OPM’s Annual Staffing Plan rule (5 CFR part 250), explained
OPM’s final rule of October 29, 2026 replaces federal human capital plans, reviews and HRStat with Annual Staffing Plans, quarterly updates to OPM and OMB, a Strategic Hiring Committee and a signed certification. It takes effect on November 30, 2026.
What the rule changes
Part 250 of title 5 of the Code of Federal Regulations sets how federal agencies plan, run and evaluate the management of their people. Until this rule, its subpart B was built around the Human Capital Framework, a Human Capital Operating Plan, Human Capital Reviews with OPM and quarterly HRStat reviews, and its subpart C required 16 core questions in every agency’s annual employee survey [1].
OPM proposed the changes on July 2, 2026 (91 FR 40435) and published the final rule on October 29, 2026, effective November 30, 2026 [1]. The rule keeps the Human Capital Framework and its four systems and standards, and replaces the planning and review machinery around it with staffing plans that run on the budget calendar. It also removes the words on workforce diversity from the regulatory text [1].
The Annual Staffing Plan
Under the new section 250.205, each agency writes an Annual Staffing Plan that lines up with its Agency Strategic Plan, Annual Performance Plan, budget, the President’s Management Agenda and the Human Capital Framework. It names workforce priorities, hiring goals and staffing strategies [1].
What the plan must contain
- Metrics, frameworks and criteria for judging the agency’s current and future workforce and staffing needs.
- Hiring aimed at skills gaps, service delivery and succession, so that the year’s new appointments land in the highest-need areas.
- Specific plans and goals, with measurable targets, for each of the four Human Capital Framework systems and standards.
The plan must also consider efficiencies from restructuring, fewer management layers, removing duplicate or nonessential functions and positions, consolidating administrative functions, cutting unnecessary or low-value contractor positions, performance management, reassignments, redistributing work, process improvement and the adoption of technology [1].
When it is written and who signs off
The plan follows the agency’s strategic planning and budget formulation cycle under OMB Circular A-11, Part 6 [1] [3]. The Chief Human Capital Officer coordinates it with the Chief Financial Officer, the Chief Operating Officer and senior leadership. Agencies prepare it at the start of each fiscal year with OPM and OMB, may amend it during the year, for example after appropriations are enacted, and send OPM and OMB an update at the beginning of every quarter showing progress and explaining significant variances [1]. Executive Order 14356 had already set this annual cycle and the Strategic Hiring Committee; OPM’s July 30, 2026 guidance asked agencies to write their fiscal year 2027 plans, with a detailed hiring forecast by quarter and component, to the proposed section 250.205 so that they would comply once the rule was final [2].
Reviews: yearly with OPM and OMB, quarterly inside the agency
OPM and OMB hold an Annual Staffing Review with each agency on how the plan was carried out and how far the agency got toward its workforce goals (section 250.206). Inside the agency, the Chief Human Capital Officer runs Quarterly Staffing Plan Performance Reviews with the Performance Improvement Officer and the Strategic Hiring Committee, and their findings go into the quarterly updates. An agency may fold these reviews into the quarterly performance reviews it already holds (section 250.207) [1].
The Strategic Hiring Committee
Section 250.204(f) requires every agency to set up and keep a Strategic Hiring Committee to oversee hiring. It must include the Deputy Secretary or equivalent, the chief of staff to the agency head and the Chief Human Capital Officer, and it must keep hiring consistent with mission needs and the Annual Staffing Plan [1].
The certification, and why it reaches IT
Section 250.204(e) requires each agency to make sure its internal delegations, organizational structure, internal policies and technological systems give the Chief Human Capital Officer enough visibility, oversight and control to carry out the duties in 5 U.S.C. 1401 and 1402(a), and to reach the information described in 5 U.S.C. 1402(b) efficiently [1].
As part of each Annual Staffing Review, the agency head signs a written statement to OPM certifying that the Chief Human Capital Officer has that visibility, oversight and control. Where the certification finds a gap, the agency must document it and give a timeline for closing it [1]. Because the rule names technological systems, an HR system or component database the Chief Human Capital Officer cannot query is a gap that has to be written down, and closing it is work for the agency’s IT organization as well as its HR office.
The employee survey
The rule cuts the prescribed survey questions to 10, listed in section 250.302(a)(2). They cover communication of goals, cooperation, recognition of performance differences, supervisor feedback and accountability, line of sight to agency goals, empowerment, reporting suspected violations without fear of reprisal, and how poor performance is handled [1].
Each agency publishes its own results on its website unless the agency head decides that doing so would harm national security, may decide what the public disclosure contains, and must send the results to OPM and OMB within 90 days after the survey closes (section 250.303) [1].
Dates to plan around
- November 30, 2026: the rule takes effect.
- Start of each fiscal year: the Annual Staffing Plan, prepared with OPM and OMB on the A-11 budget formulation cycle.
- Beginning of each quarter: an update to OPM and OMB on progress and significant variances.
- Each Annual Staffing Review: the agency head’s signed certification on the Chief Human Capital Officer’s visibility, oversight and control.
- Within 90 days of each survey closing: results to OPM and OMB.
Our weekly series looked at what the rule meant in the week it appeared: OPM’s staffing-plan rule tucked a systems certification into a personnel regulation. The steps an agency can take now are in the companion checklist.
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