OPM April 28 Memo: Why Schedule C and G Skip Performance Reviews Now

Last Updated: May 11, 2026 Reading Time: 8 min

On April 28, 2026, OPM Director Scott Kupor issued a memo telling agencies to immediately stop applying formal performance appraisal requirements (5 CFR Part 430, Subpart B) to GS employees on Schedule C and Schedule G appointments. No more performance standards. No more progress reviews. No more annual ratings of record. The headline reaction across federal employee forums was "political appointees are getting bonuses without earning ratings", but that's not what this memo does. A separate freeze on monetary awards for political appointees, in place since August 3, 2010, still blocks the bonuses. What the April 28 memo actually removes is paperwork that had no bonus-generating function for these employees anyway. The exemption affects roughly 1,500-1,700 Schedule C positions plus the newer Schedule G class created by Executive Order 14317 in July 2025. The bigger question, flagged by FedWeek analysts: could the same exemption be the template for Schedule Policy/Career, up to 50,000 CAREER positions? This is what Kupor's memo actually says, what changes for political appointees, what does NOT change for the career employees who report to them, and the precedent risk worth watching.

Key Takeaways

• April 28, 2026 OPM memo: Schedule C and Schedule G GS appointees no longer subject to 5 CFR Part 430 performance appraisals
• Statutory authority: 5 USC 4301(2)(G); regulatory: 5 CFR 430.202(c)
• Affected: ~1,500-1,700 Schedule C + Schedule G positions (count not yet disclosed)
• 2010 bonus freeze still applies. No discretionary monetary awards, no QSIs. Memo does not unlock bonuses.
• Within-grade increases (WGIs) still available under 5 USC 5335 via informal "acceptable level of competence" procedures
• At-will removal still applies (Schedule C/G are political appointees, no Chapter 43 PIPs, no Chapter 75 protections)
• Career subordinates unaffected. A Schedule C/G supervisor can still rate, discipline, and recommend actions for competitive-service subordinates under standard Chapter 43
• Precedent risk: FedWeek flags this as a possible template for Schedule Policy/Career exemption (up to 50,000 career positions)
• Separately pending: FR 2026-03619 proposed rule (Feb 24, 2026) would tighten ratings for career service in the OPPOSITE direction, comment period closed March 26, 2026

What the Memo Actually Does

Before April 28, 2026	After April 28, 2026
Schedule C/G GS employees had written performance standards	No required performance standards
Mandatory mid-year progress reviews	No required progress reviews
Annual rating of record (Outstanding / Fully Successful / etc.)	No required formal rating
WGI tied to Chapter 43 "acceptable level of competence" determination	WGI still available; agencies set own informal procedures
Removal could go through Chapter 43 PIP / ODAP procedures (rarely used for at-will appointees)	At-will removal continues (no change; political appointees were already removable at will)
2010 bonus freeze in effect	2010 bonus freeze still in effect

The memo does not change anyone's pay, removal authority, or bonus eligibility. It removes paperwork.

The Bonus Confusion

The most common misreading of this memo is that it unlocks bonuses for political appointees. It does not.

The 2010 freeze (Obama memo Aug 3, 2010) prohibits:

• Performance-based cash awards for political appointees
• Quality Step Increases (QSIs)
• Any discretionary monetary bonus

The 2010 freeze has survived:

• Obama's second term
• Trump's first term
• Biden's term
• Trump's second term (still in force as of May 2026)

What the freeze does NOT block:

• Time-off awards (still allowed)
• Nonmonetary awards (certificates, plaques)
• WGIs (statutory advancement, not discretionary)
• Promotion-based salary increases

So if you've heard the claim "political appointees are getting bonuses without ratings," it's wrong on two grounds: (1) they couldn't get bonuses anyway under the 2010 freeze, and (2) the exemption only removes the paperwork, not the bonus restriction.

Reference Map: The Federal Hiring Schedules

Schedule	What It Covers	Career or Political	Subject to Chapter 43?
Schedule A	Non-competitive (e.g., attorneys, certain disabilities)	Career	Yes
Schedule B	OPM-waived competitive	Career	Yes
Schedule C	"Confidential or policy-determining"	Political	NO (per April 28, 2026)
Schedule D	Pathways (Recent Grads, PMF)	Career	Yes
Schedule G (new July 2025)	"Policy-making or policy-advocating, transitions with administration"	Political	NO (per April 28, 2026)
Schedule Policy/Career (formerly Schedule F)	"Confidential, policy-determining, policy-making, or policy-advocating"	Career	YES (for now; precedent risk)

The critical line is between Schedule G (political, exempted) and Schedule Policy/Career (career, NOT yet exempted). Same authorizing statutory framework. Different employee status. The exemption could legally be extended to Schedule Policy/Career under 5 USC 4301(2)(G) without new legislation.

What Changes for Career Civil Servants Who Report to Schedule C/G Supervisors

Your appraisal rights are unchanged. If you are a competitive-service GS employee, the standard Chapter 43 framework still applies to YOUR appraisals:

• 5 CFR 430.207: written performance standards
• 5 CFR 430.208: progress reviews
• 5 CFR 430.209: annual rating of record
• 5 CFR 430.211: appeal/grievance rights for unfair ratings

Your supervisor can still rate you. The exemption is positional (their position is exempt), not contagious. A Schedule C/G supervisor with no rating of their own can still:

• Establish your performance standards
• Conduct your progress reviews
• Issue your annual rating of record
• Recommend personnel actions (PIP, removal, awards)

The dynamic that matters: Schedule C/G supervisors typically turn over with each presidential transition. Your performance record is captured in writing during their tenure but stays in your OPF/eOPF and travels with you to the next supervisor.

What to Do This Week If You Report to a Political Appointee

1. Confirm your appointment type. Pull your SF-50 and check Block 24 (Tenure). You should be 1 (career) or 2 (career-conditional). If you are inadvertently classified as Schedule C, you've inherited at-will status without realizing it.
2. Document everything in writing. Your performance log, supervisor feedback, accomplishments, completed projects, awards received. The lack of formal rating from your supervisor doesn't reduce the importance of YOUR contemporaneous record.
3. Get your annual rating before your supervisor leaves. If a presidential transition is approaching, push to complete your rating cycle before the political appointee departs. The next administration's appointee will not have observed your work.
4. Save your prior ratings. RIF retention register placement uses 4 prior ratings (5 CFR 351.504). If you anticipate a RIF, your last 4 ratings are the most important paperwork in your file.
5. If your supervisor is suddenly performing more aggressive at-will removals of subordinates, ensure your union (where still recognized) is aware. The Schedule C/G exemption removes performance paperwork but not the supervisor's authority to drive Chapter 75 adverse actions against career staff.

The Schedule Policy/Career Watch

OPM finalized the Schedule Policy/Career rule (formerly Schedule F) on February 5-6, 2026 (FR 2026-02375). It applies to up to 50,000 career federal positions in "confidential, policy-determining, policy-making, or policy-advocating" roles.

As of May 2026: career employees in Schedule Policy/Career classifications are still subject to Chapter 43 performance appraisals. The April 28 memo did NOT extend the exemption to them.

The precedent risk: the legal authority Kupor invoked (5 USC 4301(2)(G), 5 CFR 430.202(c)) does not strictly require a position to be "political" to be exempted. OPM determines the exemption based on its judgment. If OPM later determines that Schedule Policy/Career positions also warrant exemption, the legal framework already exists.

Combined with the proposed FR 2026-03619 rule (forced rating distribution, supervisory critical element, Level 2 removal), there's a coherent policy direction emerging:

• Tighten ratings for the bulk of competitive service
• Loosen ratings for political and "policy-influencing" career positions
• Effect: easier to discipline career line employees; less paperwork for politically-aligned managers

Watch for any OPM announcement extending the appraisal exemption beyond Schedule C and G. That's the moment when the affected employee count jumps from ~3,500 to ~53,500.

Calculate Options if You Are Reassessing Federal Service

The Schedule C/G appraisal exemption is a process change, not a benefits change. But if you're rethinking your federal trajectory in this environment:

• VERA/VSIP Decision Calculator if you've been offered a buyout
• FERS Retirement Calculator to model retirement timing
• Severance Pay Calculator to estimate statutory entitlement under 5 USC 5595
• High-3 Calculator to lock in baseline before any salary changes

Frequently Asked Questions

What did Kupor's April 28, 2026 memo do?

OPM directed agencies to stop applying 5 CFR Part 430 performance appraisals to Schedule C and Schedule G GS appointees. No standards, no progress reviews, no annual rating. Statutory authority: 5 USC 4301(2)(G).

Are political appointees now getting bonuses without ratings?

No. The 2010 Obama bonus freeze still applies. Political appointees cannot receive performance cash awards or QSIs.

Can a Schedule C/G supervisor still rate me if I'm career?

Yes. The exemption is positional, not contagious. They can still rate, discipline, and recommend actions for competitive-service subordinates under standard Chapter 43.

How many employees does this affect?

~1,500-1,700 Schedule C positions plus Schedule G (count not yet disclosed). Combined under 3,500.

Could Schedule Policy/Career be next?

FedWeek analysts and others flag this as a probable next step. Up to 50,000 career positions could be affected. As of May 2026, no extension has been announced.

What about the 2026 proposed performance appraisal rule?

FR 2026-03619 (Feb 24, 2026) would tighten career-service appraisals (forced rating distribution, supervisory critical element, Level 2 removal). Comment period closed March 26, 2026. Not yet final.

Related Resources

• Federal Hiring Loyalty Question: related controversial OPM hiring policy
• MSPB 4 Appeal Stages: if performance changes lead to adverse action
• DoD Union Contract Termination Survival Guide: related EO 14251 CBA termination context
• VA Vigil Investigations + Federal Whistleblower Rights 2026
• VERA/VSIP Decision Calculator
• FERS Retirement Calculator
• Severance Pay Calculator

Sources

• OPM CHCOC Memo: Performance Appraisals for Schedule C and G Employees (April 28, 2026)
• 5 USC 4301 (definitions, exclusion authority)
• 5 USC 5335 (within-grade increases)
• 5 CFR Part 430 Subpart B (performance appraisal regulations)
• 5 CFR 430.202 (exclusion authority)
• 5 CFR 213.3301 (Schedule C)
• Executive Order 14317 (Schedule G, July 17, 2025; FR 2025-13925)
• Schedule Policy/Career Final Rule (FR 2026-02375, February 5-6, 2026)
• Proposed Performance Appraisal Rule FR 2026-03619 (February 24, 2026)
• Obama 2010 Political Appointee Bonus Freeze Memo (August 3, 2010)
• NARFE: OPM exempts Schedule C and G employees from performance appraisals
• FedWeek: Coverage of Kupor memo
• FedSmith: OPM Schedule C/G appraisal exemption analysis