Implementing Schedule Policy/Career in the Excepted Service

6/3/2026
Executive Orders

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Action Summary

  • Purpose and Rationale: Establishes Schedule Policy/Career positions in the excepted service for senior policy-influencing roles to enhance accountability and ensure removability for misconduct or poor performance, thereby protecting democratic self-government.
  • Accountability and Merit: Transfers senior policy-influencing positions to the new schedule to improve accountability; emphasizes merit-based hiring and recognition of outstanding work.
  • Amendments to Civil Service Rules:
    • Civil Service Rule I: Adjusts competitive status retention for employees transitioning to Schedule Policy/Career.
    • Civil Service Rule III: Provides provisions for employees converted from Pathways Program positions.
    • Civil Service Rule VI: Revises publication of schedules and merit-based hiring procedures; outlines the process for attaining competitive status.
    • Civil Service Rule XI: Specifies that appointments in Schedule Policy/Career are not subject to trial periods.
    • Other Amendments: Redefines “Qualifying appointment” and adjusts provisions related to unacceptable performance or misconduct.
  • Modifications to Previous Executive Orders:
    • Executive Order 13957 & 14171: Removes certain paragraphs and revises procedures for agency heads petitioning for positions to be placed in Schedule Policy/Career.
    • Executive Order 13562: Adds provisions to include Schedule Policy/Career positions in recruiting and hiring students and recent graduates.
  • Performance Awards and Incentives: Directs agency heads to set aside bonus pools for recognizing exceptional Schedule Policy/Career employees; instructs OPM to develop a Presidential award program.
  • Schedule Determination and Transition:
    • Positions identified as having a confidential, policy-determining, policy-making, or policy-advocating character are placed into Schedule Policy/Career.
    • Agency heads must notify affected employees and update records within 7 days.
  • General Provisions: Clarifies that the order does not impair departmental authority, is subject to appropriations, does not create enforceable rights, and provides for severability and cost responsibilities.

Risks & Considerations

  • The implementation of the Executive Order to create a Schedule Policy/Career in the excepted service may lead to instability in federal hiring practices, which could influence the availability of qualified candidates for educational roles, impacting Vanderbilt’s recruitment strategies.
  • With increased accountability measures, there is a risk that some positions may become less attractive to potential employees due to the fear of dismissal for performance issues. This could lead to a talent drain from federal positions, affecting partnerships and collaborations between Vanderbilt and federal agencies.
  • The emphasis on merit-based hiring may lead to compliance challenges for universities that rely on federal funding and partnerships. Vanderbilt may need to adapt its hiring and collaborative practices to align with these new federal standards.
  • Changes in federal employment policies may also impact the diversity of the workforce at federal agencies, which could have downstream effects on the diversity of students and professionals interacting with or coming from Vanderbilt.

Impacted Programs

  • Vanderbilt’s Peabody College of Education and Human Development may need to re-evaluate its training programs for future educators to ensure alignment with the merit-based hiring practices mandated by the Executive Order.
  • The Office of Federal Relations at Vanderbilt will likely need to engage more actively with federal agencies to understand and navigate the implications of these changes on funding and partnerships.
  • Vanderbilt’s Career Services might need to provide additional support to students and alumni seeking positions in federal agencies that are affected by these policy changes, ensuring they remain competitive in a potentially shifting job market.

Financial Impact

  • The reallocation of positions into the Schedule Policy/Career may impact the funding landscape for programs at Vanderbilt that rely on federal partnerships or grants, leading to potential financial instability.
  • Vanderbilt may face increased costs associated with adapting its compliance and hiring practices to align with the new regulations, potentially diverting funds from other critical areas.
  • Opportunities for grants related to workforce development and educational reform may arise, but these will require careful navigation of the new federal landscape to ensure eligibility.

Relevance Score: 3 (The order presents moderate risks involving compliance and potential impacts on workforce diversity and educational partnerships.)

Key Actions

  • The Office of Human Resources should review current personnel policies and practices to align with the new Schedule Policy/Career framework established by the Executive Order. This includes ensuring that merit-based hiring and recognition processes are implemented for policy-influencing positions.
  • The Vanderbilt Legal Department should assess the potential legal implications of the changes to the Civil Service Rules and prepare to adapt university policies accordingly. This will ensure compliance with federal regulations and mitigate any risks related to employee management and accountability.
  • The Office of Federal Relations should engage with federal agencies to understand the specifics of how these changes may affect federal funding and grant opportunities for Vanderbilt. By staying informed, the university can better position itself to adapt to any shifts in federal priorities.
  • The Department of Political Science should conduct an analysis on the potential impacts of this order on public policy and governance. This research can provide valuable insights that may influence Vanderbilt’s strategic planning and advocacy efforts.
  • The University’s Leadership should consider establishing a task force to monitor the implementation of this order and its effects on federal workforce dynamics. This task force can help identify emerging opportunities or challenges that may arise from these policy changes.

Opportunities

  • The Executive Order presents an opportunity for Vanderbilt’s Strategic Initiatives Office to enhance its role in promoting accountability and transparency in government. The university can leverage its research capabilities to contribute to discussions on effective governance and public administration.
  • The focus on merit and accountability in federal positions aligns with Vanderbilt’s commitment to excellence. This can be an opportunity for Vanderbilt to collaborate with federal agencies on programs aimed at improving public service delivery and employee performance.
  • The changes to performance awards for Schedule Policy/Career employees could lead to partnerships with federal agencies in developing best practices for employee recognition and motivation, enhancing Vanderbilt’s influence in federal workforce management.

Relevance Score: 3 (Some adjustments are needed to processes or procedures to comply with the new federal guidelines and enhance accountability.)

Average Relevance Score: 4

Timeline for Implementation

  • Within 7 days – Agency heads must notify affected employees of their placement in Schedule Policy/Career and update records (Section 5(c)).
  • Within 60 days – The Director of the Office of Personnel Management must prepare and issue revisions to update or remove obsolete Civil Service Rules provisions (Section 2(g)).

The shortest timeline is 7 days, meaning directives require an urgent response.

Relevance Score: 5

Impacted Government Organizations

  • Office of Personnel Management (OPM): OPM is explicitly tasked with issuing rule revisions and leading the implementation of Schedule Policy/Career appointments and performance award programs.
  • Office of Management and Budget (OMB): OMB’s functions in budgetary, administrative, and legislative proposals are acknowledged, ensuring its oversight is not impaired by these changes.
  • Executive Departments and Agencies: All agencies with policy-influencing positions are directed to transfer eligible positions into Schedule Policy/Career, affecting a wide range of federal organizations across the executive branch.

Relevance Score: 5 (The directive applies broadly across the federal executive branch, impacting numerous agencies.)

Responsible Officials

  • Director of the Office of Personnel Management – Tasked with preparing and issuing revised Civil Service Rules, publishing required lists, and initiating rulemaking to create a Presidential award program for Schedule Policy/Career employees.
  • Agency Heads – Responsible for implementing the transfer of designated positions into Schedule Policy/Career, notifying affected employees, conforming agency records to reflect these changes, and establishing separate bonus pools for performance awards.

Relevance Score: 4 (Directives affect agency heads and a key federal official responsible for wide-ranging human resource and merit system modifications.)

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