Limited number of agency senior executives could be rated as ‘outstanding’ under Trump proposal

The Senior Executives Association on Tuesday criticized the Trump administration’s plan to cap the number of top performance ratings that agencies can assign to the highest-ranking career federal employees. 

On May 2, the Office of Personnel Management issued a notice of proposed rulemaking to scrap a prohibition that prevents agencies from implementing forced distribution for evaluating members of the senior executive service. Under the proposal, agencies would be able to limit the number of the highest two ratings (levels four and five) that their SES employees can receive. 

OPM said that, during the fiscal 2023 performance cycle, 64.3% of SES members were rated as “outstanding” and 31.7% as “exceeds fully successful” — the top two levels. In contrast, 0.1%, or 10 individuals, were considered to be the lowest ranking of “unsatisfactory.” 

“Removing the prohibition on forced distribution would allow agencies to establish and enforce limits on the highest SES rating levels, thereby increasing rigor in the SES appraisal process and leading to a more normalized distribution of SES ratings across the federal government,” according to the notice. 

SEA President Marcus Hill, on the other hand, argued that the proposed performance rating system overhaul was “arbitrary” and in contravention of what Congress intended when it created the SES. 

“OPM proposes to remove provisions of law which prevent the arbitrary distribution of performance ratings that are key provisions of a statutory pay for performance scheme designed by Congress governing the senior executive service,” Hill said in a statement. “The rule would instead change policy to force the distribution of performance ratings, rather than empowering political appointees with the tools to manage their agencies’ performance and consistently achieve desirable results that sustain a high performing organizational culture.” 

Hill also noted that OPM has not made public federal executive performance management data since fiscal 2015, besides top line numbers from fiscal 2023. 

“No comprehensive historical data has been released to support the record that led to this proposed rule,” he added. 

In line with Trump directives to remove diversity, equity and inclusion policies from the federal government, OPM is also proposing to drop a requirement that performance appraisals for SES members include “leadership effectiveness in promoting diversity, inclusion and engagement.” 

Relatedly, OPM also intends to strike a directive that agency heads consider diversity and inclusion when establishing the boards that review SES performance. 

OPM’s forced distribution plan was first previewed in a February memo, which also called for making whether SES members “faithfully administered the law and the president’s policies” the “most critical element” of an appraisal. The Trump administration is also working to convert more SES positions into political appointments. 

Stakeholders can comment on the notice of proposed rulemaking through June 2.