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The Whitfield Memo

MemorandumNo. 018

To
Federal employees, retirees and government contractors
From
Whitfield
Date
Re
OPM's September 30 guidance on time-to-hire under the Merit Hiring Plan: the 80-day standard, its milestones and the vetting steps inside it

OPM's 80-Day Hiring Standard Now Runs to Your First Day, Not Your Offer

OPM's September 30 time-to-hire guidance splits the 80-day goal into 66 days to a tentative offer, two days to accept and 14 days to start. The 2025 Merit Hiring Plan had counted only to the offer.

Bottom line

“Agencies must manage all hiring actions within an overall 80-calendar-day timeframe” [1]. That sentence, from OPM’s September 30 memo to chief human capital officers, carries a change the number hides. The 2025 Merit Hiring Plan counted 80 days to the initial offer [3]. The new guidance counts to the first day on the job, which leaves 66 days to reach a tentative offer [1, 2]. For applicants, the promise is a shorter wait from offer to start. For HR offices, the target just got tighter.

What happened

The memo. Veronica E. Hinton, OPM’s associate director for workforce policy and innovation, signed the memo on September 30 [1]. It carries out Executive Order 14170 and the Merit Hiring Plan, and attaches a five-page guidance document [1, 2].

The milestones. The guidance breaks the 80 days into three stages [2]:

Stage Target
Validated hiring need to tentative job offer 66 days
Candidate accepts tentative offer within 2 days
Acceptance to entry on duty within 14 days

Within two days of acceptance, agencies should notify the vetting office, start the OF-306 review and launch whatever vetting the position requires [2].

How we got here. Executive Order 14170, signed January 20, 2025, told the White House to produce a hiring plan that would “decrease government-wide time-to-hire to under 80 days” [4]. The Merit Hiring Plan followed on May 29, 2025. It said the goal “refers to time to initial offer,” while adding that it would also seek to reduce vetting delays [3]. In March 2026, OPM’s suitability office told agencies to expand preliminary determinations and electronic adjudication, and to seek three-day vetting where reciprocity applies [5]. The September 30 memo tells agencies to read the new guidance alongside that March material [1].

Where the government stands. OPM’s own fiscal 2024 baseline was 101 days, against an 80-day target for fiscal 2026 and 2027 [6]. GAO’s inspector general, citing OPM’s dashboard, reported fiscal 2024 averages of 72.1 days for contracting, 75.5 days for human resources management and 94.6 days for information technology management across CHCO Act agencies [7]. Those dashboard figures predate the new end-to-end definition.

The case for speed, and the case for care. OPM frames timeliness as compatible with quality. Its guidance says agencies should improve “without sacrificing quality, fairness, or legal compliance” [2]. It lists hiring models it estimates at roughly 46 days for a single assessment, 59 for multiple assessments and 66 for subject matter expert review [1, 2].

The counterargument appears in GAO’s inspector general report on GAO’s own hiring. There, GAO’s human capital office argued that its longer target allows more time for qualification reviews, subject matter expert panels and multiple interview rounds to obtain “well-qualified staff” [7]. The inspector general answered that a long process risks losing those same candidates to other employers [7]. GAO is not bound by OPM, but the trade-off is the same one every executive agency now has to manage inside 66 days [7].

What it means for you

Applicants holding a tentative offer. The 14-day window from acceptance to entry on duty is the part most likely to change your experience [2]. Under the guidance, an HR point of contact should be assigned to you and should answer questions about salary, locality pay, benefits and next steps within one business day [2]. Agencies are told to tell candidates early which forms they will need, so you can start gathering information [2].

Applicants returning to federal service. The Merit Hiring Plan asks agencies to seek three-day vetting for people who left within three years, have no known unresolved derogatory information and return at the same level or lower [3]. The new guidance points agencies to transfer of trust and preliminary determinations for the same purpose [2].

Current employees applying elsewhere. Reporting covers merit promotion actions as well as external hires [1, 2]. The guidance says nothing about when your current agency must release you.

HR specialists. The guidance asks for operational planning at least annually, standardized position descriptions and assessment materials kept ready before a need arises [2]. Two operational details are worth noting. “Incorrect assignment levels are a common source of delays,” the guidance says of position risk and sensitivity designations [2]. And the Defense Counterintelligence and Security Agency rejects about 3.4 percent of investigation requests; “Rejected requests add over a week, on average, to the process” [2].

Hiring managers. You are expected to define assessment needs before posting, schedule your part in assessments early and move promptly on interviews [1, 2]. Each agency should designate an office or official to track time-to-hire and review results with leadership [2].

Contractors. The guidance covers federal appointments only [1, 2]. It does not address contractor onboarding or contractor vetting timelines.

  • Whether “must” in the cover memo or “should” in the attachment is the operative word [1, 2]. The memo uses the stronger verb; the guidance it transmits uses the softer one.
  • What counts as a “validated hiring need,” the date that starts the clock [2]. GAO’s inspector general found that inconsistent start dates made GAO’s own numbers unreliable [7].
  • What happens to an agency that misses the mark. Neither document names a consequence [1, 2].

The essay questions in the same Merit Hiring Plan were the subject of the September 11 memo, after a court stayed the third question; that ruling does not touch the time-to-hire standard.

Questions you’re probably asking

How long is a federal hiring process supposed to take under OPM’s new guidance?
80 calendar days in total: 66 days from a validated hiring need to a tentative job offer, two days for the candidate to accept, and 14 days from acceptance to entry on duty [1, 2].
When does the 80-day federal time-to-hire clock start?
At the ‘validated hiring need,’ which comes before a job is posted [2]. The guidance does not define that date, and GAO’s inspector general found GAO’s own start dates were recorded inconsistently [2, 7].
How soon after accepting a tentative job offer should my background check start?
The guidance tells agencies to notify the vetting office, begin the OF-306 review and launch required vetting within two days of acceptance [2]. Agencies are also told to name an HR contact for each selectee and answer offer questions within one business day [2].
What happens if an agency takes longer than 80 days to hire me?
The guidance names no consequence for the agency and no recourse for the applicant [1, 2]. It asks agencies to set their own targets, review them at least quarterly and keep reporting time-to-hire data to OPM [1, 2].
Does OPM’s 80-day hiring standard apply to GAO or other legislative branch agencies?
No. GAO’s inspector general notes that GAO, as a legislative branch agency, is not required to follow OPM guidance; GAO’s internal target is 98 or 101 days [7].

What I’m watching

  • Quarterly target reviews. The guidance asks agencies to review their own time-to-hire targets at least quarterly [2]. Whether any agency publishes them is open.
  • Reported data under the new definition. Agencies must keep reporting time-to-hire and mission critical occupation data through existing processes [1]. The first figures measured to entry on duty would show how far the 101-day baseline sits from the new 80-day line [6].
  • DCSA’s automated preliminary determinations. OPM said in March that DCSA expected to begin offering the service in fiscal 2026 [5]. The September 30 guidance does not say whether it has started [2].

— W.

Sources

  1. Guidance on Time-to-Hire Under the Merit Hiring Plan (memorandum to Chief Human Capital Officers). U.S. Office of Personnel Management, September 30, 2026.opm.gov
  2. Guidance on Time-to-Hire Under the Merit Hiring Plan (attachment). U.S. Office of Personnel Management, September 30, 2026.opm.gov
  3. Merit Hiring Plan (memorandum to heads and acting heads of departments and agencies). White House Domestic Policy Council and U.S. Office of Personnel Management, May 29, 2025.opm.gov
  4. Executive Order 14170, Reforming the Federal Hiring Process and Restoring Merit to Government Service, 90 FR 8621, FR Doc. 2025-02094. Executive Office of the President (Federal Register), January 30, 2025.federalregister.gov
  5. Streamlining Vetting Processes in Support of the Merit Hiring Plan, SuitEA Notice 2026-01. U.S. Office of Personnel Management, March 17, 2026.opm.gov
  6. OPM FY 2026-2027 Agency Priority Goals. U.S. Office of Personnel Management, March 2026.opm.gov
  7. Time to Hire: Using More Reliable Data Could Help GAO Monitor the Length of Its Hiring Process, OIG-26-1. U.S. Government Accountability Office, Office of Inspector General, August 14, 2026.oversight.gov

See also

  1. Opinion and order in AFGE v. Kupor (D. Mass., Sept. 11, 2026) staying Question Three of the Merit Hiring Plan essay questions
  2. AFGE v. OPM, No. 25cv1237 (S.D.N.Y.), October 20, 2026 opinion and order: summary judgment for plaintiffs on APA claims that OPM's grants of DOGE access violated the Privacy Act; remedy reserved
  3. OPM and OMB final rule (FR Doc. 2026-21316), effective November 18, 2026: a new 5 CFR part 430 subpart E for SL and ST appraisal, with authority for OPM to limit Level 4 and 5 ratings