Why not?

Look at how many buildings 'HQ' has. Create new departments and sections here and there, with their own sets of senior directors, directors, deputy directors, SADs, ADs, lead manager, senior manager, manager, assistant manager.

See, so many new positions created.

Also, can speed up attrition at the top, and also post officers out of MOE to other ministries. In HQ, there are quite a number of officers and senior management who were posted in from other ministries. If they can come to MOE, surely those in MOE can go to other ministries too.

If there's a will, there's a way