03/02/2026
Sisters and Brothers,
OPM just published a proposed rule in the Federal Register that could fundamentally reshape how federal employees are evaluated under 5 CFR Part 430.
If you haven’t seen it yet, here are the links:
FedSmith overview:
https://www.fedsmith.com/2026/02/24/opm-proposal-could-reshape-federal-employee-evaluations/
Official proposed rule (Federal Register):
https://www.federalregister.gov/documents/2026/02/24/2026-03619/performance-appraisal-for-general-schedule-prevailing-rate-and-certain-other-employees
What This Could Mean
This proposal would give agencies much more latitude to use forced distribution (“bell curve”) performance ratings. That means instead of rating employees based on whether they met their standards, managers could be required to rank employees against each other — guaranteeing that some percentage of your members receive lower ratings, regardless of how well everyone performed.
If you’ve ever negotiated a performance article, you already know why this is dangerous. This impacts:
Step increases
Awards
Promotions
RIF retention standing
Removal vulnerability
And overall workplace morale
And let’s be honest — when management is handed tools that allow more subjective differentiation, it rarely works in favor of bargaining unit employees.
This rule is not final. That’s the key.
There is a public comment period open right now. The deadline is March 26, 2026.
It is imperative that locals and individual members submit comments opposing any move toward forced distribution or weakened employee protections in performance systems. If we sit quietly, OPM will say, “No one objected.”
If we flood the comment docket with real stories from real federal workers explaining how this would undermine fairness, increase favoritism, and destabilize retention — that matters. The administrative record matters.
Here’s what each Local should do:
Put this on your next meeting agenda.
Send the Federal Register link to your membership.
Encourage individual comments — personalized, professional, and specific.
Consider submitting a Local-level comment outlining bargaining impacts.
This is not about politics. It’s about process and protection. Performance systems should be about objective standards — not internal competition and manufactured losers.
We fight arbitrary discipline. We fight unfair RIFs. We fight favoritism.
We should not accept a rule that structurally builds those risks into the system.
If you would like help drafting a Local comment, talking points for members, or sample language to distribute — reach out to me or your assigned NR, whichever you’re more comfortable with. That’s what we’re here for.
We cannot control every proposal that comes out of OPM. But we absolutely control whether our voice is part of the official record.
Let’s not miss this one.
In solidarity,
Shane Reedy
OPM has proposed major changes to its performance management system. It could curb ratings, allow rating distributions, and make it easier to address poor performance.
