June 4, 2025
Comments in response to Docket ID: OPM-2025-0004
Transmitted electronically via www.regulations.gov
The American Physiological Society (APS) appreciates the opportunity to comment on the Notice of Proposed Rulemaking (NPRM) entitled Improving Performance, Accountability and Responsiveness in the Civil Service issued by the Office of Personnel Management (OPM) on April 23, 2025. APS represents over 8,300 scientists and educators working to advance our understanding of how the body functions. Their discoveries, which rely on support from federal grants, are vital for advancing new and better treatments for chronic disease and other health challenges.
U.S. global leadership in science depends on the support of knowledgeable and skilled staff at federal research agencies, and APS regards the proposed changes to the federal workforce with concern. Scientific agencies are facing funding uncertainties and staffing shortages, resulting in plummeting morale among federal workers. Over time, this will limit the ability of agencies to recruit and retain knowledgeable and skilled staff. According to a recent OPM statement the federal government struggles to recruit and retain top STEM talent. The proposed changes risk exacerbating staff shortages and driving out experienced civil servants from positions that often demand extensive knowledge of both institutional functions and highly technical subject areas.
Additionally, removing employment protections from a swath of the federal workforce would be damaging to stakeholders who benefit from the functions of federal agencies. The procedures governing the removal and suspension of civil servants protect them from politically motivated or retributive actions, enabling them to confidently carry out their duties to their agency’s mission in an unbiased and efficient manner. Agency staff who determine or review policy should be primarily guided by evidence, relevant law and agency policies, and the needs of stakeholders, not partisan ideology or political expedience.
Furthermore, this proposal risks adverse consequences propagating across the federal workforce. The proposal offers an overly broad definition of what may constitute a “policy-influencing position,” and it grants the President the ability to determine which positions are reclassified as “Schedule Policy/Career”. This invites the use of reclassification as retribution or penalization against any civil servants who do not display sufficient loyalty to a specific presidential administration’s political agenda. The proposed changes effectively place all federal staff under threat of removing employment protections at the whim of an elected official, likely leading to massive staff turnover and required staff retraining with each newly elected president.
The U.S. owes its global leadership in science to the strength of federal agencies and to the skill and expertise of the federal workforce. Research investments and scientists supporting multi-year projects leading to development of new medicines and therapies rely on the stability, efficient administrative actions, and mission-focused nature of agencies such as the National Institutes of Health (NIH) and the National Science Foundation (NSF). APS strongly urges OPM to reconsider the proposed changes to the federal workforce.
Sincerely,
Dennis Brown, PhD, FAPS
Chief Science Advisor
Comments in response to Docket ID: OPM-2025-0004
Transmitted electronically via www.regulations.gov
The American Physiological Society (APS) appreciates the opportunity to comment on the Notice of Proposed Rulemaking (NPRM) entitled Improving Performance, Accountability and Responsiveness in the Civil Service issued by the Office of Personnel Management (OPM) on April 23, 2025. APS represents over 8,300 scientists and educators working to advance our understanding of how the body functions. Their discoveries, which rely on support from federal grants, are vital for advancing new and better treatments for chronic disease and other health challenges.
U.S. global leadership in science depends on the support of knowledgeable and skilled staff at federal research agencies, and APS regards the proposed changes to the federal workforce with concern. Scientific agencies are facing funding uncertainties and staffing shortages, resulting in plummeting morale among federal workers. Over time, this will limit the ability of agencies to recruit and retain knowledgeable and skilled staff. According to a recent OPM statement the federal government struggles to recruit and retain top STEM talent. The proposed changes risk exacerbating staff shortages and driving out experienced civil servants from positions that often demand extensive knowledge of both institutional functions and highly technical subject areas.
Additionally, removing employment protections from a swath of the federal workforce would be damaging to stakeholders who benefit from the functions of federal agencies. The procedures governing the removal and suspension of civil servants protect them from politically motivated or retributive actions, enabling them to confidently carry out their duties to their agency’s mission in an unbiased and efficient manner. Agency staff who determine or review policy should be primarily guided by evidence, relevant law and agency policies, and the needs of stakeholders, not partisan ideology or political expedience.
Furthermore, this proposal risks adverse consequences propagating across the federal workforce. The proposal offers an overly broad definition of what may constitute a “policy-influencing position,” and it grants the President the ability to determine which positions are reclassified as “Schedule Policy/Career”. This invites the use of reclassification as retribution or penalization against any civil servants who do not display sufficient loyalty to a specific presidential administration’s political agenda. The proposed changes effectively place all federal staff under threat of removing employment protections at the whim of an elected official, likely leading to massive staff turnover and required staff retraining with each newly elected president.
The U.S. owes its global leadership in science to the strength of federal agencies and to the skill and expertise of the federal workforce. Research investments and scientists supporting multi-year projects leading to development of new medicines and therapies rely on the stability, efficient administrative actions, and mission-focused nature of agencies such as the National Institutes of Health (NIH) and the National Science Foundation (NSF). APS strongly urges OPM to reconsider the proposed changes to the federal workforce.
Sincerely,
Dennis Brown, PhD, FAPS
Chief Science Advisor
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