Comment from Adam Lewis

Support of Proposed Rule: Elimination of Time-in-Grade (Docket ID: OPM-2026-0067 / RIN: 3206-AP05) To the Office of Personnel Management: I am writing to express my strong support for the Office of Personnel Management’s (OPM) proposed rule to eliminate the Time-in-Grade (TIG) restriction for General Schedule (GS) competitive service positions. As a dedicated civil servant, I believe this modernization effort is long overdue and essential for building an agile, highly capable Federal workforce. I support the finalization of this rule for the following key reasons: 1. Shifts Focus to Merit and Capability Advancement in the Federal government should be driven by an employee’s demonstrated ability to perform the duties of the next grade level, not by an arbitrary calendar requirement. By removing the 52-week waiting period, OPM is aligning the civil service with modern, skills-based hiring principles. This empowers managers to advance talent based on readiness and merit. 2. Enhances Retention and Competitiveness In today’s highly competitive labor market, the Federal government often loses top talent to the private sector because high-performing employees are artificially stalled by TIG restrictions. Eliminating this barrier will significantly improve retention by allowing agencies to reward and promote exceptional employees as soon as they meet all rigorous qualification standards. 3. Preserves Rigorous Qualification Standards Removing the 52-week wait does not equate to lowering the bar for Federal employment. Candidates will still be required to fully meet OPM’s occupational qualification standards, specialized experience requirements, and job-related performance criteria. This rule simply removes an outdated administrative hurdle, ensuring that promotions remain strictly merit-based. 4. Establishes Equity Across Pay Systems The current TIG restriction creates unnecessary disparities within the Federal workforce. Because TIG does not apply to Wage Grade, excepted service, or pay-banded employees, GS competitive service employees are uniquely disadvantaged. This rule standardizes advancement criteria across the government, fostering a more equitable environment for all civil servants. Conclusion The TIG requirement, originally born out of 1950s wartime constraints, no longer serves the operational needs of a 21st-century government. I strongly urge OPM to finalize this rule without delay, granting agencies the flexibility they need to recruit, retain, and promote the best possible workforce to serve the American public. Thank you for your time and for prioritizing the modernization of Federal personnel policies. ADAM L. LEWIS, Civ, USAF AFGSC/A3OR Chief, Defense Readiness Reporting Branch Comm: 318-456-1203 Email: adam.lewis.21@us.af.mil