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

3. Central Personnel Agencies · Minor

Stop excessive designation of SES posts as "career reserved"

Partially done

Printed page 80 3. Central Personnel Agencies

“Actions such as career staff reserving excessive numbers of key policy positions as "career reserved" to deny them to noncareer SES employees frustrate CSRA intent.”

What has happened

  1. Partially done

    OPM went after the designations, one office at a time and then across the board. In February and March 2025 it encouraged agencies to redesignate Chief Information Officer and Chief Human Capital Officer posts as SES "general" positions — open to noncareer appointees — and issued guidance on career-reserved positions and agency redesignation requests that, in OPM's own description, directed a broader review of SES designations. In November it told agencies reviewing their executive allocations under Executive Order 14356 that the review should inform whether SES, SL and ST positions are appropriately classified and designated. Partial because no allowlisted source reports how many positions actually came off career-reserved status, and because the reviews are directed rather than binding.

Research log

What was searched, and what didn’t count as evidence

Research notes

Researched 2026-08-27.

The SES designation system is the mechanism: a “career reserved” position under 5 U.S.C. 3132(b) may be filled only by a career appointee; a “general” position may be filled by either. The Mandate’s complaint is that too many key policy posts are reserved.

OPM’s 2025-12-01 memorandum on SES reassignments footnotes the guidance it issued on exactly this:

“OPM, Guidance Regarding Redesignating SES CIO Positions (Feb. 4, 2025) (encouraging agencies to redesignate Chief Information Officers as SES ‘general’ positions); OPM, Guidance on Career Reserved SES Positions and Agency Redesignation Requests (Feb. 24, 2025) (directing a broader review of SES designations); OPM, Guidance Regarding Redesignating CHCO Positions (Mar. 6, 2025) (encouraging agencies to redesignate Chief Human Capital Officers as SES ‘general’ positions).”

OPM returned to it in November: the Call for Agency Review of Executive Allocations (2025-11-24) tells agencies their assessments “should also inform whether SES, SL and ST positions are appropriately classified and designated”, tied to the Annual Staffing Plans required by EO 14356.

The three February–March 2025 memoranda are not individually posted on the CHCO Council’s current listing, which carries only the 75 most recent items; they are cited here through the December memorandum, which is Primary and states what each did. No published count of career-reserved positions before and after exists.

Action
restrict
Object
"career reserved" SES positions
ID
123