1. “Considering Loper Bright Enterprises v. Raimondo, 603 U.S. 369 (2024), how should ‘officially ordered or approved’ in 5 U.S.C. § 5542(a) be interpreted?”
2. “Is this a case in which ‘the agency is authorized to exercise a degree of discretion’ such that OPM has authority to adopt its writing requirement? Loper, 603 U.S. at 394.”
3. “Is there a statutory provision (e.g., 5 U.S.C. §§ 1104, 5548) that provides such authority?”
