agency guidance and contact their HR offices for position-specific answers.

This Is Not About Improving Performance or Accountability

_If the real goal were better performance or accountability, tools already exist or could be improved. _
Instead, Schedule P/C uses the language of “performance” and “accountability” to attempt to justify stripping protections from broad classes of career workers.
By making large portions of the professional workforce subject to the whims of political leaders, the rule risks:

• increased turnover and loss of institutional knowledge
• self-censorship and reduced willingness to raise legal or ethical concerns
• politicization of everyday government work
• weaker services for the public

Overwhelming Public Opposition

OPM received more than 40,500 public comments on the proposal and acknowledged that roughly 94% opposed it.
Federal workers, unions, good-government organizations, experts, and members of the public warned that Schedule P/C would undermine the nonpartisan civil service and harm communities nationwide. OPM finalized the rule anyway.

Timing and What Happens Next

• Effective date: 30 days after the February 6 publication.
• Positions are not moved automatically – an executive order by the president is required.  Jobs and rights remain as they are today until the executive order is issued and the positions to be moved are listed.
• Agencies must update internal policies (discipline, grievances, prohibited personnel practices) within 30 days after the rule takes effect.
• OPM has already issued initial implementing guidance and additional follow-up guidance, along with templates and agency instructions. More guidance is expected. These guidance documents explain how agencies will notify employees, revise internal procedures, handle collective bargaining questions, and operationalize the rule in practice.

Workers should closely monitor agency communications, as many of the impacts will flow from these internal policies.

Democracy Forward Is Already Fighting Schedule P/C in Court
Democracy Forward is already challenging Schedule P/C in federal district court and continues the fight to protect the nonpartisan civil service in various other cases.
Civil Service Strong will continue tracking developments and sharing important updates relating to Schedule P/C.

Relevant Links

• Final Rule, Improving Performance, Accountability and Responsiveness in the Civil Service 
• February 5, 2026, Initial Implementing Guidance for Schedule Policy/Career Final Rule
• February 6, 2026, Additional Implementing Guidance for Schedule Policy/Career Final Rule