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Well, that's nothing new, it's at least been a thing for the last 20 years I've been working.
Best use of that I've seen was a manager that always pushed to get new headcount, and then never wanted to fill it. Because the company counted cancelling unfilled positions toward a departments required layoff requirements, so several layoff rounds spared every actual employee in his department.
That works until the company re-evaluates how many people that team needs...
It probably contributed to them kicking him out of management one day.