Reduction in Force

Recall

91%

38 of 42 topics OPM answered specifically match an argument rated substantive here.

Precision

78%

115 of 148 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.

• ✓Consistency with statutory framework (5 U.S.C. 3502)Answered specifically14 arguments · group "Prioritizing Performance Over Tenure and Veterans' Preference in Retention" (covered)
• ✓Due effect of tenure subgroup and length of service as tie-breakersAnswered specifically13 arguments · group "Prioritizing Performance Over Tenure and Veterans' Preference in Retention" (covered)
• ✓Undermining veterans' preferenceAnswered specifically16 arguments · group "Prioritizing Performance Over Tenure and Veterans' Preference in Retention" (covered)
• ✓Support for alignment with Merit System PrinciplesAnswered specifically6 arguments · group "Prioritizing Performance Over Tenure and Veterans' Preference in Retention" (covered)
• ✓Rule as plan to undermine merit systemAnswered specifically3 arguments · group "General Opposition and Calls to Withdraw the RIF Rule" (covered)
• ✓Reliability of performance ratingsAnswered specifically18 arguments · group "Prioritizing Performance Over Tenure and Veterans' Preference in Retention" (covered)
• ✓Targeting and manipulation of ratingsAnswered specifically8 arguments · group "Supervisor bias and challenging ratings used in RIF" (covered)
• ✓Justification for the changesAnswered specifically15 arguments · group "Adequacy of DOD Precedent and Evidentiary Justification" (covered)
• ✓Current system prioritizes service over performanceAnswered specifically1 argument (covered)
• ✓Impact on recruitment, retention and institutional knowledgeAnswered specifically11 arguments · group "Workforce Stability, Morale, and Institutional Knowledge Concerns" (covered)
• ✓Current rules not burdensome given past workforce reductionsAnswered specifically7 arguments (covered)
• ✓Reliance on DOD RIF proceduresAnswered specifically4 arguments · group "Adequacy of DOD Precedent and Evidentiary Justification" (covered)
• ✓Separate rulemakings on performance appraisal and RIF appealsAnswered specifically8 arguments · group "APA procedural defects and weak supporting sources" (covered)
• ✓Delay finalization or reopen comment periodAnswered specifically3 arguments · group "Requests to extend or reopen the comment period" (covered)
• ✓Opposition to transfer of RIF appeals to OPMAnswered with general views13 arguments · group "Moving RIF Appeals to OPM and Rule Justification" (covered)
• ✓Removal of erosion-of-duties RIF triggerAnswered specifically4 arguments (covered)
• ✓Exclusion of probationary, trial-period and temporary employeesAnswered specifically8 arguments (covered)
• ✗Impact on early-career recruitment and leadership pipelineAnswered specificallynot matched (not covered)
• ✗Presumption of retention for probationary employeesAnswered specificallynot matched (not covered)
• ✓Emergency shutdown furlough definitionAnswered specifically1 argument (covered)
• ✓Narrowing transfer of function to interagency transfersAnswered specifically3 arguments · group "Organizational Unit Definition of Competitive Areas in RIF" (covered)
• ✓Notice and opportunity for intra-agency transfers of functionAnswered specifically1 argument · group "Organizational Unit Definition of Competitive Areas in RIF" (covered)
• ✓Anti-manipulation provision for competitive areasAnswered specifically2 arguments · group "Organizational Unit Definition of Competitive Areas in RIF" (covered)
• ✓Competitive area definition and 'under separate administration'Answered specifically3 arguments · group "Organizational Unit Definition of Competitive Areas in RIF" (covered)
• ✓Using FEVS hierarchy for competitive areasAnswered specifically2 arguments · group "Organizational Unit Definition of Competitive Areas in RIF" (covered)
• ✓Gerrymandering of competitive areasAnswered specifically3 arguments · group "Organizational Unit Definition of Competitive Areas in RIF" (covered)
• ✓Enhanced performance credit based on awardsAnswered specifically1 argument · group "Performance Rating Credit, Transmutation, and Imputed Rating Rules" (covered)
• ✓Vagueness and complexity of new retention formulaAnswered specifically4 arguments · group "General Opposition and Calls to Withdraw the RIF Rule" (covered)
• ✓Errors in proposed rule examplesAnswered specifically1 argument (covered)
• ✓Effective date of retention standing and rating changesAnswered specifically2 arguments (covered)
• ✓Long unpaid RIF furloughsAnswered specifically3 arguments · group "RIF Rule Conflicts with Collective Bargaining Agreements" (covered)
• ✓OPM approval of competitive area abolishmentAnswered specifically3 arguments · group "Organizational Unit Definition of Competitive Areas in RIF" (covered)
• ✓SES placement rights in competitive area abolishmentAnswered specifically1 argument (covered)
• ✓USERRA protections in RIFsAnswered specifically6 arguments · group "Performance Rating Credit, Transmutation, and Imputed Rating Rules" (covered)
• ✓Assessments for qualification in assignment rightsAnswered specifically3 arguments · group "Changes to RPL, CTAP, ICTAP and Skills-Based Qualification Assessments" (covered)
• ✓Changes to RPL, CTAP and ICTAPAnswered specifically4 arguments · group "Changes to RPL, CTAP, ICTAP and Skills-Based Qualification Assessments" (covered)
• ✓Costs to retirement fundsAnswered specifically2 arguments · group "Unaccounted Costs and Burdens of RIF Rule Changes" (covered)
• ✓Cost savings from simplificationAnswered specifically4 arguments (covered)
• ✓Reliance interests of employeesAnswered specifically6 arguments · group "Moving RIF Appeals to OPM and Rule Justification" (covered)
• ✓Collective bargaining agreements with seniority protectionsAnswered specifically4 arguments · group "RIF Rule Conflicts with Collective Bargaining Agreements" (covered)
• ✓Increase performance-based service credit insteadAnswered specifically3 arguments (covered)
• ✓Refine performance metrics within current frameworkAnswered specifically12 arguments · group "Prioritizing Performance Over Tenure and Veterans' Preference in Retention" (covered)
• ✓Use voluntary tools instead of RIF reformAnswered specifically6 arguments (covered)

Read the final rule: Reduction in Force

• 10 copies · OPM-2025-0107-0429

  I strongly oppose OPM’s proposed changes to Reduction in Force (RIF) procedures that would prioritize recent performance ratings over tenure, veterans’ preference, and length of federal service. This proposal creates serious risks for federal employees, especially disabled veterans, veteran spouses, and bargaining unit employees working under increasingly unrealistic production standards. Perform…

• 9 copies · OPM-2025-0107-0113

  I respectfully dissent from the proposed revisions to the Reduction in Force (RIF) guidelines. While modernizing workforce management and rewarding performance are valid goals, the proposal is flawed in both design and likely impact. Rather than strengthening the federal workforce, it risks undermining fairness, morale, and mission effectiveness. 1. Overemphasis on Performance Prioritizing perfo…

• 5 copies · OPM-2025-0107-0458

  I am writing to express my opposition to Docket ID: OPM-2025-0107. This proposal appears to circumvent the statutory intent that places tenure at the forefront of retention priority. By removing tenure as a retention factor, the government is essentially incentivizing the removal of its most experienced professionals. In any organization, especially one managing public resources and land, 'insti…

• 4 copies · OPM-2025-0107-0095

  The proposed rule fundamentally changes how reduction-in-force (RIF) retention standing is determined. Under the current system, tenure and length of service dominate, with performance ratings providing marginal adjustments through additional service credit. The proposal instead centers performance ratings as the primary ranking factor, relegating tenure and service length to tie-breaking roles. T…

• 3 copies · OPM-2025-0107-0515

  Knowledgeable experienced public servants are essential for the government to function. They carry the knowledge of why something is the way it is, and the processes that got it there. They deserve protections, because they are experts and hard to replace and have actively chosen positions that serve others knowing it will not provide the same income as equivalent private sector positions. Do not …

• 3 copies · OPM-2025-0107-0034

  To the Office of Personnel Management: I write as a veteran federal employee who has earned a high performance rating under the current merit‑system. While I applaud any effort to make our workforce more effective, the proposed rule that would replace seniority with performance ratings as the primary factor in RIFs raises serious constitutional and statutory concerns. Below I outline the principa…

• 3 copies · OPM-2025-0107-0577

  Office of Personnel Management (OPM) RIN 3206-AO86 I am deeply concerned about several aspects of OPM’s proposed RIF regulations (RIN 3206-AO86) and urge OPM to reconsider this Most notably, I am concerned about giving virtually no weight to employee tenure and length of service in the conduct of a RIF. I generally agree that performance should be weighted more heavily than tenure in determining …

• 3 copies · OPM-2025-0107-0118

  To couple an arbitrary limitation of performance rating with prioritizing performance in a RIF is disingenuous to demonstrate an employee’s true performance level. There is a quota or certain forced distribution on how many high ratings can be given for each performance year, i.e., how many 3, 4, or 5 ratings can be distributed to staff. Additionally, performance ratings can be subjective and may …

• 3 copies · OPM-2025-0107-0128

  I am submitting this comment in strong opposition to OPM's proposed rule to revise federal Reduction in Force regulations published at 91 FR 10904 (March 5, 2026). I am a former employee of the United States Agency for International Development (USAID), separated via Reduction in Force in July 2025. My comments are informed directly by that experience and reflect the concerns of many colleagues wh…

• 3 copies · OPM-2025-0107-0228

  To Whom It May Concern: I submit this comment for the official record to express strong opposition to the Office of Personnel Management’s proposed revisions to veterans’ preference in federal hiring. Many commenters have described these changes as not only harmful in substance, but also deeply disrespectful and disingenuous in the way they have been presented to the public. A central concern rai…