Schedule F Comes to Science: How Reclassifying Grant Reviewers Threatens the Independence of Federal Research Funding

Of the 40,500 public comments the Office of Personnel Management received on its proposed rule to reclassify certain federal employees, 94% were opposed. OPM finalized the rule anyway.

The policy, known formally as Schedule Policy/Career and informally as the revival of Schedule F, strips traditional civil service protections from federal workers whose roles "influence public policy." In most agencies, that language targets regulatory staff and political advisors — positions where the boundary between career expertise and political judgment has always been contested. But at the agencies responsible for distributing tens of billions of dollars in research grants each year, the designation reaches into territory that has been deliberately insulated from political pressure for decades: the peer review process itself.

OPM's own regulatory text defines the affected work to include "drafting of funding opportunity announcements, evaluation of grant applications, or recommending or selecting grant recipients." At the National Institutes of Health alone, that description covers hundreds of program officers, scientific review officers, and advisory council members who collectively manage a portfolio exceeding $47 billion in annual appropriations. At the National Science Foundation, the Department of Energy's Office of Science, and the research arms of the Department of Defense, the same logic applies to the career staff who evaluate and recommend funding for the nation's foundational scientific work.

What Changes for Grant-Making Staff

Employees reclassified into Schedule Policy/Career lose three specific protections that have defined the federal career service since the Pendleton Civil Service Reform Act of 1883.

First, they lose "adverse action" protections — the procedural safeguards that require agencies to provide written notice, an opportunity to respond, and a demonstrated connection between the employee's performance and any disciplinary action. Under the new classification, supervisors can initiate removal with substantially fewer procedural requirements.

Second, they lose "performance-based action" protections, which previously required agencies to demonstrate that an employee's work failed to meet established performance standards before taking action. In the new category, performance evaluations carry different procedural weight — and critics argue that "performance" can be redefined to include ideological alignment with administration priorities.

Third, reclassified employees can no longer appeal discipline to the Merit Systems Protection Board, the independent agency that has served as the primary check against politically motivated personnel actions in the federal workforce since 1978.

In practical terms, these employees become at-will workers. They can be terminated more easily, reassigned with less process, and subjected to performance reviews with fewer external checks on the reviewer's judgment. OPM has characterized this as essential to ensuring "the ability to implement an agenda endorsed by the American people free from antidemocratic, unaccountable bureaucratic resistance."

The Scale Is Unclear — Deliberately

OPM initially estimated that approximately 50,000 federal workers nationwide would fall into Schedule Policy/Career. The Association of American Medical Colleges contested that figure, suggesting the actual number could reach 200,000. Neither OPM nor the major research agencies have specified how many grant-making employees they plan to reclassify.

This ambiguity is itself consequential. At NIH, program officers serve as the primary point of contact between the agency and funded researchers. They manage portfolios of grants, provide scientific guidance to applicants, convene study sections, and shape the research priorities within their institutes. Scientific review officers organize and oversee the peer review panels that score grant applications — the panels whose evaluations determine which research gets funded and which does not.

At NSF, program directors perform a comparable function: managing the merit review process, balancing reviewer recommendations with portfolio-level strategic considerations, and making funding recommendations to division directors. At DOE's Office of Science, program managers oversee the evaluation of proposals across physics, chemistry, materials science, computing, and energy research.

None of these agencies have publicly disclosed how many of these positions they intend to reclassify. The uncertainty itself creates a chilling effect. As one NIH program officer told STAT News in February: the fear is not necessarily that you will be fired, but that the threat of firing will shape which grants you recommend and which you don't.

The Peer Review Firewall

The American scientific enterprise rests on a structural assumption so fundamental that most researchers rarely think about it: that federal research funding decisions are made on the basis of scientific merit, not political preference.

This is not a philosophical abstraction. It is a set of concrete procedural protections. NIH's Center for Scientific Review manages approximately 80,000 grant applications annually through roughly 180 study sections — panels of external scientists who evaluate proposals using published criteria (significance, innovation, approach, investigators, environment). The study section scores are advisory; program staff and advisory councils make final funding decisions. But the entire architecture is designed to ensure that the people evaluating the science are insulated from the people setting political priorities.

Schedule Policy/Career does not formally change peer review procedures. Study sections will still convene. External reviewers will still score applications. But the career staff who organize those reviews, set review criteria, make portfolio-level funding recommendations, and ultimately decide which applications to fund at the margins — those staff now serve at the pleasure of political appointees in a way they did not before.

The concern is not that a political appointee will sit in a study section and score applications. It is subtler and more systemic. When the program officers who shape funding opportunity announcements know that their jobs depend on political alignment, the announcements themselves may shift. When scientific review officers know that recommending funding for research on politically sensitive topics could trigger scrutiny, they may exercise more caution. When advisory council members understand that their positions lack the protections that previously encouraged independent judgment, the advice they offer may become less independent.

The Intersection With Executive Order 14332

Schedule Policy/Career does not exist in isolation. It arrives in a grant-making environment already reshaped by Executive Order 14332, which requires senior political appointees to review funding opportunity announcements and discretionary awards for "consistency with agency priorities and the national interest." Together, these two policies create a system in which the people who write the solicitations, the people who evaluate the applications, and the people who recommend funding all operate under forms of political oversight that did not exist two years ago.

The combination matters because the grant-making process involves dozens of judgment calls that are invisible to applicants. Which topics get solicited. How review criteria are weighted. Where the payline falls. Which competing renewals receive priority. These decisions have always involved human judgment, but the judgment was exercised by career scientists whose job security depended on competence, not compliance.

At NIH, the effects may compound an already severe funding crisis. With grant awards down 74% compared to historical baselines, the agency is already under extraordinary pressure. OMB delayed fund releases for months, and when Director Jay Bhattacharya pledged to spend the full $48.7 billion appropriation by fiscal year's end, he did so against a backdrop of staff uncertainty and institutional disruption that makes rapid, high-quality grant administration harder, not easier.

The Legal Challenge

Multiple unions, Citizens for Responsibility and Ethics in Washington, Democracy Forward, and Public Employees for Environmental Responsibility have filed suit challenging Schedule Policy/Career on constitutional and statutory grounds. The plaintiffs argue that the policy violates the Due Process Clause, exceeds OPM's statutory authority, and conflicts with the Civil Service Reform Act's protections against politically motivated personnel actions.

The legal challenge faces an uncertain path. The Supreme Court's recent jurisprudence on executive power and agency discretion has generally favored presidential authority over procedural constraints. A federal district court in 2025 blocked an earlier, narrower version of the policy — the original Schedule F executive order — but the current iteration was issued through OPM rulemaking rather than executive order, giving it different legal standing.

For the research community, the legal timeline matters less than the behavioral effects. Even if the policy is ultimately struck down, the period of uncertainty may be long enough to alter the composition and culture of the federal grant-making workforce. Program officers who can find positions in academia or industry may leave. Those who stay may internalize a more cautious approach to funding decisions. The institutional memory and scientific judgment that takes years to develop does not rebuild quickly.

What Grant Seekers Should Know

The reclassification does not change what you submit or how proposals are scored. Study section criteria remain the same. NIH paylines, NSF merit review principles, and DOE evaluation frameworks continue to operate under their existing published procedures.

But the environment in which those procedures operate is shifting. If you are submitting proposals in politically sensitive research areas — climate science, public health, certain social sciences, diversity-related programming — awareness of the institutional dynamics is part of responsible proposal strategy. This does not mean self-censoring. It means understanding that the people evaluating your work are under pressures that did not exist in prior funding cycles.

For institutions, the priority is advocacy. Professional associations, university government relations offices, and research advocacy organizations are the primary channels through which the research community can influence how — and whether — Schedule Policy/Career is implemented at individual agencies. The public comment period is closed, but congressional oversight, appropriations riders, and litigation outcomes will shape the policy's ultimate reach.

The independence of federal research funding has never been absolute. Political priorities have always shaped which agencies get funded, which programs grow, and which areas of science receive national attention. But the structural insulation of the people who evaluate and recommend individual grants — the program officers, the review staff, the advisory council members — has been one of the defining features of the American research enterprise. Schedule Policy/Career puts that insulation under pressure in ways that will play out over years, not months, and the consequences for who gets funded and what gets studied may be with us long after the current administration ends.

Whether you are navigating a shifting NIH payline or targeting NSF programs under new review pressures, tools like Granted can help you build proposals calibrated to current conditions — because the science still has to speak for itself, even when the institution around it is changing.