As we discussed in last month’s Washington Report, the Office of Personnel Management (OPM) proposed another rule change, impacting how federal managers rank their employees, capping the number of 4s and 5s (above average) that can be given to employees. The rule change would result in a return to the “forced distribution” quota system that has been prohibited for decades. There is no cap on the number of 3s or 1s. The proposed rule also eliminates the ability to rank an employee with a 2 (minimally satisfactory).

The effort is part of the Trump administration’s effort to address inflated ratings and follows communications OPM has voiced since the summer of 2025.

FMA submitted comments to the proposed rule change, writing, “Improving accountability, reinforcing a culture of high performance, and ensuring meaningful differentiation in evaluations are important and worthwhile goals FMA supports. A well-designed performance management system can help recognize excellence, address underperformance, and better align individual contributions with agency missions. However, any approach that relies on fixed or forced distributions of ratings risks introducing unnecessary rigidity into what should be a thoughtful and evidence-based process. Requiring managers to fit employees into predetermined categories, regardless of actual performance levels, can undermine the credibility of evaluations and reduce trust in the system.”

Click here to read FMA’s full comments.

The biggest change contained in the proposed rule is the return to “forced distribution” of performance ratings, restoring a quota system artificially limiting how many employees can receive a 5 or a 4 rating. As we reported last month, agencies across the government are nearly universally opposed to this change. They argue “forced distribution” of performance ratings would cause issues in the workplace and goes against merit system principles.

OPM reports that, from FY 2022 to FY 2024, almost two-thirds of non-SES employees received a four or five rating. Only 0.6 percent of employees received a rating below a three during that timeframe. A 2016 Government Accountability Office report from 2016 found 99 percent of employees received at least a 3 (fully successful) rating.

In the rulemaking, OPM says, “The distribution of these ratings suggests there is inflation of non-SES employee ratings and poor performing employees are likely not being identified or held accountable through a rigorous appraisal process.”