OPM’s New Directive Reshapes Federal Performance Evaluations
Jun 18, 2025On June 17, 2025, the Office of Personnel Management (OPM) issued an 18-page memorandum that redefines the performance appraisal landscape for all federal employees. Among the sweeping changes: a mandatory unified appraisal calendar, a rigid 30-business-day Performance Improvement Plan (PIP) cap, and the quiet revival of a controversial employment category akin to Schedule F.
For federal employees, these updates aren’t theoretical—they start reshaping performance reviews this October. Here’s what to know, and what to do now.
A 30-Day PIP: Shorter, Riskier, and Legally Questionable
One of the most consequential changes is the new cap on PIPs at 30 business days. That’s roughly six workweeks to demonstrate improvement, regardless of the complexity of your duties. Legally, this could be problematic. Federal law requires agencies to provide a “reasonable opportunity” to improve, particularly for technical or nuanced roles under Chapter 43. A one-size-fits-all limit may not hold up—but waiting for the courts to intervene could leave your career exposed in the meantime.
Bell Curve Ratings and Pay at Risk
OPM’s guidance nudges agencies toward a bell-curve approach, discouraging high ratings across the board. Fewer “outstanding” evaluations could mean fewer quality step increases, bonuses, and retention incentives. Even a slip below “Fully Successful” could trigger withheld pay actions, including within-grade increases (WIGIs).
Meanwhile, supervisors will now be evaluated on how proactively they address low performers. That’s a strong incentive to initiate removals—not necessarily to coach or support.
Schedule Policy/Career: Schedule F Returns in New Clothes
Perhaps the most politically fraught element is the reintroduction of “Schedule Policy/Career.” If your position is deemed policy-influencing, you could lose key civil service protections. This echoes the Trump-era Schedule F, which faced legal challenges and was ultimately repealed. While lawsuits are expected again, relying on litigation to restore protections is a gamble no one can afford.
Six Steps to Safeguard Your Federal Career
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Archive Now – Save every version of your current performance plan before the new cycle starts October 1.
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Build a Brag File – Weekly wins, emails, metrics, and positive feedback matter more than ever.
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Clarify Expectations – Vague goals? Get them in writing. Email your supervisor: “Just confirming my performance target is…”
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Create Paper Trails – After check-ins, send a follow-up email summarizing key points.
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Call a Lawyer Early – At the first hint of a PIP or proposed adverse action, consult someone well-versed in federal sector law.
More Changes Coming
Watch for final regulations on the schedule policy/career category in the coming weeks. Union challenges to the 30-day PIP and legal scrutiny of forced ratings are also on the horizon. We’ll cover each twist in upcoming posts. You can check out the actual 18-page OPM memorandum here: FedLegalHelp.com/OPM
Legal Disclaimer: The information provided in this article is for informational purposes only and should not be construed as legal advice. While I am a federal employment attorney, this post does not create an attorney-client relationship. Every situation is unique, and legal outcomes depend on specific facts and circumstances.