On March 17, 2025, the Office of Personnel Management (OPM) issued a new memorandum requiring agencies to compile and report information regarding union official time usage and other issues at each agency.
This new memorandum dovetails with a February 27, 2025 OPM memorandum previously analyzed in this blog (which the new memorandum references in its text). Under the new memorandum, agencies are now required to compile and report to OPM the amounts of expenses incurred for collective bargaining and for union grievances in FY 2024. Information sought includes the total compensation paid to employees on both sides of a collective bargaining negotiation (both for the original union collective bargaining agreement and for any midterm agreements), compensation and costs on both sides for mediation and arbitration of union grievances and collective bargaining impasses. Agencies are also directed to collate information on the value of agency office space provided to unions, and amounts agencies had to pay in damages or settlements from union proceedings. Agencies are also required to report each union collective bargaining agreement they have in force, and any midterm negotiations that have occurred in FY 2024. Agencies are supposed to respond to OPM by April 18, 2025. These reporting requirements partially overlap the February 27, 2025 memorandum, and also have similarities to previous reporting requirements which were imposed in the first Trump Administration under E.O. 13837 (May 25, 2018), Sections 6-7, which had been rescinded by E.O. 14003 (January 22. 2021). Following on the present Administration’s rescission of E.O. 14003, OPM in a February, 7, 2025 memorandum directed agencies to begin reinstatement of Trump Administration policies rescinded by E.O. 14003, although OPM did clarify that “The revocation of Executive Order 14003 order does not immediately reinstate those orders” rescinded by E.O. 14003.
If you are a federal employee or federal sector union and wish to seek advice concerning your rights in relation to this new policy, consider contacting Gilbert Employment Law to request an initial consultation.