Schedule F’s Ask

The views expressed are those of the author and do not necessarily reflect the views of ASPA as an organization.

By Anna Marie Schuh
June 2, 2025

In this column, I am sharing below the public comment I sent to the Office of Personnel Management about the proposed Schedule F rule, “Improving Performance, Accountability and Responsiveness in the Civil Service.” This comment describes the consequences of Schedule F.

“Schedule F does not improve performance, accountability or responsiveness. Also, the schedule violates the three primary citizen concerns that various civil service laws were created to address: the provision of equal services to all, equal access to government work and quality service provided by capable individuals. More specifically, the schedule does not address two of these concerns, and while it nominally addresses the third (quality service) concern through its title, operationally it cannot maintain the type of performance, accountability or responsiveness expected by citizens.

“I spent thirty-six years as a federal employee. Twenty-four of those years focused on oversight of civil service law in federal agencies. During the last four years of my federal employment, I managed the Office of Personnel Management’s national oversight program. In addition, my Ph.D. dissertation contained an intensive study of civil service change and the reasons for that change. This knowledge, gained both academically and experientially, informs my concerns about Schedule F.

“Regarding the commitments in the rule’s name, Schedule F does not improve performance, accountability or responsiveness to citizens. Instead, it provides opportunities for nepotism, partisanship and favoritism in government employment—activities which are antithetical to performance, accountability and responsiveness to citizen expectations. This is because at will employment allows management to appoint and remove an employee for any reason whether it is or is not related to the performance of the individual. In addition, at will employment allows the retention of poor performers and those unresponsive to citizen concerns when management wants to retain those persons for non-merit reasons such as nepotism or partisanship. In short, at will employment retards accountability and responsiveness to citizens and is unrelated to improved performance.

“Since at will employment is a feature of many Schedule C positions and historically appointments of unqualified individuals for non-merit reasons such as partisanship has occurred in Schedule C appointments at a greater or lesser rate depending on the presidential administration, it is reasonable to assume that the same will happen with Schedule F appointments. However, because the number of Schedule F appointments is significantly higher, it is also reasonable to expect that the problems of nepotism, partisanship and favoritism in the federal government will be significantly greater under Schedule F.

“In addition to the fact that Schedule F cannot achieve the goals in its title and in fact increases the concerns about performance, accountability and responsiveness, it undermines primary citizen expectations of the civil service. These expectations center on open access to government jobs and government services. All Americans assume that they will receive consideration for a government job based only on how their qualifications meet the job requirements. The few exceptions to that expectation have been legislated assistance for specific groups such as veterans or the disabled. Schedule F is not open because it makes government employment only available to those who have a way to connect with the current government leadership, e.g., a reference from someone in government, a family member or a partisan associate. Schedule F violates the citizen expectation of access to government employment.

“Schedule F also violates the citizen expectation of equal service. In fact, the business concern about service based on illegal payments to government officials was a primary reason for the original civil service movement in the late 1800s. Under Schedule F, agency officials can provide, delay or not provide an entitled service to any citizen without having to explain why because there is no consequence if agency leadership supports the action. This results in service provision based on favoritism, partisanship, nepotism or any other reason unrelated to legal eligibility. Potentially affected service provision also includes how the citizen is treated during government interactions. For example, the Internal Revenue Service (IRS) has the discretion to determine whether to work out a payment plan or take the person to court over a tax return issue. Under the current merit system, the auditor must follow legal guidelines in making that choice. Under Schedule F, the at will employee will follow the direction of IRS management, even if that direction is unfair or illegal, because the manager has the ability to fire the employee without cause. The result is that tax matters which in the past were resolved in a consistent transparent manner may be resolved from an opaque political perspective in the future.

“In short, Schedule F does not meet the goals in its rule name. In addition, it violates citizen expectations about how government employment operates. Consequently, the rule should not be implemented.”

Federal employees take an oath to support the Constitution, not an individual. President John F. Kennedy said “ask not what your country can do for you—ask what you can do for your country.” Schedule F sets up a system where the question becomes “ask what you can do for those who can fire you.”

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Author: Anna Marie Schuh is Associate Professor and MPA Program Director at Roosevelt University, Chicago where she teaches political science and public administration. She retired from federal service after 36 years. Her last assignment involved management of the Office of Personnel Management national oversight program. She is a three-time past president of the Chicago ASPA Chapter. Email: [email protected] BlueSky: profschuh.bsky.social

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