The Office of Personnel Management's final reduction-in-force rule and OPM's own comment docket do not agree on how many people wrote in. The rule, published on 3 August at 91 FR 49178, states that “During the 60-day comment period, OPM received 721 unique comments from current and former Federal employees, Federal agencies, unions, veterans' groups, professional organizations, think tanks, and other interested parties.” Regulations.gov assigned exactly 721 comment numbers to the docket, OPM-2025-0107-0002 through -0722. Its comment listing returns 701. The other twenty are not withdrawn, restricted or withheld: each of them loads at its own public web address, and none of them appears in any list or any search result the site will produce. The rule takes effect on Wednesday 2 September.
The 701 is the docket's own figure, not an outside tally. The comment tab on the proposed rule's page at regulations.gov reads “Document Comments 701”, and the site's listing query returns 701 whether the filter is the docket ID or the parent-document ID the page uses internally. Paged to exhaustion, that listing yields 701 distinct comment IDs, the lowest numbered 0002 and the highest 0722, so nothing is sitting outside the range. Probes above the top of it come back empty — OPM-2025-0107-0725, -0726 and -0730 all return 404 — which fixes the comment ID space at exactly 721 slots wide. Subtracting one number from the other leaves twenty slots that were issued, filled, and then dropped out of view.
The twenty absent numbers are not scattered through the docket. They fall in two unbroken runs, 0103 through 0108, all posted on 23 March 2026, and 0556 through 0569, all posted on 4 May 2026, the last day of the comment period. Each run sits at the head of that day's batch. Asked for everything posted on 23 March, the docket returns two comments, 0109 and 0110; asked for 4 May, it returns 108, running from 0570 to 0677 without a single internal gap. In both cases the day's batch actually begins earlier, at 0103 and at 0556, and in both cases the first record the docket will admit to was written more than fifty minutes after the last one it will not: 55 minutes and 22 seconds on 23 March, 60 minutes and 56 seconds on 4 May.
Every one of the twenty loads on request, and one of them is the Wounded Warrior Project's. OPM-2025-0107-0561 renders in full at its public address: PUBLIC SUBMISSION, “Posted by the Office of Personnel Management on May 4, 2026”, received 30 April, tracking number mom-16hk-5ojk, one attachment. The attachment is a 349,732-byte PDF, a letter to OPM Director Scott Kupor on RIN 3206-AO86 arguing that veterans are nearly 28 per cent of the federal workforce, more than 564,000 employees, and are concentrated in the departments a reduction in force would hit hardest — roughly 43 per cent of the workforce at the Department of War and about 25 per cent at Veterans Affairs. Search the whole of regulations.gov for “Wounded Warrior Project” and it returns 106 comments, none of them from this docket; search the docket itself for “Wounded Warrior” and it returns two, 0316 and 0242. Search the site for the tracking number printed on the comment's own page and it returns nothing at all.
Run the same test on names and the split is clean. A commenter inside a missing run does not come back: “Damion Ray Emery” at 0105 returns no comments, “Millie Kings” at 0565 returns one and it is 0142, “Laura Martin” at 0568 returns 0120 and 0664. Their listed neighbours all return themselves — “Karl Burkheimer” gives 0551, “Ann Long Voelkner” gives 0548, “Josh Chappell” gives 0113. The record that can be searched and the record that exists are not the same record.
Nothing in the pattern selects for content. The twenty are individual commenters, most of them anonymous, and four organisations, and they run both for and against the rule. Other veterans' and union submissions came through untouched: Disabled American Veterans at 0157 and 0162, the Veterans of Foreign Wars at 0676, the National Treasury Employees Union at 0532 and 0717, AFGE and AFSCME jointly at 0680, the AFL-CIO at 0678. What the twenty have in common is not what they say but when they were written to disk. That points at an indexing failure, two contiguous ingest chunks that never reached the search index — a dull cause with a durable effect. It has been five months for one run and nearly four for the other, and the docket was rewritten as recently as Tuesday, when OPM posted a new document to it, without either run reappearing.
Three of the four organisational submissions inside the missing runs exist nowhere else in the docket: the Wounded Warrior Project at 0561, the Partnership for Public Service at 0560, and AFGE Local 1003 at 0564, a 1.5-megabyte filing. The fourth is the National Labor Relations Board Union — the employees' union, not the agency — which filed at 0557 and filed again the following day at 0684. That second copy is listed, and the two carry the same file under the same name at the same 216,777 bytes, so the NLRBU's argument is still in the public record even though one of its two filings is not. Attachment manifests pulled for every absent comment that carries a file, and for twenty-one organisation-titled listed comments, turned up exactly one size collision, and that was it.
The obvious innocent explanations were tested and none holds. Attachment-only comments are listed: 0157, 0676 and 0683 all carry a stock body plus a PDF and sit inside the 701, while thirteen of the twenty absent comments carry full inline text. All twenty are documentType “Public Submission” with restrictReason null, withdrawn false, duplicateComments zero, no original-document pointer, and the correct parent — docket OPM-2025-0107, commenting on OPM-2025-0107-0001. There is no listing ceiling near 700; a sibling docket from the same rulemaking family lists 1,251. Nor is it a rule about time of day: of the 701 listed comments, 72 were last written in the 15:00 and 16:00 hours UTC, the window both failed runs fall in. And the failure is not systemic to the family. OPM-2025-0173 lists 343 across IDs 0002-0344, OPM-2025-0013 lists 618 across 0002-0619, OPM-2025-0239 lists 1,251 across 0002-1252, all three contiguous with zero gaps. Only OPM-2025-0107 has a hole.
One inference the arithmetic invites is worth ruling out. OPM's preamble cites 42 commenters by their four-digit docket number, from 0002 to 0720, and none of the twenty is among them; the preamble never names the Wounded Warrior Project, the Partnership for Public Service or the NLRBU. OPM did not answer a comment the public cannot find. What it did was state a total of 721 while its docket displays 701, and finalise the rule without either figure being reconciled against the other.
The rule is one of four OPM published on Monday 3 August that take effect on 2 September: Reduction in Force (RIN 3206-AO86, 91 FR 49178), Reduction in Force Appeals (3206-AO99, 91 FR 49230), Suitability Action Appeals (3206-AO97, 91 FR 49034) and Streamlining Probationary and Trial Period Appeals (3206-AO96, 91 FR 49072). On Tuesday 25 August, eight days out, OPM published a correction to every one of them. The RIF correction, at 91 FR 54794, fixes amendatory instructions that “do not match the current text or structure of the Code of Federal Regulations” — instruction 15 adds a section 330.707(w) that already exists as “[Reserved]”, instruction 36 revises introductory text of section 351.802(a) that has none, instruction 39 quotes text for removal from 353.110(a)(1) that is not what the CFR says. It also repairs “30 percent of more” in 316.402(b)(4), a citation to 38 U.S.C. 4114 that Congress repealed in 1991, and the fact that the RIF rule and the RIF Appeals rule each revised the authority citation for part 351 with differing text on the same day. OPM calls the corrections “non-substantive.” The document prints its own docket number as “[Docket ID: OPM-2026-0107]”, a year out; regulations.gov files it under OPM-2025-0107 as document -0724.
A second number in the same set of rules is not part of this and does not add to it. The probationary-appeals rule states that OPM received 632 comments while its docket, OPM-2025-0013, holds and lists 618 — a received-versus-posted gap, with nothing missing from the listing itself. What sits on the RIF docket is narrower and stranger: twenty comment records the government wrote, numbered, posted and still serves on request, and that its own index has not acknowledged for as long as five months. The docket's modification timestamp moved at 15:01 UTC on Tuesday when the correction was filed. The count afterwards was still 701. An index rebuild would close the gap at any time.