June 2025

On June 6, AERA provided comments on a proposed rule to designate certain federal agency staff under a new category of “Schedule Policy/Career.” This rule is intended to implement the executive order (EO) issued by President Trump, “Restoring Accountability to Policy-Influencing Positions within the Federal Workforce.” A similar attempt to create a new “Schedule F” was advanced toward the end of President Trump’s first term.

At its core, the proposed rule is intended to remove civil service protections from career staff employed in roles that are “confidential, policy-determining, policy-making, or policy-advocating character.” The Office of Personnel Management (OPM) released a memorandum subsequent to the EO that provided implementation guidance to federal agencies with considerations of the types of roles that would be considered “policy-influencing.”

One category of roles that the OPM encouraged agencies to consider classifying as Schedule Policy/Career is “substantive participation and discretionary authority in agency grantmaking, such as the substantive exercise of discretion in the drafting of funding opportunity announcements, evaluation of grant applications, or recommending or selecting grant recipients.”

The comments from AERA Executive Director Felice J. Levine first address this potential inclusion of federal agency staff involved in research grants at science agencies. The comments call for the exemption of federal research program officers from Schedule Policy/Career designation due to the non-partisan nature of their work and the implementation of merit and peer review procedures that guide panel reviews and final decisions by agencies on grant awards.

“Program officers are involved in the grantmaking process, but they are implementing agency-wide policies and not engaged in policy-making themselves,” Levine wrote. “We are also concerned that placement of federal research agency staff under this designation would lead to the loss of nonpartisan subject matter expertise that is necessary to ensure that taxpayer funds are supporting research that reflects timely and relevant issues of national interest across all areas of science.”

In addition to program officers, Levine recommended that federal statistical agency staff be exempt from Schedule Policy/Career designation, given the roles that statistical agencies have to be impartial, including independence from undue political influence, and to ensure trust in the data they collect and produce.

“We are deeply concerned with the prospect of federal statistical agency staff being designated as ‘Schedule Policy/Career’ given the essential role that these agencies have in producing nationally representative statistics that are objective, reliable, and valid,” Levine wrote. “In addition, we are concerned that any designation of federal statistical agency staff as ‘Schedule Policy/Career’ may lead to gaps in protecting confidentiality of statistical information with the lifting of civil service protections.”

Publicly submitted comments will inform the final rule, though the timing for when it will be released is unclear.