Schedule F Is Back: What Federal Employees Need to Know Before March 8
OPM finalized Schedule Policy/Career, reclassifying ~50K feds as at-will. What you lose, what you keep, and what to do before March 8, 2026.
Schedule F Is Back: What Federal Employees Need to Know Before March 8
Last Updated: February 11, 2026 Reading Time: 14 min
On February 5, OPM published the final rule for Schedule Policy/Career. On March 8, it takes effect. Roughly 50,000 federal employees in "policy-influencing" positions will become at-will workers who can be fired without the protections that have defined federal civil service since 1978.
If you draft regulations, manage programs with discretionary authority, supervise attorneys, or publicly advocate for your agency's policies, your job just got less secure. You have 25 days to prepare.
Key Takeaways
- OPM's Schedule Policy/Career rule takes effect March 8, 2026, reclassifying ~50,000 positions as at-will
- Reclassified employees lose MSPB appeal rights, 30-day termination notice, student loan repayment, and retention incentives
- Reclassified employees keep FERS retirement, FEHB, TSP, severance pay eligibility, and EEOC complaint rights
- Separately, OPM is proposing to move RIF appeals from MSPB to itself, creating what critics call a conflict of interest
- No court has blocked the rule yet, though AFGE has promised "imminent" legal challenges
- No court has issued an injunction. Plan as if this takes effect on schedule.
What Schedule Policy/Career Actually Changes
The original Schedule F executive order came and went in 2020 without reclassifying a single position. Biden revoked it on day two. This time is different. The administration completed the full rulemaking process: proposed rule, 40,500+ public comments (94% opposed), and a final rule with a 30-day effective date.
The target: career federal employees whose jobs involve shaping policy rather than executing it. OPM's criteria cast a wide net.
Positions at Risk
Agencies must review their workforces and flag positions where duties include:
- Drafting or developing regulations, guidance, or executive orders
- Working in a component that primarily focuses on policy
- Supervising attorneys
- Exercising substantial discretion in how the agency carries out its statutory functions
- Advocating agency policies to Congress, other governments, or budget officials
- Publicly promoting agency or administration policies through media or social media
Line employees who implement policy (a Border Patrol agent enforcing immigration law, for example) are excluded. The rule targets the layer above: the people who write the rules, not the people who follow them.
One change from 2020: President Trump, not the OPM Director, makes the final call on which positions get reclassified.
What You Lose vs. What You Keep
This is the part that matters most. Not everything goes away.
Gone
| Protection | What It Means |
|---|---|
| MSPB appeal rights | No independent review if you're fired, suspended, or demoted |
| 30-day advance notice | Agency can terminate without the standard notice and response period |
| Office of Special Counsel access | Whistleblower complaints go to your agency's general counsel instead |
| Student loan repayment | Ineligible for up to $10,000/year federal loan repayment |
| Recruitment/retention/relocation bonuses | Ineligible for incentive pay (up to 25% for retention) |
| Presidential Rank Awards | Ineligible for SES-level recognition |
Stays
| Protection | What It Means |
|---|---|
| FERS pension, TSP, FEHB | Retirement and health benefits are unchanged |
| Severance pay | You are still eligible for severance if involuntarily separated |
| EEOC complaint rights | Discrimination complaints still go through EEO process |
| Performance awards | Cash performance bonuses continue |
| Merit-based hiring | Positions are still filled competitively with veterans' preference |
The severance piece is worth emphasizing. If you're reclassified and later fired, you still collect severance. Use the Severance Pay Calculator to see what that looks like for your situation.
The Whistleblower Problem
The rule says whistleblower protections are "retained." That's technically true. What changes is who handles complaints.
Today, federal whistleblowers file with the independent Office of Special Counsel. Under Schedule P/C, those complaints go to your employing agency's general counsel, typically a political appointee. The same organization that might be retaliating against you is now the one investigating your complaint.
AFGE, the Partnership for Public Service, and the National Law Review have all flagged this as a serious conflict of interest. The protection exists on paper. Whether it means anything in practice is a different question.
The MSPB Power Shift (Three Proposals at Once)
While Schedule Policy/Career gets the headlines, OPM is simultaneously pushing three proposals to move employee appeals away from the independent Merit Systems Protection Board:
| Appeal Type | Moving From | Moving To | Comment Deadline |
|---|---|---|---|
| RIF appeals | MSPB | OPM's MSAC office | March 12, 2026 |
| Probationary firing appeals | MSPB | OPM's MSAC office | Closed (Jan. 29) |
| Suitability appeals | MSPB | OPM | TBD |
Here's why this matters beyond Schedule P/C: even employees who aren't reclassified could lose independent appeal rights. If you get RIF'd next year and OPM has already taken over RIF appeals, your case goes to the same agency that may have directed the RIF in the first place.
Partnership for Public Service Vice President Jenny Mattingley questioned whether OPM's MSAC office, which is "not a large office with a lot of resources, particularly judicial resources," can do this work independently. Federal employment attorney Kevin Owen expects the process to function as a "rubber stamp."
The RIF appeal comment period closes March 12, 2026. Comments can be submitted at Regulations.gov.
The Legal Landscape
Four lawsuits challenging the underlying executive order (EO 14171) are pending in federal courts:
| Case | Court | Status |
|---|---|---|
| NTEU v. Trump | D.D.C. | Stayed |
| PEER v. Trump | D. Maryland | Stayed |
| GAP v. OPM | D.D.C. | Stayed |
| AFGE v. Trump | D.D.C. | Voluntarily dismissed, joined related litigation |
AFGE has promised "imminent" new challenges to the final rule specifically. Protect Democracy and Democracy Forward argue the rule violates the Civil Service Reform Act of 1978. The Saving the Civil Service Act (H.R. 492 / S.134) would block Schedule P/C legislatively, though passage is unlikely in the current Congress.
No court has issued an injunction. That could change before March 8, but don't count on it.
What the 2020 Version Got Wrong (And Why This Time Is Different)
The first Schedule F attempt ran out of clock. Trump signed EO 13957 on October 21, 2020, gave agencies until January 19, 2021 to submit position lists, and Biden revoked it two days after inauguration. No positions were actually reclassified.
This round fixed those problems:
- Full notice-and-comment rulemaking (proposed rule, comment period, final rule)
- Months of agency preparation before the rule took effect
- Final approval authority moved to the President, making it harder to challenge as overreach by a subordinate official
- Biden's protective rule (ensuring excepted service employees kept competitive service rights) was rescinded
The machinery is in place. The question is whether courts stop it.
What to Do Before March 8
Figure Out If You're Affected
Review your position description for policy-influencing language. If your PD mentions drafting regulations, developing policy, exercising broad discretion, or advocating agency positions, you may be on the list. Ask your HR office directly. Request a copy of any agency review list if one exists.
Document Everything Now
Save copies of your SF-50 (current and historical), position description, performance evaluations, and awards. Keep records off government systems. If your position gets reclassified and you're later terminated, you'll want a complete paper trail.
Talk to Your Union
AFGE, NTEU, and other unions are actively litigating. Even if your bargaining unit was recently terminated, unions still offer legal resources. Ask about collective legal challenges you can join.
Run Your Financial Numbers
Know your numbers before you need them.
Severance: Schedule P/C employees keep severance eligibility. Use the Severance Pay Calculator to estimate what you'd receive if involuntarily separated. For a GS-13 with 15 years of service, severance can exceed $30,000.
Retirement: Use the FERS Retirement Calculator to see where you stand. If you're eligible or near-eligible for retirement, compare the numbers for leaving now versus risking involuntary separation later. Some agencies are offering VERA/VSIP (early retirement with buyout), which may be worth considering.
TSP: Don't make panic withdrawals. Understand your TSP options and make sure beneficiary designations are current.
Submit Comments on the Open RIF Proposal
The proposed rule to transfer RIF appeals from MSPB to OPM has a comment deadline of March 12, 2026. Submit at Regulations.gov.
Prepare for a Job Search (Just in Case)
Update your resume and LinkedIn profile. The RIF Survival Guide has job search resources that apply here too. If you need a professional headshot, FedShot can help.
Key Dates
| Date | Event |
|---|---|
| Feb. 5, 2026 | OPM publishes final rule |
| Feb. 10, 2026 | RIF appeal transfer proposed |
| March 8, 2026 | Schedule Policy/Career takes effect |
| March 12, 2026 | RIF appeal comment period closes |
| TBD | President signs executive order approving specific position conversions |
| TBD | AFGE files legal challenge to final rule |
Frequently Asked Questions
What is Schedule Policy/Career (Schedule F) and who does it affect?
Schedule Policy/Career reclassifies approximately 50,000 career federal employees in policy-influencing positions from competitive service to excepted service, making them at-will workers. Affected positions include those that draft regulations, manage programs with broad discretion, supervise attorneys, or publicly advocate for agency policies. The rule takes effect March 8, 2026.
What protections do I lose if my position is reclassified?
You lose MSPB appeal rights for firings, suspensions, and demotions. You also lose the 30-day advance notice before termination, access to the Office of Special Counsel for whistleblower complaints, student loan repayment eligibility, and recruitment/retention/relocation incentives. You keep FERS retirement, FEHB, TSP, severance pay, and EEOC complaint rights.
When does Schedule Policy/Career take effect?
The rule takes effect March 8, 2026. However, actual reclassifications require a separate executive order from President Trump approving the specific positions agencies recommend. Agencies are currently preparing their lists. The timeline between the rule taking effect and individual employees being notified is not yet clear.
Can I appeal my reclassification?
No. The final rule does not allow employees to appeal their initial reclassification. Once a position is moved, it cannot be moved back without OPM review and White House approval. Legal challenges to the overall rule could reverse reclassifications if courts find it unlawful.
If I am reclassified and then fired, do I get severance pay?
Yes. Schedule Policy/Career employees retain federal severance pay eligibility. Use the Severance Pay Calculator to estimate your entitlement based on years of service, age, and salary. The Severance Pay Guide has the full calculation breakdown.
Related Resources
- Severance Pay Calculator: Estimate your severance if involuntarily separated
- FERS Retirement Calculator: Model your pension and compare staying vs. leaving
- RIF Survival Guide 2026: Full guide to federal layoff protections and job search
- VERA/VSIP Guide 2026: Early retirement and buyout options
- Severance Pay Guide: Complete severance calculation explained
- Federal Workforce Outlook 2026: Broader workforce trends and context
Sources: OPM Final Rule (Federal Register Doc. 2026-02375), OPM Schedule P/C FAQ, Federal News Network, Government Executive, FedSmith, Congress.gov (H.R. 492)