Checklist: getting an agency ready for OPM’s staffing-plan rule

The checklist

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1. Step 1 Confirm the Strategic Hiring Committee exists with the members the rule names, and write down what it approves.

   Agency head’s office

   Required by section 250.204(f): the committee must include the Deputy Secretary or equivalent, the chief of staff to the agency head and the Chief Human Capital Officer, and must keep hiring consistent with mission needs and the Annual Staffing Plan [1]. OPM’s guidance describes it reviewing and approving position creation and hiring actions under Executive Order 14356 [2].

2. Step 2 List every system that holds workforce data, from the core HR system to component databases and spreadsheets, and record whether the Chief Human Capital Officer can query each one.

   CHCO with the CIO

   Section 250.204(e) requires the agency’s delegations, structure, policies and technological systems to give the Chief Human Capital Officer the visibility, oversight and control the role needs, including efficient access to the information in 5 U.S.C. 1402(b) [1]. The inventory is our suggested way to find out where that access is missing.

3. Step 3 Draft the agency head’s certification now, with a written gap for each system or delegation the inventory flagged and a date to close it.

   CHCO, General Counsel

   Required by section 250.206(b): as part of each Annual Staffing Review the agency head signs a statement to OPM on the Chief Human Capital Officer’s visibility, oversight and control, and any gap must be documented with a remediation timeline [1]. Drafting it early lets the remediation dates go into IT plans and budgets.

4. Step 4 Check the fiscal year 2027 Annual Staffing Plan against the final text of section 250.205; it was written to the proposed text.

   CHCO with the CFO

   OPM asked agencies to write their fiscal year 2027 plans to the proposed section 250.205 [2]. The final rule ties the plan to the budget formulation cycle under OMB Circular A-11, Part 6, and requires coordination with the Chief Financial Officer and Chief Operating Officer [1] [3]. The plan must also set measurable targets for each of the four Human Capital Framework systems and consider the efficiencies the rule lists.

5. Step 5 Make sure the plan’s hiring forecast runs by quarter and by mission area or component, with billets and budget reserved.

   CHCO, component HR offices

   OPM’s guidance requires a detailed hiring forecast by quarter and component: total hires, external hires against internal placements, mission-critical, technology and early career hires, with the associated billets and budget [2].

6. Step 6 Measure the plan against OPM’s fiscal year 2027 hiring targets and write down how each will be met.

   CHCO

   OPM’s guidance sets governmentwide targets for fiscal year 2027, including at least 60 percent of external competitive-service selections from shared certificates and at least 33 percent early career hires among external hires, and asks for target locations, strategies, milestones and accountable officials for each [2].

7. Step 7 Name the technology billets the agency plans to fill through Tech Force shared certificates, the Early Career Talent Network and the CyberAI Scholarship for Service, with a point of contact for each.

   CHCO with the CIO and CISO

   OPM’s guidance asks agencies to reserve billets and budget for technology talent, including AI, data science, software engineering and cybersecurity roles, and to identify these channels and contacts in the plan [2].

8. Step 8 Decide where the Quarterly Staffing Plan Performance Review sits, and book the first one before the next quarterly update is due.

   CHCO with the Performance Improvement Officer

   Section 250.207 has the Chief Human Capital Officer run these reviews with the Performance Improvement Officer and the Strategic Hiring Committee, allows them to be folded into the agency’s existing quarterly performance reviews, and requires their findings to go into the quarterly update that section 250.205(e) sends to OPM and OMB at the beginning of each quarter [1].

9. Step 9 Rewrite internal HR policies, delegations and templates that still refer to the Human Capital Operating Plan, Human Capital Reviews or HRStat.

   CHCO policy staff

   The rule removes those terms from the definitions in section 250.202 and replaces HRStat with Quarterly Staffing Plan Performance Reviews in section 250.204 [1]. Updating the documents that point to them is our suggestion, so that staff work to the rule that applies.

10. Step 10 Rebuild the annual employee survey around the 10 prescribed questions, decide what the public release will show, and diary the 90-day deadline for sending results to OPM and OMB.

    CHCO survey team, with privacy and security staff

    Section 250.302(a)(2) lists the 10 questions; section 250.303 has each agency post its results publicly unless the agency head finds a national security harm, lets the agency decide what the disclosure contains, and requires results to reach OPM and OMB no later than 90 days after the survey closes [1].