While DoD has defined certain functions department-wide as exempt from the general government hiring freeze, it left other decisions in the hands of the individual military services and other lower levels, although only within tightly defined limits.

Such exceptions may be granted on either a group or individual basis, its freeze policy adds, but approving officials must: certify in writing why the exception is necessary based on the position’s function, not funding source; identify the “compelling circumstances” that justify an exception “given that the department accepts risk with respect to every decision not to hire”; document the alternatives considered; and certify that other personnel cannot be reassigned to the duties.

Certain other actions may be taken without the grant of an exception, it adds, including filling politically appointive positions; appointments under the Pathways Internship and Presidential Management Fellows programs, although not under the Recent Graduates program; career ladder promotions; and conversions to the competitive service of those currently serving in the Pathways or Veterans Recruitment Act programs.

Still other actions may be taken without the grant of an exception, but require advance coordination with the Pentagon’s central personnel office, under the DoD policy. These include appointments of seasonal employees to meet traditionally recurring seasonal workloads; certain time-limited fellowship or professional exchange programs; and voluntary transfers of SES members within DoD.

Those exceptions generally mirror policies set by earlier joint OPM-OMB guidance on the freeze.