Schedule Policy/Career and the Social Security Administration: History, Implications, and Limitations
By Elisa Walker, Senior Fellow,
National Academy of Social Insurance
May 2025
Summary
The Trump Administration has proposed to create a new category of excepted service positions called “Schedule Policy/Career” (Schedule P/C, formerly called Schedule F). Under President Trump’s January 2025 executive order and the Office of Personnel Management (OPM)’s proposed regulations issued last month, the President would designate certain “policy-influencing” positions as Schedule P/C. Positions in this category would be excepted from the adverse action protections that apply to competitive service positions, but would continue to be hired competitively and to be considered career (not political) employees. OPM estimates that about 50,000 positions, or two percent of Federal employees, would ultimately fall under Schedule P/C.
After a brief background on Schedule P/C, this brief explores the text and the legislative history of the statutory limit on SSA’s excepted service positions. It concludes that any positions designated as Schedule P/C would be subject to the statutory limit in the Social Security Act–which expressly prohibits the Social Security Administration (SSA) from having more than 20 full-time positions that are excepted from the competitive service due to their “confidential, policy-determining, policy-making, or policy-advocating character.”
As the Trump Administration moves toward implementing Schedule Policy/Career (Schedule P/C), this statutory language means that–legally–the new schedule cannot be widely implemented at SSA. An alternate proposal from a House committee would avoid a direct conflict with this statutory language, but would still be inconsistent with the spirit of the law.