The Douglas factors have been around for almost 40 years yet agencies have various ways to document that the deciding official consciously considered them. Some agencies have both the proposing and deciding official consider the factors, while other agencies limit the review to the deciding official. Some agencies complete a separate Douglas factor worksheet, while others either issue a bare-boned decision letter or incorporate all the factors into the decision letters. Agencies also simply have a deciding official “adopt” a proposing official’s Douglas factors. Mr. Erbe and MSPB Administrative Judge Ronald Weiss will discuss the pros and cons of the various approaches. In addition, you will hear which approach is more effective and which can result in a due process violation.