OPM is ending a promotion rule, but agencies still have work to do

A federal promotion can look merit-based on paper even when management shaped who would have a chance to qualify long before the job was advertised.

Sometimes the first promotion decision isn’t the selection. It’s the temporary assignment that only some employees are offered.

I’ve seen what happens next.

During my time in senior HR leadership, I saw how decisions about developmental opportunities could shape who was positioned to advance. As a leadership vacancy approached, some experienced employees were offered temporary higher-level assignments while others were not.

When the permanent position was advertised, those who had received the assignments could document higher-level work. Others did not meet the initial qualification screen and never reached an interview. The staffing specialist could explain which qualifications their applications had not established, but had not been involved in deciding who received the earlier opportunities.

The experience reinforced a lesson that applies well beyond any single hiring process: A selection process can follow its rules and still leave an important question unanswered. Who had a fair chance to gain the experience needed to compete?

The consequences outlasted the selection. Morale deteriorated, and experienced employees who had been excluded eventually left, taking institutional knowledge with them. Leadership turnover continued.

I’ve served as a federal chief human resources officer. Across 30 years in HR and executive leadership, including CEO, COO and CAO roles, I’ve learned to look past a selection file and ask how management helped create the candidate pool.

That matters now.

On Oct. 19, the Office of Personnel Management finalized a rule eliminating the governmentwide 52-week time-in-grade restriction for covered competitive-service General Schedule promotions at GS-6 and above, effective January 19, 2027.

I support removing a calendar barrier that can prevent qualified people from advancing. Time served is not proof of readiness.

But removing time-in-grade doesn’t waive the one-year specialized-experience requirement in most GS qualification standards. Nor does it eliminate merit-promotion procedures. Agencies may also maintain written, job-related and consistently applied progression requirements.

Consider a GS-12/13 career ladder. Someone hired at GS-12 on the strength of a year of GS-11-equivalent experience doesn’t automatically qualify for GS-13 after 30 days. GS-13 generally still requires a year of GS-12-equivalent specialized experience. That experience may have been earned before entering the GS-12 grade, including through creditable details or work outside government. The agency must verify it. Career-ladder progression also depends on performance, available higher-level work, readiness, funding and established promotion potential.

The danger isn’t that the rule authorizes unqualified promotions. It doesn’t. The danger is mistaking managerial preference for documented readiness—or confusing a compliant final screening with a fair path to qualification.

OPM acknowledges this problem in the final rule. Supervisors can influence who receives developmental assignments and who subsequently becomes competitive. The 52-week waiting period didn’t distribute those opportunities fairly. Eliminating it won’t either.

As a former CHRO, here’s the control I’d insist on:

Before a foreseeable leadership vacancy opens, HR and the selecting official should review how career-building opportunities were distributed.

Five questions should guide that review.

1. Who had a chance to gain the experience?

Identify higher-level details, temporary promotions, acting assignments and relevant training. Check how employees learned of them, how interest was considered and why assignments were awarded. Follow applicable competition rules.

2. Does the claimed experience actually meet the standard?

HR must examine duties performed, their level and duration, and supporting documentation, not just acting titles or management endorsements. Time-in-grade and specialized experience are different requirements.

3. Can an accelerated promotion be justified?

For career-ladder advancement, verify the occupational qualifications, performance, documented progression criteria, higher-level work, readiness and funding. Apply those standards consistently.

4. Will management own its part of the decision?

Staffing should explain the qualification determination. Managers must explain the earlier decisions that shaped who had qualifications to present. Sending employees back and forth isn’t accountability.

5. What does the agency lose when employees see no path forward?

Look at patterns in developmental access, departures and succession gaps. Losing institutional knowledge can damage a mission long after the vacancy closes.

These are management safeguards, not new governmentwide mandates. OPM declined to impose additional promotion boards or public reporting. Agencies can use existing succession-planning and HR processes.

No employee is owed a promotion. But leaders should be able to show that readiness was evaluated on evidence and employees had a fair chance to develop it.

The vacancy may be the last decision employees see. It should not be the first one leadership can explain.

Noël Tarquinii, SHRM-SCP, is a former federal chief human resources officer with 30 years of HR and executive leadership experience. She is the founder of HR Armor and Workplace Intelligence.