Agencies Push Back on OPM Plan to Cap Top Performance Ratings

Federal agencies are pushing back against Trump Administration efforts to overhaul the performance management system, warning that it violates merit system principles and could hurt collaboration.

The draft proposal from the Office of Personnel Management (OPM) would limit the number of employees who can receive top ratings by removing a long-time ban on “forced distribution” of performance ratings. It would also eliminate the level-two (“minimally satisfactory”) rating from the current five-level system used by many agencies and allow supervisors to assign a level-one (“unacceptable”) rating without higher-level review.

While OPM says the move will reduce ratings inflation, agencies disagree. In comments reviewed by Government Executive, agencies largely opposed the use of forced distributions, arguing that predetermined rating caps would distort evaluations and weaken trust in the performance rating system.

Among those criticizing at least some parts of the proposal were the Departments of Defense, Treasury, Energy, Labor, Health and Human Services, and Housing and Urban Development, along with NASA and the General Services Administration. Among those criticizing at least some parts of the proposal were the Departments of Departments of Defense, Treasury, Energy, Labor, Health and Human Services, and Housing and Urban Development, along with NASA and the General Services Administration. The Social Security Administration expressed support for forced distributions, though it raised concerns about other aspects of the rule.

NASA warned that forced distributions could disconnect ratings from actual performance.

“A forced distribution system without any flexibility to account for actual performance may prohibit supervisors from assigning an accurate rating,” NASA wrote, noting that it could lead to problems such as inconsistent ratings across similar performers and employees receiving ratings unrelated to their work.   

The Treasury Department warned it could punish high-performance teams. 

“With the intent to drive high performance, this could have unintended negative consequences if applied to small high-performing teams where there truly are no bottom-level performers,” said the Treasury Department.

OPM Response

OPM intends to have the new system in place for 2026. 

OPM rejected calls from the White House Executive Office of the President to use the term “curve” or “stacked ranking” in lieu of “forced distribution" and it rejected the White House recommendation to elaborate on its reasoning for overturning the forced distribution ban. 

“OPM has provided significant explanations on the benefits of forced distribution through its rulemaking with the [Senior Executive Service] and [senior professional] populations, as well as its recent guidance on normalizing ratings,” OPM wrote. “Additionally, although this is a change in position, OPM has provided the recent ratings data which illustrates how ratings have skewed far beyond a normalization of a majority of fully successful ratings.”

OPM did adopt a White House provision to ban employees from filing union grievances over a perceived unfair performance rating.