FR 2025-00672

General Summary

The memorandum issued by the President outlines who should step in and perform the duties of the Director of the Office of Personnel Management (OPM) in case both the Director and the Deputy Director are unable to fulfill their roles. The succession starts with the Chief of Staff, followed by other senior officials like the General Counsel and the Chief Management Officer. However, those who are already serving in acting capacities for these roles are not automatically eligible to act as Director. The President also retains the authority to appoint someone else as the acting Director, regardless of the established order. Additionally, this memorandum revokes a previous succession order from December 10, 2020.

Significant Issues or Concerns

One of the notable concerns with the memorandum is the lack of specific information on any potential financial implications of the order of succession. Without clarity on these budgetary aspects, there might be room for misunderstandings or ambiguity about costs. Additionally, the President's discretion to appoint an acting Director departs from the order could raise questions about transparency and predictability in the succession process.

The memorandum's language includes legal references and terms that may not be easily interpreted by all readers, such as "subject to the limitations set forth in the Act" and "to the extent permitted by law." These may leave gaps for interpretation, potentially complicating the document's execution. Furthermore, revoking the previous succession order without a detailed justification could affect organizational continuity at OPM.

Impact on the Public and Specific Stakeholders

For the general public, this document has indirect implications. It aims to ensure the continued functioning of the OPM, an agency responsible for managing the federal workforce, by clarifying who can take over in the case of leadership vacancies. This stability is crucial for maintaining government operations that affect federal employees and, by extension, public services.

Specific stakeholders within the OPM may experience varying impacts. Senior officials are directly affected since their potential roles in succession are clearly defined. The structure may create a sense of preparedness and accountability among these leaders. However, those in acting capacities might find the order limiting, as it prevents automatic escalation to the Director role, potentially leading to concerns about career progression.

Conclusion

This memorandum seeks to establish a clear order of succession within the OPM, ensuring that leadership transitions occur smoothly when necessary. While it lays out a structured plan, the document leaves room for presidential discretion and lacks exhaustive clarity on potential costs or legal interpretations. By addressing leadership uncertainties, the memorandum plays a critical role in the continuity of operations at OPM and indirectly supports federal workforce management, thereby impacting public services.