Secular Coalition for America Challenges OPM Memo Permitting Religious Proselytizing in Federal Workplaces

Author(s): Scott Douglas Jacobsen

Publication (Outlet/Website): The Good Men Project

Publication Date (yyyy/mm/dd): 2025/08/19

Nnenna Onwukwe (They/Them) is the Federal Policy Associate at the Secular Coalition for America, where they advocate for church-state separation, secular inclusion in policy, and protections for religious freedom for all. In this interview with Scott Douglas Jacobsen, Onwukwe discusses the new Office of Personnel Management (OPM) guidance under Director Scott Kupor. The memo, created in partnership with the White House Faith Office, permits federal employees to openly proselytize at work without consequence, raising concerns over harassment of nonreligious and minority-faith employees. Onwukwe warns this policy aligns with broader efforts by the Religious Liberty Commission to privilege certain Christian beliefs while neglecting protections for others. They outline potential workplace harms, legal gray areas, and the Coalition’s plans to provide resources for nonreligious workers facing discrimination.

Scott Douglas Jacobsen: Today, once more, we are here with the wonderful Nnenna Onwukwe. Regarding the work of the Secular Coalition for America, we have some new developments concerning the OPM guidance. Yes, it is the new Office of Personnel Management guidance under Director Scott Kupor.

Now, how long has he been in this position? One. Two, how is this partnership with the White House Faith Office not particularly good for the federal government?

Nnenna Onwukwe: Yes. Well, Scott Kupor started in July 2025. This was one of the very first pieces of guidance the OPM issued after he began his role. He worked with the White House Faith Office to create it. We believe this collaboration had been in progress for some time, as the White House Faith Office has been active in recent months.

They have worked with the Religious Liberty Commission and stated that they are focused on eliminating what they call “anti-Christian bias.” This guidance aligns with much of that work, where instead of protecting people of all religions and no religion equally, the emphasis appears to be on creating an environment in which Christians—or people of certain religions—can act without the same limitations applied to others.

Kupor oversaw this shift in federal workplace policy with the new memo. Essentially, it permits federal employees to openly proselytize on the job—trying to convert coworkers and explaining why their religion is the “right” one—without facing consequences.

Instead of simply focusing on their work, employees may now face situations where a coworker approaches them to share, for example, why Mormonism is great and why they should join. This is damaging to all employees, especially those who are nonreligious or belong to minority faiths, because it opens the door to harassment and undermines a neutral, professional workplace environment.

Jacobsen: I have worked in many places, and I am sure many others have as well—both inside and outside Canada and the United States—where harassment does occur. It can be explicit, or it can be subtle. So, they focus on “eradicating anti-Christian bias.” Do they provide actual case studies or meta-analyses, or are they simply asserting this?

Onwukwe: The Religious Liberty Commission is the body that has been tasked with eradicating what it calls anti-Christian bias, and they are trying to address this within the federal workforce. They held their first meeting a couple of months ago, and they are currently gathering data. We do not yet know what that data looks like.

We also do not know how they are defining discrimination. Is it a situation where a Christian declares their religion and is physically attacked? Or is it when a Christian expresses opposition to abortion or LGBTQ rights—positions that can be discriminatory in the workplace—and then faces consequences? From the language and priorities they have set, it sounds more like the second scenario, but at this stage, they have not released any detailed findings.

Jacobsen: So, the scenario would be something like this: a person says, “Based on my faith, I do not believe in marriage equality for homosexuals.” Someone at work responds by criticizing or pushing back against that openly stated belief. The Christian is offended by this response and files a complaint of anti-Christian bias. Is that essentially the kind of situation we are talking about?

Onwukwe: Yes, that is definitely a scenario that could happen. There is a process in place where such claims can be submitted. That kind of example seems like one of the standard situations that might arise. Another example could be people in the break room discussing the impact of the elimination of Roe v. Wade. A Christian employee could claim they were hurt or offended by that conversation, and then send an email to the relevant office stating they were discriminated against—even if, in reality, no discrimination occurred.

Jacobsen: I see. Now, previously, there were “reasonable accommodations” for religious practices. The press release talks about the OPM guidance expanding reasonable accommodations for religion. From my perspective, this seems like an overextension—taking what was already established and using it to primarily benefit certain Christian concerns.

Onwukwe: Yes. I am not entirely sure what the old guidance stated, but I can look into it and see if it is still online—if they have not removed it from the federal websites, which has happened in some cases. I do know that under existing HR guidelines, accommodations for religious observance apply to both religious and nonreligious individuals. These guidelines prohibit discrimination based on religion or lack of religion. They also allow for certain holiday observances, such as Christmas and other Christian holidays, but I am not sure of the full list.

Other than that, much of what is in the new memo goes into new territory. It states that people who are religious will be granted these accommodations, but the language is vague and leaves much room for interpretation. One question is whether these same protections will apply to non-Christians or to Christians outside certain denominations.

For example, if a Jewish employee is told by a coworker that abortion is wrong, but the Jewish faith recognizes situations in which abortion is permissible, would that Jewish employee be able to claim discrimination? Those kinds of specifics are not addressed in the memo.

The memo also goes beyond interactions between federal employees—it extends to interactions with the public. For instance, a VA doctor could speak to a patient about religion. If that patient were considering an abortion, the doctor could use religious reasoning to tell them abortion is wrong, even handing out pamphlets, instead of simply providing medical care. Similarly, a park ranger at a national park could lead a tour and then stop midway to give an hour-long talk about the Latter-day Saints, turning what should be a recreational activity into a religious information session.

Jacobsen: So, situations like that would mean it is not only federal employees who are affected—it could also impact people who do not directly work in those offices. With the VA, for example—Veterans Affairs doctors praying over patients—I can see someone like Mikey Weinstein of the Military Religious Freedom Foundation speaking very forcefully about this. I would be curious to hear his and other U.S. organizational leaders’ opinions on these cases. If the new OPM guidelines are this open-ended, it seems to me there will be a lot of people in the secular community who will be deeply concerned.

Onwukwe: Yes. For example, the Military Association of Atheists and Freethinkers (MAAF) is one of our coalition members, and they do excellent work advocating for atheists and the nonreligious within the military. There is already enough discrimination against nonreligious people in the military—the whole “no atheists in foxholes” stereotype still persists. This guidance adds yet another challenge for nonreligious people trying to secure benefits and fair treatment.

It is already hard enough for people navigating the VA system. This just adds another layer of difficulty. And in other federal agencies, workers are already under stress. People are facing layoffs. They are being told to return to the office after having been guaranteed remote work, sometimes after moving hundreds of miles away. This has displaced many workers and created uncertainty. On top of that, the new guidance means someone could now be required to go into the office and have a coworker—say, Susan from HR—start talking to them about her religion and handing them pamphlets. This is adding frustration on top of frustration.

Jacobsen: Are there any other points that should be added with regard to this memo? Obviously, there will be more developments in the coming weeks.

Onwukwe: Yes. It is relevant for people to know that we are currently working on guidelines for nonreligious employees—resources for those who do not want to face discrimination or harassment in the workplace and who do not want coworkers telling them which religion they should follow. We plan to release those guidelines soon.

We are looking closely at the memo, and there are many areas where problems could arise. If a supervisor tells you, “This is the religion you should follow,” and then begins harassing you, that is a serious issue. There will no doubt be cases like that under this guidance.

Jacobsen: Yes—when you have management, power imbalances, and similar dynamics, employees may not feel comfortable pushing back. They might fear that their job could be at risk if they do. With the mass layoffs that have already occurred in the federal government, some employees might feel forced to endure these situations.

Onwukwe: Exactly. That is why we want to provide guidance. We want to offer information on who people can reach out to, what areas they can challenge if they feel comfortable doing so, and make sure they understand their rights. Right now, there are not many resources available for nonreligious employees, so we want to fill that gap.

Jacobsen: A big part of this, from an anthropological and cultural studies perspective, is that the United States has been undergoing increasing secularization—significant, but far from complete. There is still a great deal of entrenched Christian resentment toward that trend. If members of that group hold seniority or management positions, they are more likely to have power over benefits and workplace decisions. Given this new leverage, their resentment could be expressed in ways that are acutely distressing for other employees.

Onwukwe: Yes, and that pushback is exactly what we are seeing from the Religious Liberty Commission and the White House Faith Office. Now, with OPM’s new memo, this appears to be their way of saying, “We have you covered, Christians in America. Do not worry about challenges to your faith—you can speak freely, and we will protect you.”

This approach specifically favors one particular type of Christianity, while ignoring every other faith and the nonreligious. It is consistent with other actions we have seen recently, and it is deeply concerning. We want people to be aware of what is happening and to know that there is work being done to protect those who are most at risk under these policies.

Jacobsen: Nnenna, thank you very much for your time again today. I appreciate your expertise. 

Onwukwe: Yes, sounds good. It has been great talking to you again.

—

Supplementary commentary:

About the prior guidance federal employees had on religion before this new memo was issued, Nnenna reviewed the memo alongside Title VII information from OPM and the overall messaging on both OPM and EEOC’s websites. The federal government will technically still follow Title VII. However, the new guidance dismantles key sections. Those sections dealing with religious-based harassment and discrimination, particularly those protecting the secular community).

Section 12 of EEOC’s guidance focuses on religious discrimination in the workplace. Quotes:

• The non-discrimination provisions of….[Title VII] also protect employees who do not possess religious beliefs or engage in religious practices.[10]  EEOC, as a federal government enforcement agency, and its staff, like all governmental entities, carries out its mission neutrally and without any hostility to any religion or related observances, practices, and beliefs, or lack thereof.[11]
• An employer can thus restrict religious expression when it would disrupt customer service or the workplace, including when customers or coworkers would reasonably perceive it to express the employer’s own message.[140]
• Additionally, in a government workplace, the First Amendment Free Exercise Clause and Establishment Clause may affect the employer’s or employee’s ability to restrict or engage in religious expression. 

Under the Religion section of EEOC’s Enforcement Guidance on Harassment in the Workplace, sample of example of religious based harassment included: 

• Thiago, a fraud investigator at a property and casualty insurer, is agnostic and rejects organized religion. After Thiago’s sister died unexpectedly, Thiago is despondent. He is approached by a coworker, Laney, who says that she can communicate with the dead and has received the following messages from Thiago’s sister: the sister is suffering in Hell, and Thiago will go to Hell as well if he does not “find God.” Thiago becomes upset and asks Laney to never bring up the topic again. Nevertheless, Laney repeatedly encourages Thiago to find religion so Thiago will not “go to Hell like his sister,” despite Thiago’s ongoing requests for Laney to “drop it.” Based on these facts, Laney’s harassing conduct toward Thiago is based on religion.22

Previously, EEOC’s guidance recognized religious harassment as a grounds for discipline or unlawful conduct under Title VII. EEOC emphasized the First Amendment’s Establishment Clause on government employee’s abilities to engage in religious expression in the workplace. The new OPM memo effectively erodes those protections. This opens the grounds for nonreligious community to religious-based harassment.

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