On March 6, 2025, the Office of Personnel Management (OPM) issued a new guidance memorandum concerning position classification for Chief Human Capital Officer (CHCO) positions in the Senior Executive Service.
As previously analyzed in this blog, OPM has been pushing agencies to redesignate SES positions from being ‘career reserved’ (that is, reserved for ‘career appointees’ whose professional qualifications have been reviewed) to ‘general’ (opening the position to possibly political ‘noncareer appointees’ as well as temporary or term appointees, subject to statutory limits). In particular, in a February 4, 2025, guidance memorandum, OPM specifically called for redesignation of Chief Information Officer (CIO) SES positions as ‘general.’
In the new guidance memorandum, OPM ‘recommend[ed]’ that agencies file requests to redesignate their CHCO positions as ‘general’ SES positions no later than March 24, 2025. OPM claimed in the guidance memorandum that CHCOs’ implementation of Diversity, Equity and Inclusion (DEI) programs during the Biden Administration had indicated that CHCO positions were “policy-determining and policy-advocating jobs” rather than merely impartial or technical positions, thus warranting the redesignation as ‘general’ SES positions.
This guidance memorandum is part of a larger effort seeking to expand the number of SES positions designated as ‘general’ positions, and thus open to being filled by limited emergency appointees, limited term appointees or by noncareer appointees—many of whom serve only at the pleasure of the appointing authority.
If you are an SES employee and wish to seek advice regarding your rights based on this OPM guidance memorandum, consider contacting Gilbert Employment Law, P.C. to request an initial consultation.