Welcome to the Wild West
An Uncertain Future for Performance Appraisals.
Most employees and supervisors undervalue performance appraisals. While many are just going through the motions, the performance management process serves an important purpose. Performance standards provide clear expectations. They tell you what to do and how to do it. Performance appraisals tell you whether you are meeting those standards. They are also used to determine recognition and awards, and they can be used to inform future hiring decisions. Performance ratings are also one of four factors considered during a reduction in force (RIF), which is probably on the mind of every federal employee this year.
Over the last year, we’ve seen the Office of Personnel Management (OPM) emphasize the importance of accurate performance ratings, even making moves to elevate performance over seniority in a RIF. This makes OPM’s latest guidance, which eliminates performance appraisal requirements for certain groups of federal employees, puzzling. Keep reading to learn more about OPM’s unusual guidance and what impact this guidance may have on the future of performance appraisals for all federal employees.
New Day, New Guidance.
On April 28, 2026, OPM issued guidance to exclude federal employees occupying Schedule C and Schedule G positions from the performance appraisal requirements of 5 USC Chapter 43. (OPM’s April 2026 Memo) No performance standards. No progress reviews. No rating.
Why would OPM make this move? The memo states that employees appointed under Schedule C and G are political appointees and they are “effectively ‘at-will’ employees.” They reason that retention and removal actions for these employees do not depend on formal performance ratings; therefore, ratings are not needed. They also note that there is a 2010 administrative freeze on awards and bonuses for employees serving on political appointments (OPM’s August 2010 Memo), which eliminates the argument that ratings are necessary to justify performance-based awards. However, the memo acknowledges that Schedule C and G employees remain eligible for Within Grade Increases (WGI) under the 2010 guidance. WGIs are periodic pay increases that are based on employee performance. Employees must be performing at an “acceptable level of competence” to receive the WGI and this determination is made by looking at the employee’s last performance rating. With no rating, how will agencies determine if a Schedule C or G employee is performing at an acceptable level of competence? The memo simply says that the agency “must establish procedures for making acceptable level of competence determinations based on performance appraisal requirements established by the agency.” They further state that agencies have the “discretion to design appraisal approaches that meet their needs.”
What are Schedule C and Schedule G?
Schedule C and Schedule G are authorities used for political appointments. These positions are not subject to competitive hiring procedures (unlike most federal jobs), and employment in these positions is generally limited to the term of the Administration in which the employee was appointed. For example, current Schedule C and G employees will be expected to depart their positions when President Trump’s term ends. Schedule C and G employees are also considered “at-will” employees, and they generally do not have appeal rights to the Merit Systems Protection Board (MSPB).
Schedule C was established in 1956. It is used to appoint people to political positions that are “confidential” or “policy-determining” in nature and that do not require Senate confirmation. These positions are generally GS-15 and below, and could include special assistants, advisors, policy experts, and other similar roles. In March 2026, the Partnership for Public Service reported that there are currently 1,835 Schedule C political appointees serving in government. They also note that this is largest political workforce in the US government in at least 40 years.
Schedule G is the new kid on the block. It was established in July 2025, and it is intended to hire employees into “policy-making” and “policy-advocating” roles. I could not find concrete numbers on how many (if any) Schedule G employees are currently serving in government, but most of the guidance I could find on Schedule G seemed to mirror Schedule C. These similarities may lead you to question the purpose of Schedule G. The White House claims that Schedule G was created to fill “an existing gap in federal employee classifications” by creating a new path to hire employees who will be engaged in “policy-making or policy-advocating” work. (Schedule G Fact Sheet) They are distinguishing the “confidential” and “policy-determining” work of Schedule C and the “policy-making” and “policy-advocating” work of Schedule G. However, critics argue that the work is so similar that there is no meaningful distinction here, and Schedule G is just another tool to bring more political appointees into the federal workforce – filling roles that are normally held by career employees.
Don’t get these two authorities confused with Schedule Policy/Career (P/C). Schedule P/C is another new appointing authority. It was announced via Executive Order on January 20, 2025, and it covers career (non-political) positions that are “confidential, policy-determining, policy-making, or policy-advocating.” (Schedule P/C Executive Order) While the position functions are the same as Schedule C and G, Schedule P/C is intended to be used for career positions while C and G are only used for political appointments. Federal agencies have been instructed to review current, career positions and recommend positions for transition over to Schedule P/C. OPM issued final regulations to implement Schedule P/C on February 5, 2026; however, as of the date of this post, no positions have been transferred over. Positions cannot be transferred over until the President issues an executive order placing positions into Schedule P/C, and we are still waiting on that order. Like with Schedule C and G, employees whose positions are transitioned to Schedule P/C will be exempt from the adverse action and performance-based action procedures of 5 USC Chapters 43 and 75. This means they are also “effectively ‘at-will’ employees” who generally cannot appeal personnel actions to the MSPB.
The Forecast.
You might be asking yourself – why does this matter? With such a small population of Schedule C and G employees, there will likely be little immediate impact to the federal workforce at large and probably zero impact to you personally. However, this could be an indication of future moves by OPM. If OPM uses the “at-will” status to justify the elimination of performance appraisals for Schedules C and G employees, will they do the same for future Schedule P/C employees? In April 2025, the White House said that OPM estimates that 50,000 employees (2% of the federal workforce) will be transitioned to Schedule P/C. (Schedule P/C Fact Sheet) If this policy is expanded to include P/C employees, you can expect a much greater impact.
I am also not convinced that the elimination of performance appraisals is a good move, even if the employees are considered “at-will.” How will the agency assess whether these employees are successfully performing the function they were hired to do? How will retention decisions be made? How will employees be held accountable? To me, this seems to open the door for arbitrary action by management and more uncertainty for employees. Any management decision (whether it is impacting an “at-will” employee or a career employee) should be based on solid business reasons and should be well documented. “At-will” designations shouldn’t turn the workplace into the Wild West, and the absence of meaningful standards and evaluation will create a workplace that is ripe for abuse. To be fair, OPM says agencies can develop their own processes for Schedule C and G WGI determinations, which could be a form of evaluation, but OPM’s failure to create a government-wide standard will lead to inconsistency in both process and application. Further, they didn’t suggest that these WGI determination processes will be used to document retention or removal decisions.
Finally, I must point out how incompatible this guidance is with OPM’s July 2025 performance management guidance. (OPM’s July 2025 Memo) The July 2025 guidance emphasized the importance of creating a “high-performance” culture, standardized the government-wide performance cycle, provided guidance on clear and measurable standards, and directed new supervisory training. Also, in March 2026, OPM proposed a new rule that would prioritize performance over seniority in a RIF. But, considering this new guidance, is OPM’s goal still high-performance culture and accountability, or is it simply to find the easiest route to removal?
Unfortunately, I’m left with more questions than answers on this one. While the overall impact is minimal today, this policy shift has the potential to upend future performance management practices and leave more employees in the dark.
