I had a couple of informal conversations with Ron Sanders (who was then at OPM) when the 2004 regs were working though the approval process. The conceptual model resembles best practice from industry. There is nothing in the regs to criticize.
However, when I see 88% of the covered executives rated at the two highest performance levels, its a red flag. Of course they may all be great people -- I trust they are -- but these are very difficult jobs. And the purpose of performance management is to define what is expected foer the job and at year end to assess how well the individual perfomed in light of the expectations. At the executive level, the focus should be job-specific -- its not a beauty pageant where one executive is compared with others. Each executive should be assessed on how well he or she met or exceeded the expectations for the job.
That makes the 88% suspect -- and the credibility question undermines confidence in the process. Its not surprising a high percentafge of executives are satisfied with their rating!
Compared with industry practice, one difference stands out. Industry emphasizes the notion of 'stretch' goals. Those are goals that are difficult and challenging. The idea of course is to stretch the individual's performance. But with stretch goals, it is OK to miss a goal by a small margin. That's expected with dificutl goals. Industry would not live with 88% rated at the higher levels. The policy idea of a so-called 'forced distribution' which was adopted for several years by a number of leading corporations permitted only 20% to be rated at the 'exceeds' level. This is not suggest government should try a forced distribution policy -- I think its a bad idea -- but the contrast in thinking is striking.
I appreciate that failing to achieve a goal has political implications. That's a difficult problem to solve. But there should be an incentive to exceed goals. Industry celebrates and rewards executives who exceed their goals.
The UK senior civil service pay and performance system appears to be working much better.