Around 2 million federal employees are on track to soon be held to stricter standards, as the Trump administration presses forward with overhauling the government’s performance management system.
In proposed regulations issued Tuesday, the Office of Personnel Management outlined plans for removing a current ban on a “forced distribution” of federal employee performance evaluations. Once finalized, the regulations would lead to limits on how many employees can be ranked as high performers in their annual reviews.
OPM said a forced distribution system would make performance ratings “more accurate and rigorous,” hold federal employees “accountable,” and better address poor performance across agencies.
“Performance management across the federal workforce has fallen short,” OPM wrote in the Feb. 24 proposed regulations. “Even though there have been many initiatives to reform the performance management of non-SES employees, agencies continue to struggle with ensuring that an employee’s performance is accurately measured and aligns with the agency’s mission.”
OPM additionally plans to remove the prohibition on a forced distribution system for assessments of senior-level (SL) and scientific or professional (ST) employees, according to separate proposed regulations published Tuesday.
The new proposals are a step toward making permanent 2025 guidance from the Trump administration, detailing how agencies should begin to limit top performance ratings and implement faster discipline for employees who are deemed poor performers. In the proposed regulations this week, the administration said existing parameters for performance assessments have become “increasingly incompatible” with the modern federal workforce.
“Some of the current regulatory requirements present unnecessary administrative burdens, while others present barriers to implementing needed performance appraisal reform,” OPM wrote.
The proposed regulations also mirror a final rule OPM issued in September 2025, which limited top performance ratings for career members of the Senior Executive Service. This week’s proposal broadens the scope to include similar updates for virtually all federal employees, marking the largest overhaul of the government’s performance management system in 30 years.
Critics of the proposed changes have said a forced distribution system would negatively impact agency culture and innovation. They also argued that the changes may force agencies to incorrectly rate employees due to strict limits on the upper levels of performance.
The proposed regulations are designed to address what OPM described as “inflated” top performance ratings for federal employees — and what it said was a failure of the current system to “materially differentiate” between levels of employee performance.
“If relative performance is not accurately measured in an employee’s rating of record, then the entire performance management system across the government is compromised,” OPM wrote. “Poor performing employees are not being held accountable through a rigorous appraisal process.”
OPM pointed to 2013 data from the Government Accountability Office, showing high percentages of federal employees who were ranked as top performers, and 0.3% of employees who were ranked “minimally successful.” In a more recent review of performance assessments, ranging from 2022 through 2024, OPM similarly reported that higher portions of employees were rated “outstanding,” while far fewer employees received low ratings.
In addition to lifting the ban on a forced distribution system, the proposed regulations also seek to eliminate “level 2” of the government’s five-point scale for employee performance ratings. OPM wrote that a “level 2” rating is rarely used, and redundant with a “level 1” rating of “unsatisfactory.”
Removing “level 2” on the assessment scale would improve accuracy and consistency in the system, OPM said. It also pointed to the origins of the five-point system, dating back in 1983 when the government first adopted a standardized performance management system.
“While OPM determined that five summary rating levels were appropriate, it did not give much, if any, explanation to justify its position,” the proposed regulations stated.
Additionally, OPM noted that political appointees in Schedules C and G would not be subject to the performance system changes, citing concerns that supervisors may tend to give limited slots for higher ratings to non-career employees if both were included.
Federal employees who are represented by a union would also no longer be able to contest their performance rating through grievance and arbitration proceedings under OPM’s new proposal. The Trump administration argued that these procedures undermine efficiency and the integrity of employee assessments.
“Experience has shown that arbitration of performance ratings creates duplicative processes, delays the finality of ratings of record, and diverts supervisory and agency resources from mission-critical activities,” OPM wrote.
The proposed regulations also remove the current requirement that a higher-level agency official must review and approve any level 1 “unacceptable” ratings of employees. The administration reasoned that the required review process “adds unnecessary procedural complexity,” but noted that agencies can still optionally conduct the higher-level reviews if they choose.
Every other year, all agencies would have to undergo an OPM review of their performance rating system, according to the proposed regulations. The Trump administration said requiring biennial reviews would increase oversight, hold agencies more accountable and improve the “rigor” of assessments overall.
“OPM would be better equipped to identify weaknesses in agency systems, promote best practices and provide targeted guidance to improve the quality of performance evaluations,” the proposed regulations state.
As part of the proposal’s implementation, all federal supervisors and managers would also be required to complete OPM’s training program on the new performance standards.
“Too often, new supervisors receive inadequate training on identifying and addressing poor performance,” OPM wrote. “This lack of training leads to erroneous assessment of employees’ performance, often resulting in inflated ratings for poor performers.”
The proposed regulations are open to comments from the public until March 26. OPM said it’s especially looking for feedback on whether a forced distribution system will drive better culture, productivity and accountability, and what effect the system changes will have on federal recruitment and retention.
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OPM has moved to allow agencies to use forced distributions in performance ratings for GS and wage grade employees and to end the right of union-represented employees to challenge those ratings through negotiated grievance processes.
Proposed rules in the February 24 Federal Register provide for a 30-day comment period, which would leave time for finalizing them for assigning ratings during the current (fiscal 2026) evaluation cycle, as OPM director Scott Kupor recently said was OPM’s intent.
As in that statement and others from the Trump administration (including policy “compliance“), the notice asserts that job ratings—used in decisions ranging from promotions and awards to discipline and retention standing in layoffs—do not sufficiently distinguish among levels of performance.
It says that in 2024, nearly 43 percent of employees below the senior levels on a five-level summary rating system received an “outstanding” (Level 5) and another nearly 22 percent were rated as “exceeds fully successful” (Level 4). Of those under a four-level system, nine-tenths were rated in the top two levels, including 55 percent at the highest, it says.
The rules do not specify a forced ratings pattern—what the rules deem “standardized distribution”–to be used, saying that they would allow OPM to “establish and require a standardized distribution of some or all non-SES employee rating levels for agencies to apply.”
Prior statements however have used as a model the pattern now in effect for the SES that limits to 30 percent the number who can be rated in the top two levels. The proposal also reflects Kupor’s prior statement that there would be no requirement for rating a certain percentage of employees below Level 3 (“fully successful”).
Also notably, the rules would eliminate an employee’s right to grieve a performance rating through union-negotiated processes—which it says likely would increase under forced distributions “as fewer employees would receive the highest marks.”
“Experience has shown that arbitration of performance ratings creates duplicative processes, delays the finality of ratings of record, and diverts supervisory and agency resources from mission-critical activities, thereby undermining efficiency and timely accountability for performance outcomes,” the notice says, without addressing the issue of whether that process may reveal that a rating was too low.
Employees still could “request informal reconsideration of their rating,” within the agency, it adds.
OPM said it “does not believe that a standardized rating system would deny employees fair or equitable treatment, or subject them to arbitrary action.” It further said that while it “is aware of concerns that a standardized distribution of ratings could impact teamwork among employees . . . any such concerns may be addressed by making competencies like teamwork, problem-solving, collaboration, and mentoring critical elements in individual performance plans.”
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