CFS Potential Position Term Limits & Mandatory Transfers Update: Nov. 15, 2023

Dear OCEA CFS member,

We are writing to provide an update regarding speculation about potential position term limits and mandatory transfers of SSWs and SSSSs within CFS (not including APS).

As previously communicated, when we first heard rumors about these issues we promptly requested to meet and confer with CFS management. This is our right whenever the employer considers taking action that might impact your wages, hours or working conditions.

OCEA Labor Representative Kerensa Schupmann, Operations Manager Veronica Rodarte, and Senior Organizer Alisha Greene first met with CFS management on Oct. 19, 2023. At that meeting, CFS Director Jyothi Alturi represented to us that the Agency intended to propose, but had not yet developed, policies regarding term limits and mandatory transfers with the following objectives: to reduce attrition, expand overall employee knowledge of CFS, and foster professional development and succession planning. Although they had no specifics, management did represent that any term limits would be uniformly and equitably applied to all SSW and SSSS positions. Click here to view the communication we sent to you after that meeting.

We again met with CFS management on Oct. 31, 2023. AMII Martin Raya (Assistant to CFS Director/Strategic Planning & Project Coordination Program Manager) joined this follow-up meeting, purportedly to explain the Division’s planned changes. Unfortunately, Mr. Raya’s presentation created much more uncertainty rather than what we had hoped would be confirmation and clarification.

For example, we were informed that rather than implementing term limits “uniformly and equitably,” CFS would focus solely on positions without existing attrition concerns. This would include, according to Mr. Raya, what he referred to as "support programs" or "non [primary] case-carrying assignments." Management was unable to clarify whether this is merely a preliminary or a final position regarding term limit application. It was also unclear which specific positions management might intend to include in its “no attrition issues” category. Further, they could not identify the factors which they might use to make a “no attrition issues” determination, or when and how determinations might be reviewed.

To date, the only written material management has provided is a one-page slide (to OCEA) and FAQs (to you). Yet even those are inconsistent. While the one-page slide refers to 5-year term limits, at our meeting management referred to a 3-year limit. We were also informed that this will be a “procedural change” and that there will be no written policy. But imposing term limits and mandatory transfers where none currently exist are, on their face, policy changes.

As a result of the Oct. 31 meeting we do not feel CFS management is being straightforward with us and perhaps not even with each other. We don’t believe we yet know any specifics about what they might propose or what their true objectives might be, and we are not convinced that they know themselves. We’re trying to build bridges with management and work as collaboratively as possible, but these first two meetings have not helped facilitate those efforts.

To be able to understand and evaluate what, if anything, CFS actually intends to propose and potential impacts we need much more and much clearer information than we have received. To that end, we have prepared and submitted to CFS requests for information to assist us. Responses to those requests will also help us continue to evaluate whether any changes eventually proposed by CFS might target workers over the age of 40 and potentially violate the Age Discrimination in Employment Act (ADEA) or any other statute which protects workers over that age.

Once we receive responses to our requests for information and are able to draw some conclusions as to management’s intent we will be in a position to determine next steps.

If you have additional questions, please contact OCEA Labor Relations Representative Kerensa Schupmann at and stay tuned for more updates as developments warrant.

In Solidarity,


Publication Date: November 15, 2023