What is the Senior Executive Service?
The Office of Personnel Management (OPM) has sent several memos to agencies this year regarding the Senior Executive Service (SES). These changes range from categorizing SES positions to the SES performance appraisal system.
The SES was created by the Civil Service Reform Act of 1978 (CSRA). It is a category of high-level positions within federal agencies providing leadership and management across the civil service. The SES consists of career executives and a smaller group of political appointees responsible for overseeing major programs, setting policy, and managing resources.
Federal Register Notice on SES Member Ratings
On May 2, 2025, the Office of Personnel Management (OPM) published in the Federal Register a proposed rule entitled Assuring Responsive and Accountable Federal Executive Management.
The purpose of the proposal is to “remove the prohibition of a forced distribution of performance rating levels within the Senior Executive Service (SES) as well as eliminate diversity, equity, and inclusion (DEI) language within SES performance management regulations.”
The rationale behind this proposal is:
Currently, agencies are prohibited from establishing quotas or limits on the number or proportion of the various rating levels assigned, meaning that each senior executive potentially can receive any rating based on their performance, irrespective of how other senior executives perform within the agency. However, governmentwide SES ratings data have consistently shown that virtually all SES receive the highest rating levels ( i.e., levels 4 and 5) despite documented reports of SES failings. Removing the prohibition on forced distribution would allow agencies to establish and enforce limits on the highest SES rating levels, thereby increasing rigor in the SES appraisal process and leading to a more normalized distribution of SES ratings across the Federal Government.
Comments on the proposal must be received by OPM on or before June 2, 2025.
This proposal follows an Executive Order issued by President Trump on January 20, 2025 entitled Restoring Accountability for Career Senior Executives.
It also follows an agency directive issued by the OPM on February 25, 2025. This directive asked agencies to send to OPM at [email protected] by March 24, 2025:
- A revised, proposed list of career reserved SES positions at the agency; and
- A list of requested redesignations of career-reserved SES positions (consistent with agency regulations and organic statutes).
At a minimum, these submissions to OPM were to include:
- SES positions designated as general SES positions on January 19, 2021.
- Career-reserved positions at the assistant secretary level or above;
- Career-reserved positions at the principal deputy assistant secretary level or
above; - Career-reserved positions at the deputy assistant secretary level or above, where
there is no general schedule SES position at the deputy assistant secretary level in that
component or office; and
SES Performance System
The OPM proposal focuses on four items it notes are “particularly relevant” to this proposal.
- The first requires OPM to “ensure that compensation, retention, and tenure are contingent on executive success.” Success should be based on individual and organizational performance.
- Second, SES members must be held accountable and responsible for effectiveness and productivity of subordinates.
- Third, administration of the SES is intended to “recognize exceptional accomplishment” by senior executives.
- Finally, OPM must ensure accountability for an “honest, economical, and efficient Government.”
The proposal contends “the vast majority of executives’ annual summary ratings are above the ‘Fully Successful’ level.”
While the vast majority of SES members consistently receive high ratings, there is a “disconnect between individual performance ratings and organizational performance is inconsistent with the statutory requirements regarding SES performance appraisal systems and unacceptable as a matter of government administration.”
As an example, it cites a Department of Veterans Affairs inspector general report about the manipulations of wait-times in a VA medical facility in Phoenix, Arizona. This report led to investigations at 93 other sites of VA health care across the country. Despite this, “80 percent of VA SES members received an ‘Outstanding’ or ‘Exceeds Fully Successful, rating.”
OPM has calculated that for the FY 2023 performance cycle, about 96% of executives received an “Outstanding” or “Exceeds Fully Successful” rating. Less than one half of 1% of executives were rated below “Fully Successful.”
Despite attempts to change, there is still a misalignment between poor agency performance and executive performance ratings. Citing the Department of Veterans Affairs again, the proposal states that in “the past two years, at least 12 VA OIG reports have identified failings directly related to widespread failures and deficiencies of VA senior leaders” and the same over-inflation of performance ratings still exists in the agency.
Forced Distribution of Ratings
The proposal seeks to reduce “leniency bias” in performance ratings. A system of forced distribution can be executed by assigning individual ranks to employees or categorizing groups of employees, such as top performers, average performers, and low performers.
The proposal concludes:
it is particularly important that the Executive Branch have the option to implement a forced distribution of at least some ratings given the systemic and pervasive use of Level 4 and 5 ratings, and the disconnect between these ratings and actual senior executive performance, as reflected in reports and critical incidents throughout the past decade.
By eliminating the prohibition on forced distributions, OPM expects that the highest ratings will be awarded only to the highest performing executives. The attempt to introduce forced distribution of SES ratings will only be applied to limit the number of level 4 and 5 SES member ratings. The proposal contends “a high-performance culture would encourage supervisors to provide poor performers ratings commensurate with their performance.”
While a forced ratings system does not now exist, removing the prohibition of forced ratings “will allow OPM to require and enforce a pre-established agency-wide and governmentwide distribution of performance ratings among all SES members….”
During the comment period, OPM is seeking comments on these topics:
- How will forced distribution reward merit, competence, and excellence across the federal government?
- Is there any research OPM should consider regarding what impact forced distribution may have on senior executive performance and organizational performance?
- Does the current SES performance management system accurately distinguish excellent from mediocre from poor performance? If so, how?
- Would a forced distribution help drive a high-performance culture across the federal government? Why?
- Would a forced distribution motivate senior executives to work harder and produce better results for the American people? Why?
- Would a forced distribution empower agency leadership to hold senior executives accountable for poor performance? Why?
- What effect, if any, would a forced distribution have on the Government’s ability to hire and retain top-level senior executive talent?
- Would a forced distribution have a positive or negative impact on knowledge management, programs, and mission delivery? Why?
- How has forced distribution of executive performance rankings worked in the private sector? Has it positively or negatively impacted corporate performance?
Conclusion and Observations
The Trump administration has focused on SES rating since the first day of the President’s inauguration. That makes sense because, as noted in the proposal, there are examples of how an agency failed to execute its mission but still handed out high SES performance ratings despite the obvious problems.
While the VA was mentioned, there are always issues that arise in the complex missions of large federal agencies. Perhaps a system such as this will create a more realistic performance system.
One other factor not mentioned in the proposal that commenters sending in proposals may want to consider: the SES members are supposed to represent the best of the federal workforce. In working as a federal employee in human resources and as the owner of a company that worked solely with federal agencies around the country, I found the SES members with whom I worked were almost always highly motivated, intelligent, dedicated people.
In some cases, these SES members were responsible for a large organization with hundreds or thousands of people and were responsible for an outlay of billions of dollars each year. In many cases, SES members are paid substantially less than they would receive with comparable responsibility in a private company—particularly when stock options and bonuses are included.
The aggregate pay (including bonuses and awards) for SES members is capped at the salary of the Vice President, which is $289,400 for 2025. In the private sector, company vice-presidents made a median salary of around $317,021 in May, 2025. The best-paid 25 percent made $368,320, while the lowest-paid 25 percent made around $275,364.
The Congressional Budget Office (CBO) has concluded in its studies that the federal government often pays employees with lower skills and education more than private firms. It also often pays less than private sector firms for employees with greater skills and education levels.
Commenters with expertise in this area may also be able to provide OPM with data or advice on salary levels for the SES, particularly with regard to how this new proposed change would have a positive or negative impact on pay for SES level federal employees.
