Trying to automate Performance documents but System Account is restricted from accessing

Summary:

We have 3,000+ interns for the summer, and we have been planning to use a system account to automate Anytime Documents for their review. Managers email the review, and then the system account takes those reviews, creates an Anytime Document, and everything gets entered on time and accurately. This was working fine through testing, but with the 25B update, suddenly the system account could no longer access Performance Documents.

We opened an SR, had an OWC, and then heard back a few days later that this was expected behavior. Performance Documents access is now restricted to only user accounts tied to a person record. Our system accounts are user accounts only, no worker or contingent record attached to them, so this is a blocker. We have discussed creating a generic worker record to attach the system account to, but HR has raised some concern about potential Headcount issues this could cause. Has anyone else experienced this, or know a