
OPM has formally set a general cap that no more than 30 percent of the SES may receive a rating at one of the top two levels effective with the fiscal 2026 ratings cycle, meanwhile saying that agencies additionally use it “as general guidance” in finalizing ratings in the 2025 cycle.
A memo at www.opm.gov/chcoc/latest-memos expands on rules published in the Federal Register that had not explicitly set that percentage limit on those rated at Level 4 or 5 but had instead referred to earlier guidance advocating for the same figure. The limit applies only to agencies with at least 5 SES members and the President may waive the cap at an agency “by certifying outstanding SES performance” there.
“Noncareer SES appointees are excluded from this forced distribution requirement and are not included in calculating an agency’s 30% limitation. An Office of Inspector General should calculate its 30% limitation separately from its parent agency. Agencies should update their FY 2026 SES performance guidance accordingly,” it says.
It adds, “As a reminder, while there is no expectation that agencies apply a forced distribution of SES ratings for FY 2025, agencies should treat the 30% cap on Levels 4 and 5 for career SES set forth in OPM’s SES Performance Appraisal System as general guidance for ensuring ‘performance evaluation results that make meaningful distinctions based on relative performance.’”
The memo also reminds agencies of prior guidance regarding the makeup of performance review boards, including that those boards “should be staffed with people committed to rigorous performance management who are committed to a fair and thorough process, and political leadership should be actively involved as members.”
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