The Department of Defense and nearly all other federal agencies expressed significant concerns with a potential Office of Personnel Management proposed rulemaking that would limit how many employees can be ranked “above average,” and other efforts to revamp performance management, including removing the level 2 (minimally satisfactory) rating, among others.

Government Executive researched comments on OPM’s proposal, revealing near unanimous pushback from all agencies, who argue a “forced distribution” of performance ratings would cause issues in the workplace and goes against merit system principles.

The Department of Defense (DOD) strongly recommends retaining the prohibition on forced distribution, writing, “decades of management research, and the subsequent reversal of this policy by many private sector organizations, confirm that forced ranking systems degrade organizational effectiveness.” The ban on forced distribution has been in place for more than thirty years. DOD references merit systems principles in its comments, noting performance must “be assessed against an individual’s own success in meeting objective criteria, not their standing relative to others in a mandated quota.”

In addition to DOD, other agencies who have weighed in with criticism against the proposed rulemaking include NASA, Treasury, HUD, Energy, Labor, HHS, and more.

OPM rejected recommendations from the Executive Office of the President to refer to the new rulemaking as a “curve” or “stacked ranking” in lieu of “forced distribution.” OPM responded its phrasing is more accurate, provided “significant explanations on the benefits,” of the rulemaking, and provided “recent ratings data” illustrating the need for the proposed rule.

OPM intends to implement the new rating system for the current fiscal year review season, although Government Executive reporting indicates some agencies are already utilizing elements of the plan – including forced distributions.