Project 2025 Tracker / What’s done, what’s next

Section 1 · Taking the Reins of Government

3 Central Personnel Agencies

69–86 · Dennis Dean Kirk , Donald Devine , Paul Dans

  • 6 done
  • 14 partially done
  • 7 not started

Major recommendations (2)

What has happened

The Mandate said

“This doctrine of disparate impact could be ended legislatively or at least narrowed through the regulatory process by a future Administration.”

What happened

Done

OPM struck every reference to the Uniform Guidelines on Employee Selection Procedures — the vehicle for disparate-impact review of federal hiring — from the civil service regulations, following a 2026-06-09 OLC opinion finding the Guidelines unlawful. This is the "narrowed through the regulatory process" outcome the Chapter asks for.

The Mandate said

“It should be reinstated, but SES responsibility should come first.”

+2 more citations

What happened

Done

Executive Order 14410 placed the first positions (listed in its appendix) into Schedule Policy/Career and gave agencies 7 days to notify incumbents. Lawsuits are pending; no injunction found on allowlisted sources.

The Mandate said

“It should be reinstated, but SES responsibility should come first.”

+2 more citations

What happened

Partially done

OPM published the final rule creating Schedule Policy/Career in the excepted service (effective 2026-03-09), after an April 2025 proposed rule; agencies could now request placements.

The Mandate said

“This doctrine of disparate impact could be ended legislatively or at least narrowed through the regulatory process by a future Administration.”

What happened

Partially done

DOJ removed the disparate-impact provisions from its Title VI regulations — regulatory narrowing, but for federal funding recipients rather than federal hiring.

The Mandate said

“This doctrine of disparate impact could be ended legislatively or at least narrowed through the regulatory process by a future Administration.”

What happened

Attempted

Executive Order 14281 declared a policy of eliminating disparate-impact liability "in all contexts to the maximum degree possible" and directed agencies to deprioritize enforcement and revise regulations.

Still to come

Executive action 2

  1. 78 Hold regular GSA-OPM leadership meetings on shared personnel matters Minor Not started
  2. 83 Seat the OPM Director in the President's Cabinet Minor Not started

Needs Congress 5

  1. 74 Reinstate and extend the federal merit pay program Notable Not started
  2. 76 Transfer the EEOC's federal employee section to the MSPB Notable Not started
  3. 76 Return the Office of Special Counsel's investigatory functions to OPM Notable Not started
  4. 76 Make the MSPB the main reviewer of federal adverse actions Notable Not started
  5. 77 Have OPM set pay schedules by occupation and region Notable Not started

All recommendations in this chapter

Every recommendation this chapter is the home of, in printed-page order.

  1. 69 Give personnel management Cabinet-level precedence Partially done
  2. 72 Require an "outstanding" rating for SES bonuses Partially done
  3. 72 End or narrow the disparate impact doctrine in federal hiring Done
  4. 73 Reform the Uniform Guidelines on Employee Selection Procedures Partially done
  5. 73 Have OPM restore KSA-based civil service entrance testing Done
  6. 73 Reissue Executive Order 13839 on removal procedures Partially done
  7. 74 Build policy goals directly into federal employee appraisals Partially done
  8. 74 Have political executives supervise career staff appraisals directly Partially done
  9. 74 Reinstate and extend the federal merit pay program Needs Congress Not started
  10. 76 Transfer the EEOC's federal employee section to the MSPB Needs Congress Not started
  11. 76 Return the Office of Special Counsel's investigatory functions to OPM Needs Congress Not started
  12. 76 Make the MSPB the main reviewer of federal adverse actions Needs Congress Not started
  13. 77 Have OPM set pay schedules by occupation and region Needs Congress Not started
  14. 78 Hold regular GSA-OPM leadership meetings on shared personnel matters Not started
  15. 79 Freeze all top career-position hiring to stop burrowing-in Done
  16. 79 Make performance the first factor in reduction-in-force retention Needs Congress Partially done
  17. 80 Limit SES burrowing-in by creating and filling political positions Partially done
  18. 80 Stop excessive designation of SES posts as "career reserved" Partially done
  19. 80 Put noncareer executives in control of SES evaluation boards Partially done
  20. 81 Reinstate Schedule F (Executive Order 13957) Done
  21. 81 Enforce statutory management rights against federal unions Partially done
  22. 82 Reinstate Executive Order 13836 on collective bargaining agreements Partially done
  23. 82 Reinstate Executive Order 13837 on official union time Partially done
  24. 82 Immediately appoint the FLRA General Counsel Done
  25. 82 Reactivate the Federal Service Impasses Panel Done
  26. 82 Fill all top political appointee positions from the outset Partially done
  27. 83 Seat the OPM Director in the President's Cabinet Not started