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SHOW UP Act: Reinstates pre-pandemic telework and studies future use

A federal framework requiring a 180-day study and certified plans before any expansion of telework, with a reset to 2019 policies.

The Brief

SB354, the SHOW UP Act of 2025, directs executive agencies to study the effects of COVID-era telework and submit a plan for future telework use to Congress. It also requires agencies to reinstate pre-pandemic telework policies within 30 days of enactment and bars any expansion until a plan is submitted and certified.

The bill then imposes a 180-day deadline for a comprehensive agency-specific study, including mission impact, customer service, and cost analyses (notably underutilized real property and locality pay implications), plus a plan to expand telework beyond 2019 levels. The Director of the Office of Personnel Management must certify that the plan will improve mission performance, support workforce dispersal, and reduce costs, including IT and security considerations.

The package aims to balance mission needs with workforce flexibility, under tight congressional oversight.

At a Glance

What It Does

Not later than 30 days after enactment, agencies must reinstate their 2019 telework policies. No expansion may occur until each agency submits a plan and the Director certifies it. Within 180 days, agencies must study COVID-era telework impacts and propose future telework policies with a certification requirement.

Who It Affects

All executive agencies, plus the Director of the Office of Personnel Management, their HR and IT functions, and federal employees who telework. The framework will influence real property decisions and locality-pay considerations tied to telework.

Why It Matters

Creates a formal, Congress-oversight-driven reset of telework policy, tying future expansion to quantified performance, cost, and security metrics, and dispersing the federal workforce nationwide.

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What This Bill Actually Does

The SHOW UP Act imposes a structured reset on how the federal government uses telework. It requires agencies to roll back to their pre-COVID telework policies (as they stood on December 31, 2019) within 30 days of enactment, and it forbids any expansion of telework until Congress receives a concrete plan and the Director of the Office of Personnel Management (OPM) certifies that plan.

Central to the bill is a 180-day requirement for each agency to deliver three things: (1) a study detailing the impacts of the COVID-era telework expansion on the agency’s mission and operations (including customer service); (2) a plan to expand telework beyond 2019 levels; and (3) a certification by the OPM Director that the plan will positively affect mission performance, enable greater workforce dispersal, and reduce costs, while ensuring teleworkers have secure networks and access to necessary data and records.The statutory language ties the ability to move forward with telework changes to concrete outcomes: improved mission performance and customer service, greater geographic dispersal of staff, and potential reductions in real property costs and locality pay allocations. The act also explicitly definitions telework to include remote work, aligning terms across policy, security, and payroll considerations.

Taken together, the bill makes telework a measurable policy decision rather than a blanket administrative option, subject to rigorous oversight and certification.

The Five Things You Need to Know

1

The bill requires agency heads to reinstate pre-2019 telework policies within 30 days of enactment.

2

Expansion of telework is prohibited until each agency submits a plan to Congress and receives a Director of OPM certification.

3

A 180-day study is required analyzing mission performance, customer service, security, and costs related to COVID-era telework (including real property and locality pay factors).

4

Agencies must also submit a plan to expand telework beyond 2019 levels, with a certification that the plan will yield positive mission and cost outcomes.

5

Telework, as defined in the bill, includes remote work and is anchored to Section 6501 definitions in title 5 U.S.C.

Section-by-Section Breakdown

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Section 1

Short Title

This section establishes the official name for the act: the Stopping Home Office Work’s Unproductive Problems Act of 2025, also called the SHOW UP Act of 2025. The title signals the bill’s intent to regulate how telework expanded during the pandemic will be studied and recalibrated going forward.

Section 2

Definitions

This section defines core terms used throughout the bill. It clarifies that an 'agency' aligns with the term 'Executive agency' in 5 U.S.C. 105; 'Director' refers to the Director of the Office of Personnel Management; 'Locality pay' covers pay under 5 U.S.C. 5304 or 5304a; and 'telework' or 'teleworking' includes remote work and uses the definitions in 5 U.S.C. 6501. These definitions ensure uniform interpretation across agencies and help avoid ambiguity in implementation.

Section 3

Reinstatement of Pre-Pandemic Telework Policies, Practices, and Levels for Executive Agencies

Not later than 30 days after enactment, agency heads must reinstate the telework policies that were in effect on December 31, 2019. The section also prohibits expanding any policy, practice, or level described in the reinstatement until the agency submits an accompanying plan under section 4(a)(2) and receives a Director certification under section 4(a)(3). This creates a mandatory pause on expansion while agencies perform due diligence and obtain congressional oversight.

1 more section
Section 4

Study, Plan, and Certification Regarding Executive Agency Telework Policies

This section sets a 180-day deadline for the head of each agency, in consultation with the Director, to submit to Congress a three-part package: (1) a study on the impacts of COVID-era telework on the agency’s mission, including analyses of adverse effects on performance, customer service, and related costs; (2) an agency plan to expand telework beyond the 2019 baseline; and (3) a certification by the Director that the plan will have substantial positive effects on mission performance and dispersal, and will reduce costs while ensuring secure access to data and systems. The package requires consideration of secure network capacity and proper data access, as well as the potential to disperse the workforce across the United States. The section also sets a mechanism for approval, requiring certification before any expansion can be implemented.

At scale

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Who Benefits and Who Bears the Cost

Every bill creates winners and losers. Here's who stands to gain and who bears the cost.

Who Benefits

  • Agency heads and HR/IT leadership gain a clear framework for evaluating telework and for drafting enforceable plans that satisfy congressional oversight.
  • The Director of the Office of Personnel Management gains a formal certification role, clarifying when a telework expansion can proceed.
  • Federal employees who telework benefit from explicit requirements around secure access and established baselines for policy changes.
  • The federal workforce dispersal effort could improve recruitment and retention by broadening where work can be done without sacrificing mission performance.
  • Compliance and security professionals in agencies gain a defined process to assess and certify telework implementations.

Who Bears the Cost

  • Agency IT and security teams bear the upfront costs of upgrading networks, tools, and access controls to support telework securely.
  • Agencies may incur real property costs related to underutilized assets as workforce dispersion increases and the policy is evaluated.
  • Office of Personnel Management and agency budget offices bear ongoing oversight and certification responsibilities, with potential administrative overhead.
  • Contractors and vendors providing telework infrastructure face demand for compliant, certified solutions, potentially raising contract costs.
  • Smaller agencies may experience disproportionate administrative burden during the 180-day study and certification process.

Key Issues

The Core Tension

The central dilemma is whether mandating a policy reset and certification process will stifle innovation in flexible work while delivering measurable gains in productivity and cost savings, or whether it provides needed discipline to avoid repeating the disjointed telework expansions seen during the pandemic.

The bill anchors telework policy in a tight timeline: a 30-day reinstatement, a 180-day study, and a formal Director certification before any policy expansion. In practice, this could slow agency modernization efforts aimed at flexibility, while enabling congressional oversight to anchor telework decisions in measurable outcomes.

The approach assumes uniform capability across agencies to assess mission impact, security readiness, and cost implications, which may not reflect the diversity of IT maturity and workforce needs. A key implementation question will be whether the required data—such as secure network capacity and compatibility with Federal records access—can be gathered quickly and accurately across agencies with varying IT architectures.

Another unresolved question is how agencies balance dispersed staffing with thresholds for workload, service levels, and visitor-facing functions that depend on in-person presence.

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