Comment from Anonymous

Re: Comment Opposing Proposed Rule, “Elimination of Time-in-Grade” Docket ID: OPM-2026-0067 To Whom It May Concern: I respectfully submit this comment in opposition to the Office of Personnel Management’s proposed rule to eliminate the time-in-grade requirement for advancement to competitive service positions in the General Schedule. While I support efforts to modernize federal hiring and advancement, strengthen merit-based selections, and provide agencies with tools to retain high-performing employees, I do not believe eliminating time-in-grade is the appropriate solution. The 52-week time-in-grade requirement serves an important role in promoting fairness, consistency, workforce readiness, and public confidence in the federal merit system. Time-in-grade is not merely an arbitrary waiting period. It provides a reasonable and consistent minimum period for employees to demonstrate sustained performance, develop technical competence, understand agency operations, and show readiness for higher-level duties. Removing this requirement could result in uneven promotion practices across agencies and offices, particularly where internal controls, performance management practices, and supervisory documentation vary significantly. The proposed rule places substantial reliance on qualification standards, merit promotion procedures, and managerial judgment. However, in practice, these safeguards may not always be applied consistently. Without a governmentwide time-in-grade requirement, agencies could face increased pressure to accelerate promotions based on short-term performance, internal preference, recruitment or retention pressures, or subjective assessments of readiness. This could increase the risk of favoritism, inequity, inconsistent advancement opportunities, and employee morale concerns. The time-in-grade requirement also supports workforce development. Federal work often requires employees to understand complex laws, regulations, systems, policies, internal controls, stakeholder relationships, and mission-specific responsibilities. A minimum period in grade allows employees to gain practical experience and demonstrate that they can perform at their current level before assuming greater responsibility. Eliminating this structure may unintentionally promote employees before they have had sufficient opportunity to develop the judgment, technical depth, and accountability expected at the next grade level. This concern is especially important for mission-critical, technical, financial, regulatory, administrative, and supervisory positions. In these areas, premature promotion decisions can have operational consequences, including increased errors, weakened internal controls, poor customer service, inconsistent program execution, and additional burden on supervisors and experienced staff who must correct or rework incomplete products. The current time-in-grade framework also provides employees with a clear, transparent, and predictable standard. Employees understand the minimum eligibility timeline and can plan their development accordingly. Removing this requirement could create confusion and perceptions of unfairness if some employees are promoted quickly while others are required to wait based on differing local policies, supervisory discretion, or office-level practices. If OPM determines that changes to time-in-grade are necessary, I recommend a more measured approach rather than full elimination. OPM could consider limited exceptions for documented mission-critical needs, hard-to-fill positions, exceptional performance, or structured career development programs. Any exception should require written justification, evidence of demonstrated readiness, confirmation that higher-level duties exist, budgetary review, and appropriate HR oversight. This would provide agencies flexibility while preserving the fairness and consistency that the current rule supports. At a minimum, 1. A requirement for agencies to establish written internal promotion criteria before using any flexibility created by the rule; 2. Documentation showing that the employee has demonstrated sustained performance and readiness for the next grade; 3. Review by human resources and, where appropriate, classification officials to confirm the position and duties support the promotion; 5. Reporting or audit mechanisms to monitor accelerated promotions by grade, series, office, demographic category, and agency; 6. Clear guidance to prevent accelerated promotions from being used as a substitute for proper position management, recruitment planning, or retention strategy. For these reasons, I respectfully urge OPM to withdraw the proposed rule or revise it to preserve a governmentwide minimum time-in-grade standard while allowing narrowly tailored, well-controlled exceptions where justified. Thank you for the opportunity to comment. Respectfully submitted,