It’s not through recess appointments—it’s via the Federal Vacancies Reform Act.

President-elect Donald Trump’s Nov. 10 tweet on the possibility of recess appointments for his nominees set off a flurry of analysis and concern that he would use this route to circumvent the Senate. But recess appointments are hard to effectuate. And there is a different and entirely lawful route for Trump to appoint loyalists to senior executive branch positions without Senate confirmation: the Federal Vacancies Reform Act (FVRA).

FVRA establishes rules for presidents to appoint “temporary” acting officials to (potentially very lengthy) positions for which Senate advice and consent is otherwise needed. It applies whenever a vacancy occurs because a Senate-confirmed official “dies, resigns, or is otherwise unable to perform the functions and duties of the office.”

https://www.lawfaremedia.org/article/how-trump-will-lawfully-appoint-loyalists-without-senate-consent

 

Author seems legit but haven’t heard this theory before……..