Schedule F: Who’s Covered, What You Lose, and How It Happens

Schedule F, reinstated in January 2025 under the name Schedule Policy/Career, is a federal employment category that moves career civil servants in policy-influencing roles out of the competitive service and into the excepted service, making them at-will employees who can be fired without the notice, cause requirement, or appeal rights they previously had. The Office of Personnel Management finalized the implementing rule on February 5, 2026, with an effective date 30 days later.¹ Estimates suggest roughly 50,000 federal employees could eventually be reclassified. For any federal employee whose position lands in the category, the practical effect is a shift from something close to permanent employment to something closer to private-sector at-will work.

What Schedule F Is Now

The category exists today as Schedule Policy/Career. Executive Order 14171, signed January 20, 2025, reinstated the original 2020 Schedule F order “with full force and effect,” revoked the Biden-era order that had killed it, and renamed the schedule.² OPM’s February 2026 final rule rescinded a 2024 regulation that had built procedural barriers against involuntary reclassification, and put the framework for at-will policy positions formally into effect.³

The regulatory machinery is in place, but no employees have actually been reclassified yet. Reclassification requires a separate presidential order naming specific positions, and none had been issued as of mid-2026.

Whose Jobs Are Covered

The category targets career positions with a “confidential, policy-determining, policy-making, or policy-advocating character” that are “not normally subject to change as a result of a Presidential transition.”² In practice that reaches employees who exercise meaningful discretion: people who draft regulations, manage sensitive programs, interpret statutes, or present budget requests to OMB examiners. Routine administrative and technical work is not the target.

The 2025 order widened the criteria beyond the 2020 version. It added employees who directly or indirectly supervise other Schedule Policy/Career positions, plus any duties the OPM Director “otherwise indicates may be appropriate for inclusion.” That last phrase functions as a catch-all, and the “policy-advocating” label is broad enough on its own to reach employees who represent an agency externally or draft public-facing documents.

The executive order includes language that has become the most argued-over part of the policy. Schedule Policy/Career employees “are not required to personally or politically support the current President or the policies of the current administration,” but they “are required to faithfully implement administration policies to the best of their ability,” and failure to do so is expressly listed as grounds for dismissal. Critics read this as political loyalty by another name. Supporters read it as ordinary accountability for policy staff.

What You Lose If Your Position Is Reclassified

Your job duties, pay grade, salary, retirement contributions, and health insurance do not change. What changes is the legal framework around firing you.

Advance Notice and Cause

A career employee in the competitive service facing removal or suspension normally gets at least 30 days’ advance written notice stating the specific reasons, at least seven days to respond in writing or orally and submit evidence, the right to be represented by an attorney, and a written decision.⁴ Employees moved into Schedule Policy/Career lose all of it. The 2026 final rule states plainly that these positions become “at-will positions excepted from adverse action procedures or appeals.”³

The statutory hook is Title 5, which excludes from adverse action protection any employee whose position has been determined by the President or OPM to be of a “confidential, policy-determining, policy-making or policy-advocating character.”⁵ Schedule Policy/Career is defined using that exact language, so once a position is reclassified, the exclusion applies automatically.

MSPB Appeals

In the competitive service, an employee who believes they were fired unfairly can appeal to the Merit Systems Protection Board, an independent body that reviews whether the agency had legitimate grounds and followed proper procedures. The 2026 final rule states that Schedule Policy/Career employees are “categorically exempt” from MSPB appeal coverage.³ A terminated employee in the category has no independent administrative body to review the firing.

Whistleblower Protection: An Open Question

Federal law prohibits a long list of personnel abuses, including retaliation against whistleblowers, discrimination, political coercion, and nepotism. These protections apply to employees in “covered positions,” and the statute expressly excludes from that definition any position “excepted from the competitive service because of its confidential, policy-determining, policy-making, or policy-advocating character.”⁶ That exclusion maps directly onto the definition of Schedule Policy/Career.

If the exclusion applies as written, reclassified employees would lose the statutory shield against being fired for reporting waste, fraud, or abuse, or for refusing to engage in political activity. The MSPB has noted that whistleblower appeal rights generally extend to most excepted service positions, but the carve-out for policy-determining positions is a specific exception to that general rule.⁷ Whether that reading holds is one of the central questions in the pending litigation.

What Survives

Anti-discrimination statutes with their own coverage rules — Title VII, the Age Discrimination in Employment Act, the Rehabilitation Act — do not depend on the Section 2302 definition and would likely continue to apply. An employee who believes a reclassification or a subsequent firing was racially discriminatory or retaliatory in a way those statutes cover would still have recourse, though the scope of available remedies once the Section 2302 exclusion kicks in is unresolved.

How Reclassification Actually Happens

The process begins inside your agency. Each agency head reviews the roster of competitive service positions and identifies which ones meet the policy-influencing criteria, assessing job descriptions, daily responsibilities, and the degree of discretion involved. The agency then submits a formal petition to OPM.³

Under the 2020 version, OPM had final approval authority. The 2025 order changed that. OPM now reviews petitions and makes recommendations, but the President makes the final call, and the reclassification takes effect through a separate presidential executive order naming specific positions.⁸ Practically, this means your position does not move into Schedule Policy/Career until three things have happened: your agency has petitioned, OPM has reviewed, and the President has signed an order that includes your position.

What Is and Isn’t Being Challenged

Two federal lawsuits are challenging the framework. The National Treasury Employees Union filed in the U.S. District Court for the District of Columbia the day Executive Order 14171 was signed. That case was stayed while OPM developed its final rule, and in March 2026 the court accepted NTEU’s proposal to file an amended complaint within 14 days of any presidential order placing specific positions into Schedule Policy/Career. A second case, PEER v. Trump, is in the U.S. District Court for the District of Maryland; on March 4, 2026, a coalition including AFGE, AFSCME, the AFL-CIO, and Democracy Forward filed a second amended complaint targeting the executive order, OPM’s rule, and the reclassification framework as a whole. As of mid-2026, no court has issued a preliminary injunction blocking the rule.

In Congress, the Saving the Civil Service Act (H.R. 492 / S. 134) would prohibit the creation of the new schedule. It was introduced in January 2025 and remains at the “Introduced” stage with no committee vote or floor action as of mid-2026.⁹ For now, the courts are the primary check.

One boundary worth noting: recent executive orders directing agencies to terminate collective bargaining agreements and stop payroll dues collection (Executive Orders 14251 and 14343) are separate policies. They do not target Schedule Policy/Career specifically, though many of the same agencies and positions are affected by both. Police officers, security guards, and firefighters are exempted from the labor exclusion orders and continue to be represented by their unions.¹⁰

1
U.S. Office of Personnel Management. OPM Finalizes Schedule Policy/Career Rule to Strengthen Accountability
2
Federal Register. Restoring Accountability to Policy-Influencing Positions Within the Federal Workforce
3
Federal Register. Improving Performance, Accountability and Responsiveness in the Civil Service
4
Office of the Law Revision Counsel. 5 USC 7513 – Cause and Procedure
5
Office of the Law Revision Counsel. 5 USC 7511 – Definitions; Application
6
Office of the Law Revision Counsel. 5 USC 2302 – Prohibited Personnel Practices
7
U.S. Merit Systems Protection Board. Whistleblower Questions and Answers
8
Federal Register. Improving Performance, Accountability and Responsiveness in the Civil Service
9
Congress.gov. H.R. 492 – 119th Congress – Saving the Civil Service Act
10
U.S. Office of Personnel Management. Frequently Asked Questions – Executive Order 14251 Exclusions from Federal Labor-Management Relations Programs