Which agencies previously drafted the largest lists for Schedule F-style reclassification and how did internal HR assessments differ?
Executive summary
Five agencies and several components prepared the largest draft rosters for Schedule F–style reclassification; internal human resources reviews varied from sweeping inclusion (more than half of roles at one agency) to narrow, checkbox-style lists that covered 10% or less of staff, while a separate set of agencies concluded they would reclassify no positions at all [1]. Those disparities reflect both differing institutional missions and sharply divergent interpretations of the Schedule Policy/Career criteria, with OMB/OPM playing a central gatekeeper role and some agency leaders pushing far broader conversions than their HR shops judged appropriate [1] [2] [3].
1. Which agencies drafted the largest lists: a short inventory
Reporting identifies five agencies that produced notable draft lists: the Federal Energy Regulatory Commission (FERC), the Equal Employment Opportunity Commission (EEOC), the Environmental Protection Agency (EPA), the Federal Trade Commission (FTC), and the Office of Personnel Management (OPM) itself, with FERC standing out for inclusion of a majority of positions and the others producing much smaller-percentage drafts [1]. Separately, the Office of Management and Budget submitted a list of 140 position types—136 of which OPM approved—that would have affected 415 of the agency’s 610 employees, illustrating how component agencies and central budget offices also created substantial proposed rosters [1].
2. FERC and OMB: biggest proportions versus high head‑count concentration
FERC’s internal assessment concluded that more than half of its positions met the Schedule Policy/Career criteria, a proportion far larger than other agencies’ self-assessments and a signal that mission-specific regulatory agencies can produce very expansive lists when applying the policy’s broad language to technical roles [1]. OMB’s submission, by contrast, was notable for density rather than percentage—140 position types approved by OPM translated to 415 employees at OMB, a high concentration within a small agency where certain policy, digital services, and program examination roles were singled out [1].
3. Department of Commerce and Social Security: thousands on paper, maximalist local directives
The Commerce Department was reported to be reviewing lists from component bureaus that contained thousands of employees, reportedly including most GS‑15s and many GS‑14s—an approach that could produce large absolute numbers even if percentage shares varied across bureaus [1]. At the Social Security Administration, acting leadership pushed a sweeping internal directive to convert entire senior leadership layers and some offices into Schedule Policy/Career, a maximalist stance that alarmed unions and career staff and illustrates how agency heads could outpace or override conservative HR readings [3].
4. Agencies that opted out and those that produced modest drafts
At the other end of the spectrum, six agencies explicitly determined they would not reclassify any positions—an internal decision consistent with narrow HR readings of the criteria; those agencies included the Federal Maritime Commission, Federal Retirement Thrift Investment Board, National Archives and Records Administration, National Transportation Safety Board, National Labor Relations Board, and AmeriCorps [1]. Meanwhile EEOC, EPA, FTC and OPM each produced draft lists that would have reclassified around or less than 10% of their workforces, showing that many HR shops interpreted the guidance far more narrowly than agencies like FERC or some Commerce components [1].
5. Why internal HR assessments differed: definitions, mission, and legal posture
Differences in HR judgments stemmed from the policy’s expansive definitional hooks (which can sweep in anyone who “views, circulates, or otherwise works with” proposed policy materials) and from each agency’s mission-driven judgment about what counts as policy work; watchdog analyses warned that the wording could capture administrative assistants, IT staff, and FOIA officers, pressuring HR to either broadly or narrowly interpret inclusion criteria [4] [1]. OPM acted as arbiter—making recommendations and approving many agency submissions—which meant internal HR assessments folded in both agency leaders’ directional decisions and OPM’s evolving legal and procedural guidance during the review process [2] [1].
6. The practical outcome and limits of available reporting
Available reporting makes clear which agencies drafted the largest lists and how assessments diverged internally—FERC and Commerce components produced the largest proportional or numeric rosters, while several independent agencies produced little or none—but the sources do not document final personnel actions taken or the full internal deliberative records that produced those lists, and some numbers (like the OPM estimate of up to 50,000 possible reclassifications) are presented as estimates rather than completed conversions [1] [5]. The pattern is unambiguous in the record: interpretation of Schedule Policy/Career varied dramatically across agencies, producing outcomes that ranged from sweeping proposed conversions to explicit internal decisions to reclassify nobody [1] [3] [4].