Comment from Kandace McGlynn

I am writing in strong support of OPM's proposed rule to eliminate the Time-in-Grade (TIG) requirement. Eliminating TIG is an excellent step forward. It will open up talent pools, particularly for employees whose education and experience have already prepared them for higher-level work, but who are currently blocked from moving up without climbing each rung of the ladder regardless of demonstrated readiness. As it stands, agencies lose out on qualified talent simply because employees are forced to wait out an arbitrary calendar period rather than being promoted based on their actual ability to perform the job. This drives skilled employees to leave government service altogether for private-sector opportunities where advancement is tied to merit and performance rather than tenure. A few additional benefits worth highlighting: 1. Reduces administrative burden on agencies. Removing TIG-related tracking, approvals, and reviews frees up HR and supervisory time currently spent managing an arbitrary waiting period rather than evaluating actual qualifications. 2. Aligns federal promotion practices with the private sector, where advancement is already based on demonstrated skill and performance. This makes federal careers more competitive for professionals considering public service. 3. Corrects an existing inconsistency within government itself. TIG currently applies to General Schedule employees but not to Federal Wage System or excepted service employees, creating an uneven system where similarly qualified employees are treated differently based solely on their pay system. 4. Supports retention of high performers, particularly in agencies facing critical staffing shortages, where losing capable employees to slower internal advancement is a real and avoidable cost. 5. Does not weaken merit protections. Employees would still be required to meet OPM qualification standards and any additional agency-specific, job-related requirements — this rule removes an arbitrary waiting period, not the standards themselves. For these reasons, I urge OPM to finalize this rule. It is a practical, merit-based reform that benefits both agencies and the employees who serve them. Thank you for your consideration. Respectfully, Dr. Kandace McGlynn