Civil Service Accountability Act¶
Overview¶
Published February 2026¶
Based on Rev 1.3 of the Civil Service Accountability Act
The Problem: Over-Politicization and Institutional Dysfunction¶
The United States federal government authorizes approximately 4,000 political appointments -- yet no modern administration has ever functionally staffed more than approximately 2,000-2,100 of those positions. Average confirmation times have nearly tripled from 69 days under Reagan to 192 days under Biden. At the 100-day mark of any new administration, 85% of sub-cabinet positions remain empty. The result is a system that produces chronic vacancies, acting officials with limited authority, and implementation gaps regardless of which party holds power.
Even at operational staffing levels, the United States maintains dramatically more political appointments than peer democracies such as the United Kingdom (100), Germany (50), and Canada (150). This over-politicization has created cascading dysfunction: institutional amnesia as knowledge walks out the door every 2-4 years, a competence crisis as positions are filled based on loyalty rather than expertise, and revolving-door corruption as officials make decisions with future private employment in mind.
The paradox is that this system produces the very "deep state" behavior it purports to prevent. When inexperienced political appointees cannot execute basic functions, career staff must work around them to keep government operating -- which then appears as "resistance" to political direction. The solution proposed is always more political appointments, which makes the problem worse.
America ranks 16th in government effectiveness and 27th in corruption perceptions among advanced democracies -- below every peer nation with a professional civil service. The Civil Service Accountability Act addresses this dysfunction at its root.
The Solution: The Military Model Applied to Civil Service¶
The CSAA draws on a proven model: the United States military officer corps. Americans trust career generals and admirals to defend the nation under civilian control because they operate with professional standards, transparent accountability, fixed terms spanning administrations, Senate confirmation for senior officers, constitutional oaths, and clear consequences for misconduct. Nobody accuses the military of being "deep state" despite career professionals serving decades and maintaining institutional relationships across administrations.
The CSAA applies these same principles to civil service. Cabinet Secretaries remain political appointees who set policy direction. Below them, professional civil servants execute those policies with the same competence, continuity, and non-partisan service that characterizes military professionals. The President retains full constitutional authority to supervise the executive branch and remove officers for cause -- but arbitrary political purges are replaced with transparent accountability.
Title-by-Title Summary¶
Title I: Professional Civil Service Structure¶
The CSAA establishes a three-tier structure mirroring the military:
Tier 1: Senior Professional Service (SPS) encompasses the highest career positions -- Deputy Secretaries, Undersecretaries, and Assistant Secretaries -- designated CS-1 through CS-3. These officers serve fixed terms (6 years for CS-1, 5 years for CS-2, career appointments for CS-3) and provide strategic leadership and institutional continuity across administrations.
Tier 2: Professional Civil Service Officer Corps (PCSOC) covers mid-level management and technical leadership, designated CS-4 through CS-10. These are career positions with merit-based advancement, competitive promotion, and professional development standards -- analogous to military officers O-1 through O-6.
Tier 3: Career Civil Service (CCS) forms the foundational workforce, designated CS-11 through CS-20. Entry-level through mid-career positions are filled through merit-based competitive hiring -- analogous to enlisted personnel.
The chain of command runs from President to Cabinet Secretary (political) to Deputy Secretary (CS-1 professional) through the professional ranks. Political leadership sets policy; professional civil servants execute it.
Title II: Accountability and Transparency Standards¶
The CSAA creates robust accountability mechanisms replacing the current system where incompetent political appointees face no consequences:
Public Performance Reviews. All SPS officers receive annual evaluations made publicly available. Reviews assess professional competence, execution of responsibilities, management effectiveness, ethics adherence, and response to lawful directives. Two consecutive "Unsatisfactory" ratings constitute grounds for removal.
Inspector General Oversight. IGs receive enhanced authority including unannounced inspections, unrestricted access, and subpoena power. They are selected through merit-based processes, serve fixed 7-year terms with for-cause removal protection, and play a central role in the triangulated accountability framework. IG reports transmit to Congress and become public within 60 days.
Congressional Testimony. SPS members must testify under oath before relevant committees at least annually. They receive protection from retaliation for truthful testimony regarding operational matters, legal compliance, or professional expertise.
For-Cause Removal. Officers may be removed for incompetence, neglect of duty, malfeasance, refusal to execute lawful directives, ethics violations, or criminal conduct. Critically, policy disagreement, political affiliation, and unwelcome professional advice do not constitute grounds for removal. Due process requires written notice, opportunity to respond, impartial review, and appeal rights.
Title III: Senior Professional Service¶
The SPS represents the Act's central innovation -- creating a corps of career executives modeled on the Chairman of the Joint Chiefs of Staff.
Qualifications require 10-15 years of federal service (or equivalent), advanced degrees or professional credentials, demonstrated leadership of large organizations, excellent performance history, and unblemished ethics records. Selection panels recommend candidates through a structured professional recommendation process.
Tiered Confirmation matches the confirmation burden to the political significance of each tier. CS-1 officers (Deputy Secretary equivalent) receive full Senate confirmation -- the President selects from panel-recommended candidates and nominates for Senate confirmation. CS-2 officers (Undersecretary equivalent) receive committee confirmation with a 60-day default approval mechanism -- nominees are confirmed unless the relevant committee votes to reject within 60 legislative days. CS-3 officers (Assistant Secretary equivalent) are selected by professional merit panels with no Senate involvement.
Professional Recommendation and Political Override Framework establishes that professional merit panels recommend candidates for SPS positions based on qualifications and competence. The President (for CS-1) or agency head (for CS-2 and CS-3) retains authority to override panel recommendations, but overrides require written justification documenting the reasons for departing from the professional recommendation. Override decisions automatically escalate to strengthened Inspectors General and relevant congressional oversight committees, creating triangulated accountability without eliminating political discretion.
Bipartisan Balance requires that no more than 60% of CS-1 and CS-2 positions across the executive branch be held by individuals affiliated with a single political party, preventing any administration from stacking senior career positions. CS-3 positions are subject to transparency-only monitoring.
Terms and Tenure are staggered so that every president nominates roughly half the CS-1 corps within their first term, ensuring democratic renewal while maintaining institutional continuity. New presidents inherit sitting SPS members and work with them until terms expire -- just as new commanders work with existing military officers.
Responsibilities include executing Cabinet Secretary directives, maintaining operations during transitions, providing professional expertise, coordinating across divisions, maintaining institutional relationships with Congress and international counterparts, and briefing incoming political leadership.
Title IV: Reduction and Reform of Political Appointments¶
The CSAA right-sizes political appointments from approximately 4,000 authorized positions to approximately 1,000 through an evidence-based framework:
The Formula. Total political appointments are capped at 1.25% of the senior policy and management workforce -- the approximately 80,000 people who constitute the management core of the federal government, including Senior Executive Service members, supervisory GS-14/GS-15 headquarters managers, and incumbent political appointees. With the current workforce, this yields a target of approximately 1,000 positions, with a floor of 1.0% (~800) and a ceiling of 1.5% (~1,200). The formula scales automatically as the workforce expands or contracts.
Categorical Framework. Political appointments are organized in five tiers: Executive Office of the President (150-200 positions), Cabinet Leadership including Secretaries and senior policy staff with a maximum of 8 per department (130-150 positions), Diplomatic and Quasi-Judicial including ambassadors and regulatory commissioners (250-300 positions), Legal and Law Enforcement including U.S. Attorneys (200-220 positions), and Confidential/Personal Staff under Schedule C (maximum 130 positions).
Three-Tranche Conversion. Rather than a linear drawdown, conversion proceeds through three evidence-based tranches. Tranche 1 (Years 1-2): OPM audits all positions and addresses approximately 2,000 chronically vacant positions -- those vacant for a cumulative two years or more across the two most recent administrations. Tranche 2 (Years 3-5): Positions identified as operational rather than requiring political judgment convert upon vacancy through normal attrition. Tranche 3 (Years 5-8): Remaining boundary positions undergo individual evaluation with agency head consultation and convert as political appointees depart.
Standing Position Evaluation. OPM maintains an ongoing classification review function, evaluating every political appointee position on a rolling 4-year cycle to determine whether positions genuinely require political judgment or whether their core functions are operational, technical, or managerial.
Anti-Circumvention. Agencies cannot evade limits through detailees performing political functions, contractors exercising governmental authority, extended "acting" appointments, manipulation of the senior policy and management workforce denominator, or other mechanisms. GAO audits annually for compliance, with violations triggering appointment freezes and potential withholding of administrative funds.
Emergency Flexibility. During declared national emergencies, the President may temporarily designate up to 50 additional political appointments, expiring 180 days after the emergency ends.
Title V: Merit-Based Hiring and Promotion¶
The CSAA strengthens merit system principles and creates clear advancement pathways:
Competitive Examination governs entry-level hiring through public announcements, structured assessments, veteran preference, and prohibition on political inquiries during selection.
Promotion to PCSOC ranks uses weighted criteria: performance evaluations (40%), professional development (20%), competitive assessment (30%), and promotion board interview (10%). Promotion boards of senior civil servants evaluate candidates using standardized criteria.
Performance Evaluation applies objective, measurable standards established in advance. Ratings determine pay increases, bonuses, and advancement eligibility -- or trigger improvement plans and potential removal.
Title VI: Constitutional Oath and Non-Partisan Service¶
All civil servants take the same oath as military officers, swearing to support and defend the Constitution -- not any individual or political party.
Restrictions on Political Activity strengthen Hatch Act provisions. No political activity during work hours or using government resources. SPS members may not run for partisan office while serving. Coercion of subordinates for political purposes is prohibited.
Enhanced Post-Employment Restrictions close the revolving door. SPS officers face 5-year bans on lobbying their former agency, employment with regulated entities, and employment with contractors. Definitions are broad, covering strategic advising and de facto influence -- not just formal lobbying. Enforcement includes civil penalties up to $250,000 per violation, criminal prosecution with up to 5 years imprisonment, pension forfeiture, and disgorgement of prohibited compensation. OGE tracks all departing SPS officers and maintains a public database of post-government employment.
Compensation Offsets make restrictions viable. SPS officers receive enhanced retirement (2.0% multiplier versus standard 1.0%), retention bonuses for completing terms, and professional development support for transitioning to compliant careers.
Title VII: Compensation and Professional Development¶
The CSAA establishes competitive compensation to attract and retain talent:
Pay Scales range from $150,000-$280,000 for CS-1 (Deputy Secretary level), $130,000-$220,000 for CS-2, $110,000-$180,000 for CS-3, with PCSOC ranging $70,000-$150,000 and CCS $35,000-$95,000. Performance bonuses reach 25% of base salary for SPS officers.
Professional Development requires minimum 40 hours annually for all civil servants, leadership training before assuming supervisory duties, and executive programs for SPS candidates. Agencies must budget at least 3% of personnel costs for training.
Benefits include the Federal Employees Retirement System with enhanced accrual for SPS service, TSP matching, continued health coverage into retirement, 12 weeks paid parental leave, and sabbaticals for advanced education.
Title VIII: Implementation and Transition¶
Implementation proceeds over 8 years in three phases aligned with the tranche-based conversion approach:
Phase 1 (Years 1-2) establishes the foundation: OPM issues regulations, agencies submit implementation plans, professional standards and examination systems are developed, and the transparency portal launches. OPM conducts a comprehensive audit of all political appointee positions, addressing approximately 2,000 chronically vacant positions.
Phase 2 (Years 3-5) converts operational positions as political appointees depart through normal attrition. No forced removals occur -- positions convert naturally as incumbents leave. The first wave of SPS appointments is completed through merit selection and tiered confirmation.
Phase 3 (Years 6-8) completes remaining boundary-position conversions through individual evaluation. By Year 8, political appointments reach approximately 1,000, and the full professional civil service is operational.
Incumbent Protection ensures current political appointees are not removed solely due to position conversion. They may remain until normal departure, compete for converted positions if qualified, accept reassignment, retire with incentives, or depart with severance.
Title IX: Oversight and Reporting¶
Multiple oversight mechanisms ensure accountability:
Merit Systems Protection Board hears appeals of SPS removal decisions on expedited basis and conducts compliance audits. Board members serve 7-year staggered terms with bipartisan composition.
Government Accountability Office audits civil service operations biennially, investigates systemic problems, and reports findings publicly.
Congressional Oversight through annual hearings, quarterly reports from OPM, and notification requirements for compliance issues. Override decisions under the Professional Recommendation and Political Override Framework automatically route to relevant congressional committees.
Public Transparency through an OPM annual report covering performance data, personnel actions, accountability measures, and cost efficiency -- with all underlying data published in machine-readable formats. The Transparency Portal publishes override records, escalation filings, and IG findings on override disputes.
Structured Severability¶
The CSAA includes a structured severability provision that drafts each SPS tier's protections as self-contained legislative units. If any provision is held unconstitutional, remaining provisions continue to operate independently with explicit fallback mechanisms. The severability architecture identifies constitutionally unexposed provisions that operate entirely within Congress's Article I authority to structure executive departments, distinguishing them from provisions that engage contested Article II questions. This design ensures the Act degrades gracefully rather than collapsing entirely if any single element faces successful constitutional challenge.
Implementation and Outcomes¶
The tranche-based approach allows proper system development, smooth transitions without chaos, experience by both parties with the new system, and course corrections based on lessons learned.
Projected Outcomes. Five years after implementation: chronically vacant positions eliminated, operational positions converting through attrition, first wave of SPS officers confirmed through tiered confirmation process, performance review systems demonstrating results, revolving door violations prosecuted, and government effectiveness rankings rising. Ten years after implementation: full professional civil service operational with approximately 1,000 political appointments, institutional knowledge preserved across multiple transitions, improved corruption perceptions ranking, and both parties having experienced competent execution of their agendas by professional civil servants.
Supporting Documentation¶
For detailed analysis, see companion documents: CSAA International Comparative Analysis (peer democracy civil service structures), CSAA Constitutional and Legal Analysis (precedents and presidential authority), CSAA Economic Analysis (cost-benefit assessment), and CSAA Policy Rationale (design choices and stakeholder concerns).
Revision History¶
Revision 1.3 (Current) - Updated to reflect CSAA Rev 1.3 legislative text - Revised problem framing: distinguished authorized positions (~4,000) from functionally staffed positions (~2,000-2,100); added confirmation pipeline deterioration data - Updated SPS term lengths from 10/8/6 years to 6/5/career throughout - Replaced Senate confirmation for all SPS tiers with tiered confirmation structure - Added Professional Recommendation and Political Override Framework to Title III summary - Revised Title IV: replaced 0.2% formula (target ~420) with 1.25% of senior policy and management workforce (target ~1,000); updated categorical framework position estimates; replaced linear drawdown with three-tranche conversion approach; added standing position evaluation function; added denominator anti-circumvention provision - Updated Title VIII implementation phases to align with tranche-based conversion - Added structured severability provision summary - Updated Title IX to reflect override framework escalation and expanded Transparency Portal - Revised projected outcomes to reflect revised parameters - Updated publication date
Revision 1.2 - Initial Overview document for CSAA Rev 1.2 - Covers all nine Titles with substantive summaries - Includes implementation timeline and projected outcomes
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Prepared by Albert Ramos for The American Policy Architecture Institute