‘A rushed and complicated system.’ Federal employees say they’re in the dark over limited top ratings 

Federal agencies are crunching the numbers on how many employees they can justify getting above-average scores in their upcoming performance reviews, after the Trump administration put a cap on top marks across the federal workforce. 

The Office of Personnel Management in September directed agencies to limit top scores – an “outstanding” score of five, and an “exceeds fully successful” score of four –  to no more than 40% of their General Schedule employees during this year’s performance review cycle.

At OPM’s direction, agencies have also stood up “calibration” panels staffed with senior executives to ensure managers and supervisors are awarding ratings fairly. 

“A calibration panel is not a rating board that re-rates employees independently. The panel evaluates whether proposed ratings are supported by evidence, applied consistently across organizations, and aligned with agency performance standards,” OPM wrote in guidance this summer. 

OPM finalized regulations in July that removed a longstanding ban on a forced distribution system. The federal HR agency wrote that limiting the number of top scores that employees can receive “will curb ratings inflation and increase accountability” across the federal workforce. 

Experts in public-sector performance management say calibration panels can help weed out bias in performance scores. But combined with the rollout of a new forced distribution system, they warn this new rating system may pit employees against each other for a limited number of top scores, undermining the collaborative nature of some jobs.

Meanwhile, federal employees and their managers say they’ve been left in the dark about how these sweeping changes are being carried out. 

The rollout

Federal workers told Government Executive that several agencies provided little information on how they should prepare self-evaluations that will serve as the basis for their final performance evaluations, and offered few details on the criteria senior officials will use to distribute a limited number of fours and fives. 

Some have been told by their agencies that a three – which equates to “meets expectations” – is the default score that many employees will receive. Several managers said these constraints prevent them from giving high-performing employees the scores they deserve.  

An IRS manager told Government Executive their program manager “didn’t want to see” any fives or fours – and that a “fully successful” score of three out of five “is what is expected across the board.” 

“I’m sick of this constant abuse on good employees. Morale is low – really low,” the IRS manager said. 

A manager at the Veterans Affairs Department said four of his five direct reports have “quantifiably achieved at least a 4, but I’m not allowed to give them all a final rating that high.” 

“I hate the concept, but what I hate even more is that we weren’t notified of this plan before we issued the FY26 performance plans. Had we been notified first, we could have written the plans in a way that aligns to the rating system,” the VA manager said. 

A supervisor at the Labor Department’s Mine Safety and Health Administration said the agency has instructed managers to lower employee ratings before they are sent to the calibration panels. 

“I am a rating official, I rated my employees and the reviewing official concurred. Then the ratings were shared with leadership. Leadership met with us and told us the ones that need to be lowered,” the MSHA supervisor said.

The MSHA supervisor said these instructions from agency leadership were “to show the calibration process is not needed,” and that MSHA’s ratings are “already within the 40% of ‘exceeds’ and ‘outsandings.’” 

These annual reviews carry material consequences for federal workers. Earning top scores make some federal workers eligible for financial and time-off awards. Low scores could also make it easier for agencies to remove certain employees. OPM in July finalized a rule emphasizing recent performance reviews over tenure when carrying out reductions in force. 

Government Executive reported in January that most agencies sought to push back against OPM’s plan. In internal comments, many warned that enforcing a forced distribution of performance ratings contradicts merit systems principles and reduces collaboration and cohesion among employees.

Deadlines and training bottlenecks

Employees at the Health and Human Services Department told Government Executive that departmentwide and component agency-level trainings on these changes have been unable to accommodate all those looking to attend.

A recent meeting for Food and Drug Administration employees “started off with them having to re-send a link to let in everyone who wanted to attend,” according to an FDA employee who attended. At an HHS-wide meeting, “once again the online meeting did not have enough capacity for all who wanted to attend.” 

“We’re scoring people on things we haven’t communicated,” a second FDA employee said, summing up communications from agency leadership about the performance evaluation changes. 

This communication gap is mirrored in internal directives obtained by Government Executive, which outline strict timelines and calibration steps that managers must obtain behind closed doors. 

In a message to employees, HHS wrote that OPM “will allocate a fixed number” fives to the department, and that the “HHS calibration process will ensure that HHS does not exceed its allocation.” 

“The purpose of standardized distribution is not to predetermine individual ratings or replace rigorous performance appraisal. Rather, it is intended to support consistent distinctions among levels of performance across the Department,” HHS wrote.

An HHS spokesperson told Government Executive that the department is following OPM’s latest guidance on performance awards. An OPM spokesperson Kiki Nyoh said in a statement that a 40% cap on above-average performance ratings “best balances meaningful, standards-based ratings with recognizing outstanding performance." 

“We will closely monitor FY 2026 results and use that data to guide future appraisal cycles,” Nyoh said.

The American Federation of Government Employees Local 2883, which represents employees at the Centers for Disease Control and Prevention’s headquarters in Atlanta, told members in a recent email that HHS is rushing supervisors to “carry out a rushed and complicated system,” and that setting employees up to compete for a limited number of top scores undermines the collaborative nature of its scientific mission.

“CDC works because people collaborate. That is how public service works,” the union wrote. “A system that requires supervisors to rank teammates against one another risks turning people with a shared mission into competitors for limited recognition. It further erodes trust and creates exactly the wrong incentive for an institution like CDC.”

HHS employees had until Oct. 16 to complete a 6,000 maximum character “self-accomplishment narrative” highlighting their key accomplishments. Rating officials – usually an employee’s immediate manager or supervisor – will soon draft a “summary” of each employee’s self-evaluation, assign a preliminary rating and then rank all employees under their supervision.

According to internal documents obtained by Government Executive, each rating official must “rank each employee relative to the total number (N) of employees they supervise.” Each rating official’s preliminary scores and employee rankings will undergo “review and calibration” by agency-level and department calibration panels.

“Final ratings distribution will be reviewed and approved at the HHS level,” the memo states. Employees will be able to request reconsideration of their final ratings within five business days of receiving them. 

“All ratings and narratives are preliminary and must not be discussed with or provided to employees at any time prior to them being approved by HHS senior executive leadership,” the memo states.

HHS employee evaluations will focus on three criteria – “organizational value,” “quality & reliability of demonstrated performance,” and “timeliness and efficiency of results.”

In one document outlining its “calibration factors,” HHS asks rating and reviewing officials to consider how an employee’s work advanced “organizational priorities or mission,” how often employees made mistakes in their work, and whether employees consistently met deadlines. But the document states that this information “should not be discussed with or provided to employees.” 

Timelines and anxiety

A similar process is being rolled out at the Homeland Security Department, although some of the criteria employees are being evaluated on vary. Self-assessment forms at the Federal Emergency Management Agency ask employees to evaluate how well they’ve carried out the “administration’s priorities” – which include “executive orders, governmentwide directives [and] efficiency efforts.”

In a presentation to employees, FEMA officials stated that the new forced distribution system is “not a predetermined rating,” and “not a quota assigned to individual employees.” The presentation slides also state this new performance rating system “does not mean employees all receive the same rating.”

According to internal documents obtained by Government Executive, FEMA employees had until Sept. 30 to complete their self-assessments. Self-assessments are voluntary but highly encouraged,” one internal document states. 

FEMA’s calibration panel will review employees’ preliminary ratings between mid-October and early November. Final ratings will be determined by Nov. 20 after DHS-level calibration. Employees will be notified of their final ratings in December. Performance awards are tentatively scheduled for February 2027.

The agency’s calibration panel will be led by a group of senior agency employees from each FEMA program office. According to internal documents, the calibration panel will “review preliminary ratings for consistency, fairness and alignment.”

A FEMA employee said staff are concerned their final performance ratings “will come from a panel of senior leaders who don’t know anything about our individual programs.”

“There is an incredible amount of lack of information at nearly every level in FEMA about this,” the FEMA employee said. “Nobody knows how the panels are being selected, what they are supposed to calibrate, and what the point of this new system is that isn’t already being accompanied by the current system.”

“The unspoken fear on everybody’s minds is that assessments from our supervisors and our self-assessments will be used to essentially grade everyone in the department ‘on a curve’ and then use that as a metric to start identifying people as ‘legitimate’ targets for being fired,” the FEMA employee said.

A second FEMA employee stressed the rushed rollout of changes this big, adding that, “in more normal times, they would have started socializing this months in advance.”

“It’s a huge ask for everyone, particularly leadership because they have to figure out and communicate the new system to their teams with little to no guidance,” the second FEMA employee said.

A Customs and Border Protection employee said a similar process is rolling out across DHS. 

“The panels review proposed ratings for consistency. They compare across work units and they verify that the ratings are justified by evidence,” the CBP employee said. DHS and FEMA did not immediately respond to requests for comment. 

Weighing the limits

Bob Tobias, distinguished practitioner in residence at the Key Executive Leadership Program at American University and former president of the National Treasury Employees Union, said performance management research shows that “those who perform at the highest level are those who are informed of what the goal is, and regularly informed about whether or not they're reaching that goal.” 

“Right now, no one knows what behavior is being asked to be changed,” Tobias said. “All that's happening is a group of people at the end of the process are now evaluating employees. I do not believe that that approach will achieve a goal of increasing organizational performance or individual performance.”

Ellen Rubin, an associate professor of public administration and policy at the University of Albany, said research shows calibration ensures managers are applying the same standards consistently across different teams of employees, and can flag potential bias or discrimination before ratings are finalized.

“Calibration sessions – on their own, in theory – are a good thing,” Rubin said. “But when you introduce the forced distribution rating system, it cuts the legs out from the benefits that could potentially be realized.”

Rubin said a forced distribution system doesn’t root out poor performers, and that creating a scarcity of top scores “undermines collaboration” in team projects. 

“There’s decades of research showing that forced distribution rating systems demotivate employees, and lead to ratings that employees think are often unfair,” she said. “There's also a pretty high incidence of force distribution rating systems leading to discrimination complaints. So generally, they are a terrible idea.” 

Tobias said OPM’s rollout of a forced distribution system is starting from the assumption that “we've got too many people who are evaluated too high.” A 2016 Government Accountability Office report that found in 2013, 99% of employees received at least a “fully successful” rating. 

“If I'm an employee and I get my evaluation, and then all of a sudden instead of being in the top 20%, I'm in the middle, how is that change going to inspire me next year? I don't know why my evaluation’s changed. The whole evaluation process is to give me information so that I can perform better next year. That doesn't happen with this system,” Tobias said.