The titles are a mouthful.

There’s the deputy director exercising the authority of director for the National Park Service, and the senior official performing the duties of the director at U.S. Immigration and Customs Enforcement.

This is how President Trump is filling dozens of high-level jobs in the federal government without Senate confirmation. The administration leaves key jobs vacant at a given agency, while delegating the authority of those positions down to subordinates who do not need to be confirmed or even nominated for the jobs.

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“That’s the shocking thing — just how many positions are working because of these delegations,” says Anne Joseph O’Connell, an expert on administrative law at Stanford Law School.

Why not just name acting directors and deputies to fill these open positions? The answer, O’Connell says, lies in a law known as the Federal Vacancies Reform Act, which lays out extensive rules about who can be appointed to serve in Senate-confirmed jobs, and for how long.

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“The vacancies act has time limits,” O’Connell says. “But these delegations typically don’t.”

In most cases, O’Connell says you can hold the “acting” title in a job that requires Senate approval for only so long, usually about seven months. With delegation, there’s no time limit. A subordinate can effectively take on the boss’s responsibilities indefinitely.