June 2025, the Office of Personnel Management (OPM) proposed big changes to suitability policies and procedures. Suitability has been a metric for evaluating prospective federal employees and contractors, for the most part. Soon, however, suitability standards will apply to current, post-probationary employees too. This is a revolutionary rolling back of the clock, to a time when Federal employment was vastly different than either Gen X, Millennials, or Gen Z would recognize. The newest generations, Alpha and Beta, will comprise the new workforce cast and burnished by a revived OPM.
What Is the Role of OPM?
When Congress abolished the old United States Civil Service Commission in 1978 and replaced it with the Federal Merit System, the rump Commission duties that were not given to the Merit Systems Protection Board (and the Office of Special Counsel) and the Federal Labor Relations Authority were packaged together and given to the newly created OPM. OPM did little "Personnel Management" over the next century. It delegated out its functions and acted as an oversight/policy-making office for the President. It was always a management-biased institution, and hostile to Federal missions such as whistleblowing. For instance, it is OPM which establishes the standards and processes used to evaluate the suitability of the federal workforce (or 'fitness' in the case of industrial/contractor personnel). The Suitability and Credentialing Executive Agent (SuitEA) is the arm of OPM charged with oversight of suitability standards, evaluations, and actions.
What is Suitability for Federal Employees?
Suitability is an administrative determination by the federal government that an individual is suited to federal employment. It is a character and conduct evaluation, not a technical assessment of an individual's ability to perform the actual tasks of a job. The aim is to screen out those employees who might compromise the "integrity or efficiency of the Federal service" (5 CFR Part 731).
Suitability determines "public trust," and is comparable to eligibility for access to classified information in some ways. But suitability is the less rigorous middle ground between a security clearance and credentialling, the troika constituting access to Federal facilities and the public workplace. Title 5 Part 731 Subpart B outlines the factors considered in suitability determinations.
Key Aspects of OPM Suitability Rule Change
There are three main changes to Federal suitability rules that federal employees, applicants, and contractors need to be aware of.
1. Expansion to Current Employees for Post-Appointment Conduct
U.S.C. Chapter 75 outlines disciplinary procedures for current Title 5 employees. As of now, suitability has chiefly been a stage in the federal hiring and screening processes, not a matter for employee discipline. OPM seeks to change this in the name of "efficiency, rigor and timeliness," and to hold current employees as accountable as candidates. Such a change would place the process of firing someone more in line with the process of electing not to hire an individual in the first place.
2. Additional Suitability Criteria
President Trump's Executive Order 13467 is best known for instructing agencies to prepare to implement largescale reductions in force (RIFs). But this order also directed OPM to expand 5 C.F.R. 731.202(b) with four additional suitability criteria. Once adopted, the following would be cause for suitability action, including removal of post-probationary employees:
- Failing to meet your legal obligations, like filing and paying your taxes on time.
- No longer meeting basic employment requirements, like U.S. citizenship.
- Refusing to agree to and maintain non-disclosure agreements (NDAs).
- Stealing, misusing, losing, or otherwise neglecting government resources or equipment.
There is no surprise here to the seasoned holder of a security clearance: these proposals look much like the security concerns promulgated through SEAD-4 at Guidelines C, E, F, J, and K/M. This confluence of suitability and security has been underway since 2008, and has been supported by the OPM directors for Presidents Obama, Trump, and Biden. There is a desire to drop the number of security clearances issued post-9/11. Rather than expand the number of people granted clearances, the other alternative is to place suitability on steroids. What this ends is that comfort zone many applicants found in holding a public trust position. As it was less intrusive than a security clearance review, the public trust/suitability review was often sought by those with something to keep discreet. That safe haven will soon be much smaller.
3. Streamlined Removal Process
Title 5 employees who have completed their probationary periods have been accustomed to a good deal of due process: in theory, if not practice. U.S.C. Chapter 75 grants federal employees facing removal or other adverse actions the following rights:
- 30 days' written notice with reasons for the proposed removal,
- the opportunity to respond to those reasons,
- legal representation, and
- appeal before the Merit Systems Protection Board (MSPB).
Suitability cases, by contrast, run according to a far shorter timeline. OPM's proposed changes would reduce the time federal employees have between notice and removal in suitability cases to as little as five days. It can take 30 to 60 days to gather the evidence necessary to show additional considerations proving you are suitable, once challenged.
Only preparation in anticipation of a management strike at you will permit you to optimize your response.
Why OPM's Suitability Changes Matter for Federal Employees
After these changes go into effect, current employees will find themselves under continuing suitability review and evaluated with additional criteria. What was previously not a disqualifying factor could trigger removal in future—and an "efficient" 5-day removal at that. Federal employment will effectively be 'at the will' of supervisors and managers.
Bear in mind: these suitability changes are not taking place in a vacuum. RIFs are a common enough topic of conversation. Less talked about, however, is Trusted Workforce 2.0 and the implementation of Continuous Vetting (CV) for more and more federal employees. The ultimate goal is to enroll all federal employees and contractor personnel under CV.
Suitability Changes in Context
Let us take a step back and consider the larger field at play.
We have Suitability: a determination standard by which an individual can be disqualified from joining the federal workforce.
OPM's proposed changes will expand the ambit of suitability. Rather than a screening mechanism in the hiring process, suitability will become a rolling qualification that federal employees must maintain in order to remain in the federal workforce. A lapse in suitability would then be grounds for the removal of federal employees even after clearing their probationary period, but with the "efficiency" with which applicants are denied entry.
Add to this the deployment of a more arduous set of standards used in assessing an individual's suitability for federal employment.
Finally, factor into this revival of the old pro-management Civil Service principles the expansion of Continuous Vetting: an ongoing, automated evaluation process making it far more likely security concerns will be detected. All that is needed now is the application of artificial intelligence (AI) to synthesize the collection of security and suitability data together, and a shift from periodic reevaluations to continuous vetting will further abbreviate the timeline in which employees might mitigate derogatory information or defend themselves against unfavorable suitability decisions. Employees' opportunity to appeal suitability determinations to MSPB would also be limited.
What Does It All Mean?
In short, the result of OPM's proposed changes: federal employees can be removed without nearly the same degree of warning or due process to which they have been accustomed. If you are a federal employee and wish to remain so, it is time to become far more proactive about protecting your position.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
