The report said that OPM has focused attention on the percentage of senior executives who receive the highest summary appraisal rating, with the result of substantial decreases since 2003, the last year of the old system, in the percentages of execs receiving those top ratings.
CRS attributed some of the shift to a number of large departments and agencies shifting away from three-level ratings systems to those using four or five levels.
"Awarding the top-level rating to all, or virtually all, senior executives in a given agency would not appear to meet OPM’s broad concept of ‘meaningful distinctions.’ However, because OPM at present is emphasizing only the percentage of executives who receive the top-most rating, it is conceivable that an agency could, in a five-level appraisal system, cluster virtually all of its senior executives at the top two rating levels as long as the percentage of individuals who receive the highest rating does not exceed certain levels," the report said.
OPM has asserted that agencies are doing a better job of making distinctions between levels of performance, CRS said, but some execs suspect that supposedly banned forced ratings are being applied.
CRS said that apart from some anecdotal evidence in several agencies that has not been examined fully, "there does not appear to be any data available that either confirms or disproves the use of quotas. For this and other reasons, forced distributions could remain a sensitive issue for some time, particularly if similar pay-for-performance systems are implemented throughout the federal government."