The Office of Personnel Management has formally imposed a governmentwide, temporary hiring freeze on Senior Executive Service members — a move that’s usually customary during presidential transitions.

The announcement comes less than two weeks before the start of the incoming Biden administration on Jan. 20. It also coincides with statements President Donald Trump made earlier this week, which said he would “ensure a smooth, orderly and seamless transition of power.”

Specifically, OPM has said it will temporarily stop processing an agency’s SES Qualifications Review Board (QRB) cases, meaning agencies can’t finalize the hiring or placement of prospective candidates to positions within the Senior Executive Service.

A moratorium on SES QRB cases is considered a traditional transition activity, designed to give incoming agency heads the time and space to make decisions about executive resources and set his or her own priorities.

“This is done to ensure the incoming head of the agency will have the full opportunity to exercise his or her prerogative to make or approve executive resources decisions that will impact the agency’s performance during his or her tenure,” Dennis Kirk, OPM’s associate director of employee services, said Friday afternoon in a memo to agency heads and chief human capital officers. “To that end, OPM has imposed a moratorium on the processing of a particular agency’s SES QRB cases when the head of that agency departs for any reason, effective immediately upon the effective date of his or her departure. A QRB moratorium will also be imposed when the head of an agency announces his or her intention to leave that office, effective immediately upon that announcement.”

The moratorium is effective Jan. 8, Kirk said.

During this time, OPM will not accept any new QRB cases. It will also suspend the usual 90-day deadline for agencies to submit QRB cases.

OPM’s latest guidance does not directly mention Trump or President-elect Joe Biden.

It simply describes OPM’s plans to impose the QRB moratorium and explains past practices for ordering temporary SES hiring freezes when agency heads have departed or announced plans to resign.

Agencies can ask OPM to resume processing SES QRB cases once a new agency head has been appointed, according to the guidance.

OPM will continue to review and process QRB cases submitted before Jan. 8, the agency said. It also requests exceptions to the temporary SES hiring freeze on a case-by-case basis.

“Requests for exceptions should be signed by the agency head or the official who is designated to act in the agency head’s absence and must specifically address the potential for adverse impact on national security, homeland security or a critical agency mission, program or function if a particular SES candidate is not immediately certified,” Kirk said.

OPM last imposed a moratorium on SES QRB cases on Dec. 7, 2016. The date coincided with the deadline former President Barack Obama gave agency heads to submit their letters of resignation, Beth Cobert, OPM’s acting director, said in guidance announcing the coming hiring freeze, which the agency issued three weeks earlier on Nov. 18.

Good government groups like the Partnership for Public Service expressed concern late last year OPM hadn’t yet provided some of the usual support it offers to federal agencies during presidential transitions. It pointed to lack of an SES QRB moratorium or a new transition guide for agencies as examples.

OPM later published a new guide for the 2020 transition on Dec. 21, 2020.

Instead, the Partnership said it feared OPM had become politicized and distracted by efforts to implement the president’s Schedule F executive order, which allows agencies to reclassify career federal employees in certain policy-making positions to a new class of quasi-political appointees.

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