As Anne Joseph O’Connell has explained, a statutory qualification requirement for a position would not apply to an acting officer in the position unless the statute explicitly mentions that it does so apply (and I am not aware of any that do). To fix this loophole, Congress could amend the Vacancies Act to clarify that all statutory qualification requirements also apply to acting officers in the same positions. But simply mandating that all acting officers must come from the same agency as the vacant position would go far toward achieving the same end. Acting officers are important to keep the vital offices of government functioning during periods of transition. But they are also dangerous because they avoid the Senate confirmation process that the framers designed as a check against presidential cronyism. Congress reformed the Vacancies Act in 1998 to rein in presidential abuses of the act; it is past time that Congress do so again.