A memo from the Trump administration’s top human resources official Monday laid out expansive descriptions of workers who could be stripped of civil service protections this year.

The memo concerns a broad new category of federal workers that could be removed from the so-called “competitive service” and exempted from protections against “adverse actions” like being fired or suspended. These employees would be eligible to be transferred into “Schedule Policy/Career,” which was previously known as “Schedule F.”

According to an executive order President Donald Trump issued in 2020 — and reissued, with some changes, after taking office last week — this new “schedule” of workers will include people in “policy-influencing positions,” defined as “positions of a confidential, policy-determining, policy-making, or policy-advocating character.”

And according to an interim guidance memo sent Monday by Charles Ezell, the acting director of the Office of Personnel Management, the Trump administration thinks this description could fit a whole lot of government workers.

In a bulleted list, Ezell wrote that agencies should consider “rescheduling” positions involved in, among other things, “directing the work of an organizational unit,” “being held accountable for the success of one or more specific programs or projects,” “substantive participation and discretionary authority in agency grantmaking,” including “evaluation of grant applications,” and “publicly advocating for the policies of the agency or the administration, including before the news media or on social media.”

Only a few thousand government employees — political appointees — typically leave their jobs when a new administration comes in. They are far outnumbered by those in the competitive service, who are hired based on merit and have strong employment protections. The broad descriptions in Ezell’s memo could make tens of thousands of career, nonpolitical employees — such as project managers, analysts and clerical workers — eligible to lose those protections, leaving their futures in the hands of their politically appointed superiors.

“The categories of potential employees are extraordinarily broad,” Donald Moynihan, a professor of public policy at the University of Michigan who has closely tracked Trump’s attacks on the civil service, told HuffPost in an email.

“Effectively, any employee that uses discretion involved in the interpretation and implementation of policy could be fired if they displease the administration. Officials who played PR or advocacy roles at the request of the prior administration can be fired now.”

Trump’s new executive order goes further than the one he issued in 2020 by stating that jobs eligible to be rescheduled include any involving “duties that the Director otherwise indicates may be appropriate for inclusion in Schedule Policy/Career.” This line, which Ezell mentioned in his memo, expands the Trump administration’s authority to reclassify workers.

The executive order and memo both contain language asserting that civil service protections won’t be stripped based on individual workers’ political beliefs. But the memo says federal employees are required “to faithfully implement administration policies to the best of their ability,” and the new executive order requires they carry out their work consistent with “the vesting of executive authority solely in the President.”

If Trump’s first term is any indication, agency heads — political appointees installed by Trump — are likely to interpret affected positions broadly.

Trump’s original “Schedule F” order was issued in October 2020 and therefore never fully put into effect. But before Trump left office, a few agencies did put together lists of positions they thought were eligible to be stripped of civil service protections. Among them, according to public records obtained by the National Treasury Employees Union, were IT specialists, human resource specialists and office managers, in addition to policy analysts, economists and legal roles.

Notably, in addition to revoking Trump’s 2020 “Schedule F” order, Joe Biden’s administration also went through a formal rule-making process, completed in 2024, to codify existing civil service protections and put up barriers to future presidents attempting to copy Trump’s order.

Now back in office, Trump appears intent on simply bulldozing through that 2024 Biden rule. Not only has an OPM press release for it been erased, but Ezell’s memo also states that Trump used his executive order to simply “directly nullify these regulations” where they stemmed from presidential authority.

“OPM’s October 25, 2024, guidance document entitled ‘Implementing Guidance for Upholding Civil Service Protections and Merit System Principles Regulations’ is hereby rescinded in its entirety,” Ezell’s memo says flatly.

“The memo simply dismisses the Biden rule limiting Schedule F,” Moynihan wrote. “Biden went through a formal rulemaking process, but the Trump administration is saying that they can ignore that. This is the biggest change to the civil service system since its creation, and the Trump administration says they do not require any new legislation or following the rulemaking process.”

The National Treasury Employees Union has already sued over Trump’s Schedule Policy/Career order, arguing the president exceeded his authority by potentially creating such a broad category of federal workers, and that statutory language about “confidential, policy-determining, policy-making, or policy-advocating” was intended to refer only to noncareer political appointees, who change with every president, and not career civil servants.

The new executive order gives OPM until Feb. 19 to come up with additional positions to potentially be rescheduled. “OPM will issue final guidance prior to that date,” a footnote in Ezell’s memo reads.

Under the executive order, agency heads have 90 days to make a preliminary list of positions to reschedule and an additional 120 days to finalize the list.

“OPM retains discretion to determine which categories and types of positions it will recommend for Schedule Policy/Career, and the President will make the final determination about which positions to transfer,” Monday’s memo reads.