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To meet the certification criteria, agencies are expected to make distinctions in rates of pay, pay increases, and/or performance awards. The Act only freezes pay adjustments, and does not affect the agency's ability to grant performance awards to career executives. Therefore, agencies can make the pay distinctions required for performance appraisal system certification in their bonus decisions. OPM is aware the Act prohibits agencies from making pay increases and would consider this in applying the certification criteria.
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