OPM Sends RIF NPRM to OMB

Yesterday the OMB’s Office of Information and Regulatory Affairs (OIRA) announced that it had received a notice of proposed rulemaking from the Office of Personnel Management on “Reduction in Force”.

According to the listing for this rulemaking in the Spring 2025 Unified Agenda:

“The Office of Personnel Management is proposing to modify the regulations for reduction in force (RIF) to amend the retention factors to prioritize performance over length of service when determining which employees will be retained in a RIF and streamline the RIF process.”

The current civil service program was specifically designed to prevent federal jobs from being part of a political patronage system. While recognizing that above a certain level, management of the federal bureaucracy is political in nature (and thus requiring presidential appointment), most federal jobs require some level of practical expertise and experience to fairly and efficiently operate and oversee federal programs. Those jobs should not be subject to political litmus tests that change with every change in administration.

While I am sure that the folks at the Heritage Foundation have done an admirable job of cloaking their intent to rid the swamp of any liberal employees in language that would appear to be purely focused on efficiency and efficacy, the brief history of this administration makes it clear that ‘performance’ in the 47^th Administration means fealty to, and adoration of, the royal executive. That makes this rulemaking suspect at best.

This rulemaking is outside of the typical scope of coverage of this blog, so I will probably not devote any significant coverage to it, but I will certainly mention its publication in the appropriate Short Takes post.

Review – Chemical Security Inspector Reduction in Force – Part 4

I have been talking about the upcoming reduction in force of CISA’s Chemical Security Inspectors (CSI) this week. This will probably be the last post in this series of free posts in the series so I thought that I would try to outline what I would like to see happen. The earlier posts in this series include:

CSI RIF,

Chemical Security Inspector Reduction in Force – Part 2, and

Chemical Security Inspector Reduction in Force – Part 3

Too Late to Fix

To start with, I learned today that the CSI have been given until Monday to make their decisions about whether to take the offered ways to quit (making DHS look better than firing them would), or to stay around long enough to actually get their reduction in force (RIF) notices that everyone knows are coming. Neither option is great. Take the deferred resignation and get paid (with benefits) through the end of the fiscal year, but resignations mean that there will be no unemployment benefits. Get RIFed and they are eligible for unemployment benefits, but at much lower pay than they have been receiving. Federal medical benefits also disappear; fortunately, Obama Care is now available, not great, but better than what was available the last time I was laid off.

 

To see the alternatives that would provide a longer-term solution to the job situations for CSI and the security support for chemical facilities, see my article at CFSN Detailed Analysis - https://patrickcoyle.substack.com/p/chemical-security-inspector-reduction-7ca - free content.

Review – Chemical Security Inspector Reduction in Force – Part 3

Yesterday I published a guest post over on my CFSN Detailed Analysis blog by a CISA Chemical Security Inspector about the role of the CSI in the Chemical Facility Anti-Terrorism Standards (CFATS) program and their pending abolition in the current restructuring of the Cybersecurity and Infrastructure Security Agency. I thought that that letter was important enough that it should stand on its own before I added my two cents worth.

First, I want to clear up a mistake on my part in the introduction of yesterday’s post. I stated that the post was written by CSI that had “recently received their reduction in force notification.” What they had received from CISA was an advanced notice about the reorganization of CISA that has been described elsewhere. The actual RIF notices have not yet been sent out. What they were told was that the CSI were no longer required. About the only thing that can stop that is action by Congress, which is, unfortunately, unlikely to happen.

The bulk of my comments on that guest post are going to be published on CFSN Detailed Analysis - https://patrickcoyle.substack.com/p/chemical-security-inspector-reduction-faa - again as a free-to-all post.

Moving Forward

In the face of the mass layoffs at so many federal agencies, many would ask why I would take up the case of these eighty or so CSI that are most probably facing their own layoffs. The simple answer is that I have been advocating for them and their compatriots for the last 16 years or so and I am not going to stop now. More importantly, I have a solid understanding of what CISA and DHS are going to lose if these CSI are going to be let go. This is a valuable resource that CISA will eventually deeply regret losing.

Chemical Security Inspector Reduction in Force – Part 2

I published a non-paywalled article over on CFSN Detailed Analysis, it is a long-form letter from a CISA Chemical Security Inspector that was better suited to that format. Please, go and read it there.