Project 2025's Civil-Service Overhaul: Gutting Independent Oversight Under the Banner of 'Performance'
Project 2025's personnel proposals for the Office of Personnel Management (OPM) — presented as recommendations, not enacted rules — would concentrate disciplinary power over federal employees in the hands of political executives, while reintroducing Trump's Executive Order 13839, which buried whistleblower-retaliation review as a subordinate clause in an HR process rather than a statutory protection. Together, these proposals would create the structural conditions to purge career analysts who deliver unwelcome findings to political leadership.
The language here is managerial and bloodless — merit pay, performance appraisals, corrective action timelines — but the operational logic is straightforwardly political. By mandating that political executives build policy goals directly into employee appraisals and warning against delegating to senior career managers, Project 2025 inverts the foundational principle of the Pendleton Civil Service Reform Act: that federal employees serve the public, not the party in power. When a career defense analyst's annual rating is written by a Schedule F-style political appointee whose own career depends on ideological alignment, the analyst faces a structural choice between honest assessment and self-preservation.
The proposed resurrection of Executive Order 13839 is particularly telling. The order's stated purpose was faster discipline for poor performers, but buried in its list of mandates — reproduced verbatim in the source chapter — was a requirement to 'reevaluate procedures for agencies to discipline supervisors who retaliate against whistleblowers.' That clause is not a protection. It is a bureaucratic demotion of whistleblower retaliation from a statutory violation to an internal HR process subject to political-executive review. The Intelligence Community Whistleblower Protection Act exists precisely because internal reevaluation procedures controlled by the same chain of command that committed the retaliation are not protection at all.
The DOD context makes this acute. The Department has failed every financial audit since audits began in 2018, with FY2023 identifying unsupported journal entries totaling trillions of dollars. The career comptrollers, auditors, and program analysts who flag those discrepancies are exactly the workforce this chapter targets for accelerated discipline and political-executive supervision. Overclassification — documented by the Federation of American Scientists' Secrecy News across multiple ISOO annual reports — already shields enormous tranches of defense spending from scrutiny; a politicized appraisal system adds a human deterrent on top of the classification barrier, ensuring that the employees most likely to surface problems are also the most exposed to retaliation dressed as performance management.
The reform that accountability demands runs in exactly the opposite direction: strengthen the Merit Systems Protection Board's independence, codify whistleblower retaliation as a per se prohibited personnel practice with external adjudication, require that DOD inspector general findings trigger automatic congressional notification rather than internal review, and remove political appointees from the direct appraisal chain for intelligence and audit personnel. Performance accountability is legitimate and necessary — but it must be accountability to law and mission, not to the ideological preferences of whichever political faction controls the executive branch at a given moment.
Original source — excerpted
project2025 Project 2025 ch. 4: Department of Defense (pp 106-107)"— 73 — Central Personnel Agencies: Managing the Bureaucracy that would change regularly to depress cheating. President Donald Trump’s OPM planned to implement such changes but was delayed because of legal concerns over possible disparate impact. Courts have agreed to review the consent decree if the Uniform Guidelines on Employee Selection Procedures setting the technical requirements for sound exams are reformed. A government that is unable to select employees based on KSA-like test qualifications cannot work, and the OPM must move forward on this very basic personnel management obligation. The Centrality of Performance Appraisal. In the meantime, the OPM must manage the workforce it has. Before they can reward or discipline federal employees, managers must first identify who their top performers are and who is performing less than adequately. In fact, as Ludwig von Mises proved in his classic Bureaucracy,14 unlike the profit-and-loss evaluation tool used in the private sector, government performance measurement depends totally on a functioning appraisal system. If they cannot be identified in the first place within a functioning appraisal system, it is impossible t…"