Yes, you can still do facility swaps...release dates are subject to the staffing requirements though.
From the Q+A:
Q4. Are controller requests for mutual reassignment (mutual swaps) subject to the newNational Release Policy? A4. Yes. Release dates will be subject to the qualifying category (MOU Section1. 13. A.) for the facility of each employee. If an employee from a Category 1 or 2facility is seeking a swap with an employee in a facility that does not meet eitherof the Category 1 or 2 criteria, approval will only be in accordance with theprovisions of Section 1. 13. C (Office of the COO).
"Yes, swaps between a Cat 1 and Cat 2 facility can be approved, and the release/report dates do not have to be concurrent. A swap involving a person at a facility that is neither Cat 1 nor 2 will likely not be approved."