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1 October 2025

Federal Employees, Prepare: OPM's Suitability Overhaul Is Coming

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Tully Rinckey

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It was back in March of 2025 that President Trump directed OPM to revise its suitability rules. But it was not until June that the actual text became publicly...
United States Employment and HR
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It was back in March of 2025 that President Trump directed OPM to revise its suitability rules. But it was not until June that the actual text became publicly available for comment. Assuming these changes—expansion to current employees, expansion of suitability criteria, and expedited removal process—move forward, they are unlikely to go into effect in 2025.

That means Federal employees still have time to prepare. It is advised that they do so. If you have made it this far into the current administration's personnel overhaul, you are already aware. Now you must be even more proactive about protecting your career in Federal service.

How Can Federal Employees Protect Themselves?

Shifts in political weather patterns come with casualties, many unavoidable. But here are four best practices for Federal employees committed to securing their jobs:

Know Who Will Speak for You

At every point in your career, you need to have 5-10 people who will 'speak for you.' Absent such supporters, it is either you personally who has to speak for yourself—and you are biased, obviously—or someone you pay, like an attorney. The best guidance for choosing sponsors is to answer the question: For whom have I been useful? Having professional support is all about what you have done for others. When the chips are down, no one wants to listen to a self-destructive narcissist. And trust me: HR and Security Office are looking for self-destructive narcissists in the workplace, every day.

Establish Clear Expectations and Maintain Records

Maintain your own personal security and personnel files, at home, off the employer network. If your work is of such a nature that the information is controlled or classified, strive to get unclassified and uncontrolled summaries of the same; thank you letters from customers can substitute for official documents. On the personnel side of the ledger, get a copy of your official personnel record every three years, and ensure you are familiar with and accept everything filed in the official record. Do the same for your security file every two years.

If you cannot describe what poor, acceptable, above-average, and excellent performance of your job looks like on a daily, weekly, monthly, and annual basis, take time to understand your position description and performance plan. If you cannot list your known security liabilities and provide mitigating evidence, read SEAD-4 and begin that self-assessment. If necessary, request clarification from your supervisors and document these exchanges. E.g., My current understanding of my role is this, please advise on any required adjustments. As your evaluation criteria becomes stricter, so too must your self-evaluation practices.

Compile Performance Reviews and Keep a Brag File

If you perform exceptionally well or accomplish anything notable on the job, note that. Maintain a brag file on yourself. Keep it organized. Make updating your brag file part of your daily routine. If management asks what you have accomplished this month, you should be able to answer that question accurately and in documented detail. The brag letter file from satisfied "customers" should also include civic engagement and community involvement. There is an expectation in the security community, at least, that a well-balanced and healthy Federal employee is involved in their community. The same is true, to a lesser extent, in the HR Office.

Stay on Top of Your Finances

File and pay your taxes on time. Pay your bills. If you have debt, make a documented plan to resolve that debt responsibly. Do not rely on others to work out your debt issues; the Federal government expects you to show maturity in that regard. If you come by a large sum of money or make a big-ticket purchase, be prepared to explain and justify it—accurately.

Know Whom to Talk to and Whom NOT to Talk To

Do not count on management to appropriately empower you with information regarding suitability. Neither your agency, nor OPM are concerned with your career prospects. Their concern is the efficiency, integrity, and rigor of the government and its workforce. They are not invested in your individual flourishing. You are of individual interest when you are a liability. Your suitability concerns and questions are best suited for an attorney: ideally, one with experience in the intricacies of Federal credentialing, suitability, and clearance.

Educate Yourself on Suitability Guidelines and Adjudication

When your career hinges on your suitability, and that suitability is determined by a set of standards, those standards should be etched in your memory. Security clearance holders are advised to study SEAD-4 to maintain awareness of their behavioral expectations and protect their careers. Federal employees would do well to take the suitability factors (found in 5 C.F.R. 731.202(b)) just as seriously.

Trusted Workforce 2.0 does not apply solely to individuals cleared to access classified information and restricted materials. Federal employees who are expected to prove and maintain their suitability may find themselves subject to continuous vetting. Fail to pay your taxes on time? Inherit $20 thousand? Use marijuana? Get pulled over for a DUI? Assume the Federal government knows about it. Do not let them be the ones to bring up any derogatory information.

Stay on Top of Policy Changes

The suitability factors used to evaluate you upon hiring will be expanding. Meaning, you will be appraised by more stringent criteria after OPM implements these rule changes. Potential disqualifiers will soon include:

  1. Not complying with legal obligations, including not filing your tax returns on time;
  2. Anything that would preclude regular Federal service, like a lack of U.S. citizenship;
  3. Noncompliance with nondisclosure obligations;
  4. Theft, misuse, or negligence of Government resources or equipment.

Conclusion

It would not hurt to live your life as though you were aiming for a security clearance. There is a reason agencies will use suitability determinations as a backdoor prescreening metric for security clearance eligibility. If you do not qualify for suitability, you will not qualify for the more intensive security clearance.

As practicable options for employees to appeal unfavorable decisions diminish, proactivity becomes the move. That is not to say it is easy. But if you are invested in keeping your career in Federal service, overcaution will serve you well.

Dan Meyer, Esq. is a Partner at Tully Rinckey PLLC's Washington, D.C. office and has dedicated more than 25 years of service to the field of Federal Employment and National Security law as both a practicing attorney and federal investigator and senior executive. He is a lead in advocating for service members, Federal civilian employees, and contractors as they fight to retain their credentialing, suitability and security clearances.

Federal employment is subject to laws and regulations that differ significantly from those in the private sector; consulting with a federal employment lawyer can make all the difference. Tully Rinckey's team of dedicated federal employment attorneys is available to assist you today. Please call (888) 488-7041 to schedule a consultation, or schedule a consultation online.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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