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Did any agency write new rules for checking political hires after the 2024 election?

Research question: Did the Office of Personnel Management or any agency change how political appointees are vetted after the 2024 election, and what written guidance did they issue?

The records show that OPM issued an April 10, 2025 memo instructing agencies to revoke delegations that had let career HR staff onboard and vet political appointees 27. Democratic senators argued in May 2025 that the related pay memo would let appointees begin sensitive work without vetting, including conflict-of-interest and background checks 2. A June 30, 2026 final rule limits OPM's ability to take post-appointment conduct suitability actions against appointees unless an agency makes a proper and sufficient referral, which the agency head or designees may make 202223. The records do not show a dedicated written vetting guidance for political appointees, and the rule's appeal changes leave the underlying vetting standards untouched 1. The newest facts date from October 2026, which matches today, and they concern Schedule G's proposed rule rather than vetting 3940.

Checked 2026-10-21. Only documented and supported facts are used.
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Sources

[1] supported
The rule changes only the forum and procedures for appealing suitability actions, not the underlying vetting standards.
"It revises only subpart E--the forum and procedures for appealing a suitability action taken under part 731."
Suitability Action Appeals (Personnel Management Office, 2026-08-03)
[2] supported
Democratic senators argued that the memo would let appointees begin sensitive work without vetting, including conflict-of-interest checks and background checks.
"This would allow appointees to begin work in sensitive roles without any vetting, including for conflicts of interest or background checks, bypassing the basic guardrails that have been in place for decades."
Senators fix their sights on OPM’s pay memo for political appointees - Government Executive
[3] supported
The federal government is consolidating its separate background investigation questionnaires for political appointees into a single Personnel Vetting Questionnaire.
"The government is in the process of consolidating these forms into one Personnel Vetting Questionnaire."
Frequently Asked Questions About the Political Appointment Process • Center for Presidential Transition
[4] documented
The rule added a new requirement that individuals in low risk positions be continuously vetted.
"Aside from the new requirement for individuals in low risk positions to be continuously vetted"
Suitability and Fitness (Personnel Management Office, 2024-12-18)
[5] documented
The rule does not expand the categories of positions or people covered by part 731, create new suitability factors, authorize new suitability actions, or change when OPM or an agency may take a suitability action.
"This final rule does not expand the categories of positions or individuals subject to part 731, create new substantive suitability factors, authorize new suitability actions, or alter the circumstances under which OPM or an agency may take a suitability action."
Suitability Action Appeals (Personnel Management Office, 2026-08-03)
[6] supported
The senators' May 28 letter asked acting OPM director Charles Ezell for any OPM guidance on setting Schedule C terms to avoid widespread corruption, and for information on the Presidential Personnel Office's role in hiring Schedule C appointees.
"any OPM guidance to agencies as to how to set the terms for a Schedule C appointment in order to avoid widespread corruption"
Senators fix their sights on OPM’s pay memo for political appointees - Government Executive
[7] documented
OPM delegates limited authority to agency heads to adjudicate suitability of applicants or appointees for competitive service and career Senior Executive Service positions.
"This section describes the limited delegation and related requirements that OPM makes to agency heads for adjudicating the suitability of applicants or appointees for competitive service and career Senior Executive Service positions"
Suitability and Fitness (Personnel Management Office, 2024-12-18)
[8] documented
Appointees, applicants, and employees can no longer appeal a part 731 suitability action to the MSPB under subpart E.
"Individuals in any covered status--whether applicant, appointee, or employee, as those terms are used in part 731--may no longer appeal a part 731 suitability action to the MSPB under subpart E."
Suitability Action Appeals (Personnel Management Office, 2026-08-03)
[9] documented
OPM kept the power to adjudicate suitability itself where the nature of the conduct makes an individual unsuitable for any position.
"OPM retained the authority to adjudicate suitability in cases where the nature of the conduct causes the individual to be unsuitable for any position."
Suitability and Fitness (Personnel Management Office, 2024-12-18)
[10] supported
The Trump administration released its Merit Hiring Plan in May 2025, saying it aims to ensure only the most talented, capable and patriotic Americans are hired into federal service.
"The Trump administration released its Merit Hiring Plan in May 2025 to ensure that “only the most talented, capable and patriotic Americans are hired to the federal service.”"
Federal job applicants can’t skip ‘loyalty question’ that OPM says is optional, court filings claim
[11] supported
The appeals rule is limited to suitability actions and does not create appeal rights for fitness, security-clearance, or credentialing determinations.
"This final rule is limited to appeals of suitability actions under part 731."
Suitability Action Appeals (Personnel Management Office, 2026-08-03)
[12] supported
In follow-up guidance, OPM downplayed the essay questions as just one piece of a candidate's overall application.
"OPM downplayed the importance of the essays as just one piece of a candidate’s overall application."
Federal job applicants can’t skip ‘loyalty question’ that OPM says is optional, court filings claim
[13] supported
OPM told agencies that the essay questions are optional for candidates applying for General Schedule 5 through 15 positions and Senior Professional positions.
"OPM told agencies that the four questions are optional for candidates applying for General Schedule 5 through 15 positions and Senior Professional positions"
Federal job applicants can’t skip ‘loyalty question’ that OPM says is optional, court filings claim
[14] supported
OPM's guidance said the questions should not serve as an ideological litmus test, and applicants who skip them will not be disqualified or screened out.
"OPM’s guidance said the questions should not serve as an “ideological litmus test on candidates,” and that if an applicant does not answer the questions along with their application, “they will not be disqualified or screened out.”"
Federal job applicants can’t skip ‘loyalty question’ that OPM says is optional, court filings claim
[15] supported
An OPM official told federal HR employees in a virtual training that the essays were optional for candidates but mandatory for agencies to include on applications.
"An OPM official told federal HR employees in a virtual training last summer that it was “optional” for job candidates to complete the essays, but “mandatory” for agencies to include them on applications."
Federal job applicants can’t skip ‘loyalty question’ that OPM says is optional, court filings claim
[16] documented
The Office of Personnel Management (OPM) explicitly excludes political appointees from its suitability and fitness vetting jurisdiction, determining it lacks the authority to prescribe standards for them.
"OPM is also excluding political appointees from its definition of the ``excepted service'' for purposes of suitability and fitness under part 731. OPM has determined that the Director of OPM does not have the authority to prescribe standards of fitness and related vetting requirements for political appointments."
Suitability and Fitness Vetting (Personnel Management Office, 2023-01-31)
[17] documented
Positions filled by political appointment are statutorily excluded from OPM's appointing authorities and suitability standards under Civil Service Rule II.
"except for (A) positions in any element of the intelligence community as defined in the National Security Act of 1947, as amended, to the extent they are not otherwise subject to OPM appointing authorities, (B) positions where OPM is statutorily precluded from prescribing such standards, and (C) positions when filled by political appointment. These exceptions are in Civil Service Rule II, 5 CFR 2."
Suitability and Fitness Vetting (Personnel Management Office, 2023-01-31)
[18] documented
OPM is proposing to transition from traditional periodic reinvestigations to a U.S. Government-wide continuous vetting system to assess security, suitability, and fitness on an ongoing basis.
"Transition from traditional periodic reinvestigations to U.S. Government-wide continuous vetting, as defined in E.O. 13467, as amended, to the maximum extent practicable, consistent with law and as further directed by the E.O., to assess security, suitability, fitness, and credentialing decisions on an ongoing basis"
Suitability and Fitness Vetting (Personnel Management Office, 2023-01-31)
[19] documented
The Office of Personnel Management issued a final rule in June 2026 amending federal personnel vetting adjudicative processes to improve efficiency and rigor.
"The Office of Personnel Management (OPM) is amending the Federal Government personnel vetting adjudicative processes for determining suitability and taking suitability actions. The final rule will improve the efficiency, rigor, and ti"
Suitability and Fitness (Personnel Management Office, 2026-06-30)
[20] documented
OPM limited its authority to take post-appointment conduct suitability actions against appointees unless the employing agency first makes a proper and sufficient referral.
"OPM proposed that it would only make final suitability determinations and take suitability actions based on post-appointment conduct if the employing agency first made a proper and sufficient referral to OPM."
Suitability and Fitness (Personnel Management Office, 2026-06-30)
[21] documented
The rule explicitly states that suitability determinations are not subject to partisan political activities and that applicants are not asked about their voting patterns or political preferences.
"suitability determinations and actions are not subject to, nor do they have any bearing on, partisan political activities or coercion. Further, contrary to one commenter's concern that individuals seeking to work or working in the Federal civil service would be required to disclose their voting history and any political party preferences, this is simply not true."
Suitability and Fitness (Personnel Management Office, 2026-06-30)
[22] documented
OPM clarified that agency referrals to OPM for suitability cases may be made by the agency head or one or more people the agency head designates, rather than necessarily by the political appointee themselves.
"OPM will add language to Sec. Sec. 731.103(b) and 731.105(b) and (d) making it clear that the referral from the agency may be made by the agency head or one or more people the agency head designates."
Suitability and Fitness (Personnel Management Office, 2026-06-30)
[23] documented
The final rule establishes that OPM may take a suitability action against an appointee based on post-appointment conduct only when there is a proper and sufficient referral by the head of the appointee's employing agency or their designee.
"When the basis for the action is post-appointment conduct, OPM may take a suitability action against an appointee only when there is a proper and sufficient referral by the head of the appointee's employing agency, or designee."
Suitability and Fitness (Personnel Management Office, 2026-06-30)
[24] documented
Agencies are required to report specific details of background investigations and suitability actions to the Central Verification System or its successor, including the nature, result, and completion date of each check.
"An agency must report to the Central Verification System or its successor the level or nature, result, and completion date of each background investigation, reinvestigation, or enrollment in Continuous Vetting; each agency decision based on such investigation, reinvestigation, or Continuous Vetting; and any personnel action, to include suitability actions, taken based on such investigation, reinve"
eCFR :: 5 CFR Part 731 -- Suitability and Fitness
[25] documented
Hiring agencies are prohibited from making specific inquiries about an applicant's criminal background until a conditional offer of employment has been made.
"A hiring agency may not make specific inquiries concerning an applicant's criminal background in oral or written form (including through the OF-306 or other forms used to conduct vetting for Federal employment, USAJOBS, or any other electronic means) unless the hiring agency has made a conditional offer of employment to the applicant."
eCFR :: 5 CFR Part 731 -- Suitability and Fitness
[26] documented
If an individual's position risk level changes to a higher level due to promotion or transfer, any required upgrade in investigation must be initiated within 14 days after the change is final.
"Any upgrade in the investigation required for the new risk level should be initiated within 14 days after the promotion, demotion, reassignment, transfer or new designation of risk level is final or as otherwise required by 5 CFR part 1400 ."
eCFR :: 5 CFR Part 731 -- Suitability and Fitness
[27] supported
OPM issued a memo on April 10, 2025, instructing agencies to revoke delegations given to career HR employees for onboarding and vetting political appointees.
"The April 10 memo from acting OPM Director Charles Ezell to agency heads reminds them of the “great flexibility” they have when setting the pay of employees hired under Schedule C of the federal government’s excepted service, the portion of the federal workforce made up of low-level political appointees. ... The memo notes that Schedule C salaries cap out at $195,200. And it instructs agencies to "
OPM strips career HR from Schedule C appointments, salary setting
[28] supported
The OPM guidance encourages agencies to pay political appointees the maximum federal salary of $195,200.
"The Office of Personnel Management last week issued new guidance encouraging agencies to pay political appointees the maximum federal salary and removing career HR workers from the appointment process. ... The memo notes that Schedule C salaries cap out at $195,200."
OPM strips career HR from Schedule C appointments, salary setting
[29] supported
OPM stated that Schedule C appointing authority requires approval by OPM’s White House liaison through OPM’s Executive and Schedule C System.
"“Agencies should also note that as a matter of process, Schedule C appointing authority requires approval by OPM’s White House liaison, through OPM’s Executive and Schedule C System,” the document states."
OPM strips career HR from Schedule C appointments, salary setting
[30] supported
Traditionally, career HR employees evaluated resumes, ensured vetting, and provided input on starting salaries for Schedule C appointees, a role the new memo removes.
"Traditionally, while the selection of Schedule C appointees is typically the job of the White House or an agency’s White House liaison, career HR employees evaluate an incoming appointee’s resume and experience, ensure they are properly vetted, and provide input about the appointee’s proposed starting salary."
OPM strips career HR from Schedule C appointments, salary setting
[31] supported
The White House presidential personnel office is responsible for recruiting, screening, and managing political appointees.
"The White House presidential personnel office exists to recruit, screen and manage those employees."
Inside the Trump White House's intense screening of job-seekers | AP News
[32] supported
In July 2025, President Trump issued an executive order creating Schedule G, a new job classification for non-Senate-confirmed political appointees in policy-making or policy-advocating roles.
"In July 2025, the president issued an executive order creating Schedule G , a new job classification for non-Senate-confirmed political appointees in policy-making or policy-advocating roles."
Trump quietly hired political appointees under a new job classification ...
[33] supported
An OPM memo excludes all Schedule C and Schedule G political appointees from the Trump administration's stricter federal performance appraisal overhaul.
"A memo from the Office of Personnel Management excludes all Schedule C and Schedule G appointees from the stricter performance metrics."
Political appointees exempt from new performance evaluations
[34] supported
OPM issued updated written guidance on December 18, 2025, in memo CPM 2025-21, but its subject is the pay freeze for certain senior political officials, not how political appointees are vetted.
"Updated Guidance – Pay Freeze for Certain Senior Political Officials"
PDF Memo on Continued Pay Freeze for Senior Political Officials
[35] supported
Shortly after the executive order, the Office of Personnel Management issued written guidance to agencies on making Schedule G appointments.
"Shortly thereafter, the Office of Personnel Management issued guidance to agencies on making Schedule G appointments."
Trump quietly hired political appointees under a new job classification ...
[36] supported
OPM said political appointees are already at-will workers, so decisions to keep or remove them do not depend on formal performance evaluations.
"OPM said political appointees are already at-will workers, so decisions on whether they should be kept or removed from their jobs do not depend on formal performance evaluations."
Political appointees exempt from new performance evaluations
[37] supported
The updated guidance extends the senior political official pay freeze through January 30, 2026, and says future Congressional action will determine whether it continues.
"Section 747 continues the pay freeze through January 30, 2026."
PDF Memo on Continued Pay Freeze for Senior Political Officials
[38] supported
OPM proposed a rule in September to establish Schedule G in regulation, with public comments due November 17.
"The government’s HR agency proposed a rule establishing Schedule G in regulation in September; the deadline for members of the public to comment on the proposed rule is Nov. 17."
Trump quietly hired political appointees under a new job classification ...
[39] supported
OPM said that even without a final rule, Schedule G has formal guardrails from its implementing guidance to agencies and the executive order itself.
"OPM countered that, even without a final rule, there are still formal guardrails for Schedule G because of its implementing guidance to agencies as well as the executive order itself."
Trump quietly hired political appointees under a new job classification ...
[40] supported
The pending proposed rule would only make conforming amendments to the Code of Federal Regulations and does not establish the underlying authority for Schedule G.
"The pending proposed rule would make conforming amendments to [the Code of Federal Regulations]; it does not establish the underlying authority for Schedule G,"
Trump quietly hired political appointees under a new job classification ...