Suitability and Fitness

Recall

96%

44 of 46 topics OPM answered specifically match an argument rated substantive here.

Precision

78%

156 of 200 arguments rated substantive were answered specifically in the final rule. OPM does not answer every argument separately, so this is a floor, not an error rate.

• ✓Expansion of suitability factors applicable to employeesAnswered specifically8 arguments · group "Vagueness and Overbreadth of New Suitability Factors" (covered)
• ✓Definitions for theft, misuse, negligent loss exampleAnswered specifically19 arguments · group "Vagueness and Overbreadth of New Suitability Factors" (covered)
• ✓Non-disclosure obligations and whistleblower protectionsAnswered specifically20 arguments · group "Nondisclosure and Testimony Suitability Factors Threaten Whistleblowers" (covered)
• ✓Refusal to furnish testimony exampleAnswered specifically9 arguments · group "Nondisclosure and Testimony Suitability Factors Threaten Whistleblowers" (covered)
• ✓Vagueness of legal obligations/tax filing factor and 'knowing and willful'Answered specifically9 arguments · group "Vagueness and Overbreadth of New Suitability Factors" (covered)
• ✓Timely filing of tax returnsAnswered specifically4 arguments · group "Failure to timely file tax returns as suitability factor" (covered)
• ✓Overlap of legal obligations factor with criminal conductAnswered specifically6 arguments · group "Requests for Clarification, Communication, and Processing Timelines" (covered)
• ✓Alcohol use factorAnswered specifically2 arguments · group "Alcohol and Drug Use Suitability Factors in § 731.202" (covered)
• ✓Overlap of provision precluding Federal service with statutory bar factorAnswered specifically3 arguments (covered)
• ✓Citizenship and nationality requirementsAnswered specifically3 arguments · group "Citizenship Criterion and Related Suitability Removal Concerns" (covered)
• ✓OPM authority for post-appointment conduct suitability actionsAnswered specifically18 arguments · group "Suitability Actions Against Current Employees for Post-Appointment Conduct" (covered)
• ✓Chapter 75 as exclusive procedure for misconductAnswered specifically12 arguments · group "Suitability Actions Against Current Employees for Post-Appointment Conduct" (covered)
• ✓Policy is new and politically motivatedAnswered specifically9 arguments · group "Opposition to Rule as Politicizing the Federal Workforce" (covered)
• ✓Authority over career SES employeesAnswered specifically1 argument · group "Coverage, Definitions, and Authority Over Covered Employee Groups" (covered)
• ✓Add Douglas factorsAnswered specifically3 arguments (covered)
• ✓Post-appointment actions unnecessary given Chapter 75Answered specifically13 arguments · group "Suitability Actions Against Current Employees for Post-Appointment Conduct" (covered)
• ✓Completing actions after separationAnswered specifically2 arguments (covered)
• ✓Agency input and discretion in post-appointment casesAnswered specifically13 arguments · group "Suitability Actions Against Current Employees for Post-Appointment Conduct" (covered)
• ✓Delegate post-appointment authority to agenciesAnswered specifically10 arguments · group "Suitability Actions Against Current Employees for Post-Appointment Conduct" (covered)
• ✓OPM capacity to handle referral workloadAnswered specifically3 arguments · group "Requests for Clarification, Communication, and Processing Timelines" (covered)
• ✓Appointees who previously converted to employeesAnswered specifically1 argument · group "Coverage, Definitions, and Authority Over Covered Employee Groups" (covered)
• ✓Politicization, spoils system, and Hatch ActAnswered specifically26 arguments · group "Opposition to Rule as Politicizing the Federal Workforce" (covered)
• ✓Agency head making referralsAnswered specifically1 argument · group "Suitability Actions Against Current Employees for Post-Appointment Conduct" (covered)
• ✓No due process or appeal rightsAnswered specifically23 arguments · group "Suitability Actions Against Current Employees for Post-Appointment Conduct" (covered)
• ✓Five-workday removal requirementAnswered specifically11 arguments · group "Five-Day Response and Removal Timeframe for Suitability Actions" (covered)
• ✓Restore notice of appeal rightsAnswered specifically1 argument (covered)
• ✓Final decisions by career staff and deciding official tenureAnswered specifically6 arguments · group "Implementation safeguards, oversight, and transparency of adjudication criteria" (covered)
• ✓Removal timing for employees overseasAnswered specifically2 arguments · group "Five-Day Response and Removal Timeframe for Suitability Actions" (covered)
• ✓Diminished due process compared to Chapter 75Answered specifically22 arguments · group "Suitability Actions Against Current Employees for Post-Appointment Conduct" (covered)
• ✓Reporting to Central Verification System and privacyAnswered specifically6 arguments · group "Recording Suitability Actions in the Central Verification System" (covered)
• ✓Continuous vetting and internal agency sourcesAnswered specifically6 arguments · group "Continuous Vetting Scope, Privacy, Justification, and Due Process" (covered)
• ✓Need for actions given Trusted Workforce 2.0 progressAnswered specifically4 arguments · group "Continuous Vetting Scope, Privacy, Justification, and Due Process" (covered)
• ✓Removal of references to part 315Answered specifically5 arguments · group "Removal of Part 315 Probationer Protections and Reinstatement Cancellation" (covered)
• ✓Training standards for adjudicatorsAnswered specifically6 arguments · group "Undefined Training Standards and Referral Criteria in Suitability Rule" (covered)
• ✓Adequacy of comment periodAnswered specifically6 arguments · group "Adequacy of Comment Period and Public Participation" (covered)
• ✓Impact on recruitment, retention, and moraleAnswered specifically8 arguments · group "Rule's Effects on Federal Recruitment and Retention" (covered)
• ✓Consistency with prohibited personnel practicesAnswered specifically9 arguments (covered)
• ✓Implementation guidance and effective dateAnswered specifically1 argument · group "Requests for Clarification, Communication, and Processing Timelines" (covered)
• ✓MSPB impact and number and speed of removalsAnswered specifically2 arguments · group "Challenges to Claimed Efficiency Gains and Impact Analysis" (covered)
• ✓Compliance with OMB Circular A-4Answered specifically7 arguments · group "Challenges to the Rule's Cost-Benefit Analysis and Savings Claims" (covered)
• ✓50 percent estimate of Chapter 75 removals shiftingAnswered specifically4 arguments · group "Challenges to the Rule's Cost-Benefit Analysis and Savings Claims" (covered)
• ✓OPM workload estimate assumptionsAnswered specifically2 arguments · group "Challenges to the Rule's Cost-Benefit Analysis and Savings Claims" (covered)
• ✓Washington, DC locality assumptionAnswered specifically1 argument · group "Challenges to the Rule's Cost-Benefit Analysis and Savings Claims" (covered)
• ✓Thirty percent savings assumptionAnswered specifically1 argument · group "Challenges to the Rule's Cost-Benefit Analysis and Savings Claims" (covered)
• ✓OPM adjudicator staffing grade, locality, and numberAnswered specifically4 arguments · group "Questions on Rule Coverage, Staffing, and Cost Assumptions" (covered)
• ✓Improve Chapter 75 training insteadAnswered specifically6 arguments (covered)

Read the final rule: Suitability and Fitness

• 15 copies · OPM-2025-0007-0060

  I write in strong opposition to the Office of Personnel Management’s proposed rule expanding suitability-based removals to current federal employees (RIN: 3206-AO46). This rule undermines the core principles of a professional, non-partisan civil service. While it is important to ensure the integrity of the federal workforce, this proposal introduces sweeping changes that will erode due process, i…

• 7 copies · OPM-2025-0007-0516

  I strongly oppose the proposed amendments to 5 CFR Part 731, which would radically expand OPM’s authority to summarily fire current federal employees based on vague “suitability” standards. This rule undermines merit-system protections and core due-process rights in several troubling ways: 1. **Bypasses established due process (Chapter 75) ** The rule enables OPM to direct agencies to remove an …

• 6 copies · OPM-2025-0007-0064

  Regarding: OPM-2025-0007-0001, Federal Register No. 2025-10067 I am writing to voice my strong opposition for this proposed rule change. The existing rules are more than sufficient to adjudicate instances of non-suitability. Additionally, this rule change explicitly states that OPM, rather than the employing agency, would have the final suitability determination; however, OPM does not directly in…

• 5 copies · OPM-2025-0007-0008

  This rule, in conjunction with other newly proposed OPM rules and executive orders, seeks to erode civil service protections and weaken the federal workforce. This rule will limit or eradicate due process protections for civil servants and create an at-will civil service workforce. This is a dangerous precedent as the federal government will not only lose experienced and qualified employees, but i…

• 5 copies · OPM-2025-0007-0216

  I am writing to strongly oppose this proposed rule change. The existing rules are more than sufficient to adjudicate instances of non-suitability. Additionally, this rule change explicitly states that OPM, rather than the employing agency, would have the final suitability determination; however, OPM does not directly interact with employees of different agencies and, therefore, should not make per…

• 5 copies · OPM-2025-0007-0268

  Opposition to Proposed Rule RIN 3206–AO84 – Suitability and Fitness To Whom It May Concern: I am writing as a long-serving federal employee and concerned citizen to express strong opposition to the proposed rule titled Suitability and Fitness (RIN 3206–AO84), published in the Federal Register on June 3, 2025. This rule threatens to fundamentally alter the landscape of civil service protections …

• 5 copies · OPM-2025-0007-0682

  Opposition to Proposed Changes to 5 CFR Part 731 – “Suitability and Fitness” Rulemaking I am writing to express strong opposition to the Office of Personnel Management’s proposed rule change regarding post-appointment suitability actions under 5 CFR Part 731, as outlined in Docket ID OPM-2025-0007-0001. While I support efforts to maintain a high standard of conduct in federal service, this rule …

• 3 copies · OPM-2025-0007-1067

  July 3, 2025 Federal eRulemaking Portal: https://regulations.gov Charles Ezell Acting Director, U.S. Office of Personnel Management 1900 E Street, N.W. Washington, DC 20415 Re: “Suitability and Fitness,” Proposed Rule, Docket ID: OPM-2025-0007, RIN 3206-AO84 Dear Acting Director Ezell: Public Employees for Environmental Responsibility (PEER) submits these comments on the “Suitability and Fitness P…

• 3 copies · OPM-2025-0007-0434

  I write to express my strong opposition to the proposed rule OPM-2025-0007, which I believe violates fundamental constitutional principles and threatens the integrity of our federal civil service system. The proposed rule appears to undermine the constitutional principle of separation of powers by concentrating excessive authority in the executive branch to arbitrarily remove or reclassify feder…

• 3 copies · OPM-2025-0007-0436

  Every federal agency employee I have met is a true patriot who chose to put their life into improving their country. It is absolutely shameful that OPM now seeks to throw them out because they refuse to bend to the administration's whims. The proposed rule conceives of loyalty not as willingness to help one's country, which every agency employee possesses in spades, but willingness to pledge blind…

• 3 copies · OPM-2025-0007-0506

  Federal employees are loyal to the American people, not a president. The agencies they work for and represent were designated by congress, and they continue to serve the mission and purpose of those crucial agencies. They are passionate about their expertise, as many federal jobs are very sought after and highly competitive. They are propelled by public service, and a commitment to serve and prote…

• 3 copies · OPM-2025-0007-0019

  This rule will be abused and used to retain only those the administration deems suitable federal employees. Probably with some future loyalty test. It is a pathway to lawsuits, nepotism, and should not be adopted.…

• 3 copies · OPM-2025-0007-0059

  This proposed rule should not be implemented. It talks about OPM evaluating an employee's suitability, however this does not work in practice. Many employees have very specialized jobs that are not easily understood outside of their field, and OPM would not be able to evaluate their work as well as their agency could. Considering evaluation plans have been halted at agencies, how would OPM be able…

• 3 copies · OPM-2025-0007-0079

  No Loyalty Pledge!!! We are a democracy. We owe no !loyalty to any individual, President Prophet, or King.…

• 3 copies · OPM-2025-0007-0544

  This rule will enable politicization of federal employment and erode the civil service protections that have evolved over the history of our country. Some employees will be reclassified to at-will positions by the separately proposed Schedule Policy/Career rule. The rule proposed here will effectively remove the protections afforded by the Civil Service Reform Act for the remainder of the workforc…