Does the Student Career Employment Program Still Exist? A Comprehensive Guide to Federal Pathways Programs

Navigating Federal Careers: Understanding the Pathways Programs Framework

For students and recent graduates aspiring to public service, navigating the landscape of federal employment can be complex. You might be asking, “Does The Student Career Employment Program Still Exist?” While the exact terminology may have evolved, the spirit of these programs thrives today through the Pathways Programs. This guide, drawing from official sources, clarifies the structure of these programs and answers your key questions about accessing federal internships and career opportunities.

What are the Pathways Programs?

The Pathways Programs are not a single entity but a framework encompassing three distinct programs designed to bridge the gap between education and federal employment. These programs utilize Schedule D excepted service appointments to offer students and recent graduates valuable experiences and potential career paths within federal agencies:

• Internship Program: Tailored for students from high school through graduate levels, this program provides paid work opportunities within federal agencies. It’s a chance to explore federal careers while still pursuing education. Eligibility extends to those enrolled at least part-time in various educational programs, including Registered Apprenticeships and certain volunteer service programs. To become eligible for conversion to the competitive service, interns must complete a minimum of 480 internship hours, although a waiver reducing this to 320 hours is possible under certain conditions.

• Recent Graduates Program: This program is designed to provide recent graduates with structured career development within federal agencies. It offers one- to two-year developmental experiences. Applicants must have recently graduated from a qualifying educational institution or career and technical education program, typically within the past two years. Veterans who were prevented from applying due to their service obligations have an extended application window of up to six years post-graduation.

• Presidential Management Fellows (PMF) Program: Considered the federal government’s premier leadership development program, the PMF Program is a highly selective two-year program for advanced degree candidates and graduates. PMFs are provided with mentors, participate in professional development activities, and complete at least 160 hours of formal, interactive training. This includes an Individual Development Plan and at least one developmental, rotational assignment to broaden their experience. Eligibility is limited to individuals who have obtained an advanced degree (master’s, professional, or doctorate) within the preceding two years.

Where to Find the Regulations Governing Pathways Programs?

The rules and regulations for the Pathways Programs are formally documented in the Code of Federal Regulations (CFR) under Title 5 CFR parts 362, 213, 302, and 315. For detailed information, you can refer to these specific sections:

• 5 CFR part 362, subpart A: Outlines the general rules applicable to all Pathways Programs.
• 5 CFR part 362, subpart B: Details the specific regulations for the Internship Program.
• 5 CFR part 362, subpart C: Focuses on the rules pertinent to the Recent Graduates Program.
• 5 CFR part 362, subpart D: Covers the specific guidelines for the PMF Program.
• 5 CFR 213.3401-2: Provides general provisions concerning Schedule D of the excepted service, which is the basis for Pathways appointments.
• 5 CFR part 302: Regulates the procedures for filling excepted service positions, including the application of veterans’ preference within these programs.

Agencies are advised to consult these regulations directly when hiring through the Pathways Programs and to seek legal counsel for any interpretive questions.

Pathways Programs Eligibility: Who Can Apply?

Internship Program Eligibility Requirements

To be eligible for the Internship Program, applicants must meet one of the following criteria:

• Enrollment in a Qualifying Educational Institution: Applicants must be accepted for enrollment or currently enrolled and actively pursuing a degree (diploma, certificate, etc.) at a qualifying educational institution. Enrollment must be at least half-time, as defined by the institution.
• Enrollment in a Qualifying Career or Technical Education Program: Eligibility also extends to individuals accepted for enrollment or enrolled in a qualifying career or technical education program that awards a recognized postsecondary credential. This includes Registered Apprenticeship Programs and Job Corps.

Even if an individual needs to complete less than a half-time course load to graduate, they remain eligible under this program, ensuring flexibility for those nearing the completion of their studies.

Recent Graduate Program Eligibility Requirements

For the Recent Graduates Program, eligibility is based on educational attainment within a recent timeframe. Applicants must have obtained one of the following within the 2 years prior to applying:

• An associate’s, bachelor’s, master’s, professional, doctorate, vocational, or technical degree.
• A certificate from a qualifying educational institution.
• Completion of a qualifying career or technical education program.

This broad range of qualifications ensures that recent graduates from various educational paths can access these federal career opportunities.

Defining Qualifying Career and Technical Education Programs

To clarify what constitutes a qualifying career or technical education program, the Pathways Programs specify three types of programs that meet the eligibility criteria:

• Federally Administered Educational Programs: These programs are characterized by rigorous academic content, technical skill development, and the awarding of a recognized postsecondary credential. They are designed to prepare individuals for further education and/or careers in current or emerging professions.
• Registered Apprenticeship Programs: These structured programs combine on-the-job training with related technical instruction, leading to nationally recognized credentials in various skilled occupations.
• Federally Administered Volunteer Service Programs: This category includes local, state, national, or international volunteer service programs that are administered by the federal government, providing valuable experience and skills development.

Federally Administered Career or Technical Education Program Oversight

A program is considered “Federally administered” if it is subject to programmatic oversight by a federal agency. This oversight includes several key aspects:

• Nature and Scope of Work: Defining the tasks and responsibilities participants will undertake.
• Type and Scope of Training: Specifying the educational and skill-building activities provided to participants.
• Skills Development: Identifying the specific skills participants are expected to acquire or develop (e.g., teaching, environmental work, business skills, scientific expertise, public health, language proficiency).
• Mentoring Level: Determining the level and extent of mentoring provided to participants to support their development.
• Program Completion Metrics: Establishing measurable criteria for successful program completion.

This programmatic oversight is often formalized through partnership or cooperative agreements, ensuring structured and quality educational experiences.

Acceptable Documentation for Internship Program Eligibility

Agencies require documentation to verify eligibility for the Internship Program. Acceptable forms of documentation include:

• Transcripts: Official or unofficial academic transcripts.
• Diplomas: Copies of diplomas or certificates of degree completion.
• Written Documentation: Letters from the educational institution or career/technical program confirming enrollment or acceptance into a qualifying program.

This flexibility in documentation allows applicants to easily provide proof of their eligibility.

Acceptable Documentation for Recent Graduate Program Eligibility

Similarly, for the Recent Graduate Program, agencies accept various forms of documentation to confirm eligibility, including:

• Transcripts: Official or unofficial academic transcripts.
• Diplomas: Copies of diplomas or certificates of degree completion.
• Written Documentation: Official documents from the educational institution or career and technical education program that substantiate eligibility criteria outlined in 5 CFR 362.302.

The documentation must clearly provide the following information:

• Applicant’s Name: To identify the individual.
• Degree or Program Name: Specifying the qualification obtained.
• Completion Date: Date of degree or program completion (or expected completion date).
• Program Length: For certificate programs or volunteer service programs, information on the duration of the program is necessary to confirm it meets the minimum requirements.

Applying to the Recent Graduates Program Before Degree Completion

It’s important to note that applicants do not need to have already completed their degree or career/technical education program to apply for the Recent Graduates Program. Students in their final weeks or months of study are encouraged to apply. However, they must meet the definition of a recent graduate as per 5 CFR 362.302 before their appointment start date.

Agencies have the discretion to set specific deadlines related to education completion, such as application closing dates, certificate issuance dates, or appointment dates. Any such conditions must be clearly stated in the agency’s Pathways policy and application procedures, as per 5 CFR 302.301.

Defining a Valid Certificate Program for Pathways Eligibility

The Pathways Programs regulation (5 CFR 362.102) defines a certificate program as post-secondary education that meets specific criteria:

• Qualifying Educational Institution: The certificate program must be offered by a qualifying educational institution, such as a trade or vocational school, a 2-year or 4-year college or university, or a graduate or professional school. It must be equivalent to at least one academic year of full-time study and be part of an accredited curriculum.
• Qualifying Career or Technical Education Program: Alternatively, a certificate program can be from a qualifying career or technical education program, also requiring at least one year of study and awarding a recognized postsecondary credential.

This definition ensures that certificate programs offer substantial educational value and are comparable in rigor to academic degree programs.

Citizenship Requirements for Pathways Programs

Regarding citizenship, the requirements for Pathways Programs vary. While there is no overarching rule mandating U.S. citizenship for excepted service positions, several factors influence this:

• Agency Restrictions: Many federal agencies are restricted from using appropriated funds to pay non-citizens due to annual appropriations legislation or other agency-specific statutes. Each agency must determine if such restrictions apply to their hiring practices, in consultation with their legal counsel.
• Legal Residency: Even if an agency can hire non-citizens, a non-citizen applicant for a Pathways Program position must be lawfully admitted to the United States as a permanent resident or otherwise be authorized to work in the U.S.
• Conversion to Permanent Employment: Crucially, to be eligible for non-competitive conversion to permanent federal employment in the competitive service after completing a Pathways Program, an intern, recent graduate, or fellow must possess full U.S. citizenship by the end of their program.

Therefore, while non-citizens may participate in Pathways Programs under certain conditions, U.S. citizenship is a prerequisite for conversion to permanent competitive service positions.

Public Notification for Pathways Positions

Options for Public Notification

Public notification is a crucial aspect of the Pathways Programs, ensuring transparency and open competition. Agencies have two primary methods to meet the public notification requirement (5 CFR 326.104(c)(6)(iii) and 362.105(b)):

• USAJOBS.gov Posting: Agencies can post a searchable job announcement directly on USAJOBS.gov, the federal government’s official employment website. This makes the opportunity visible to a wide range of potential applicants.
• Agency Website Posting with USAJOBS Link: Alternatively, agencies can post job information on their own public-facing career or job information web page. This posting must include a direct link to a USAJOBS custom job announcement, ensuring applicants can access full details and application procedures via USAJOBS.

In addition to these mandatory methods, agencies are encouraged to enhance their recruitment efforts by utilizing supplementary channels like third-party websites and social media platforms to further publicize Pathways opportunities.

For PMF Program positions, agencies post opportunities on the PMF Program’s Talent Management System (TMS) when recruiting finalists, catering to the specific recruitment process of this program.

Required Information in Job Announcements

To ensure job announcements for Pathways Internship and Recent Graduate positions are effective and informative, they must include at minimum the following details:

• Position Details:
  • Position title, series, and grade level.
  • Starting salary.
  • Geographic location(s).
• Qualifications: Minimum qualifications required for the position.
• Application Information: Clear instructions on how to apply or a link to the agency’s website with application details.
• Equal Opportunity and Accessibility Statements:
  • Reasonable Accommodation statement, ensuring accessibility for applicants with disabilities.
  • Information on how to claim veterans’ preference, outlining the process for veterans to assert their preference.
• Program Specific Information:
  • Information about the possibility of conversion to permanent appointment, if applicable to the position.
  • Promotion potential, if the position offers career advancement opportunities.

The Office of Personnel Management (OPM) also recommends including the following additional information to make announcements even more comprehensive:

• Job Description: A brief overview of the duties and responsibilities.
• Work Schedule: Available work schedules (e.g., full-time, part-time).
• Pathways Program Links: Direct links to official Pathways Programs information resources for applicants seeking more context.
• Incentives: Information on relocation expenses or recruitment incentives, if applicable to attract candidates to specific locations or positions.

By including these details, agencies ensure that potential applicants have all the necessary information to assess their suitability and interest in Pathways positions.

Career Fairs and Public Notification Requirements

Agencies sometimes participate in career fairs or host their own recruitment events. However, it’s crucial to understand that agencies cannot solely rely on career fair participation to meet the public notification requirement for Pathways positions.

Agencies must still provide public notification through USAJOBS or their agency website with a USAJOBS link, as described earlier, even when attending career fairs. Furthermore, to ensure fair access for all potential candidates, agencies must provide an alternative method of application for individuals who are unable to attend the career fair or recruitment event. This ensures that opportunities are not limited to those physically present at a specific event.

Managing High Application Volumes

Agencies may be concerned about receiving an overwhelming number of applications in response to Pathways job announcements. To manage this effectively and efficiently, agencies have several options at their disposal:

• Limited Announcement Period: Agencies have the flexibility to set the opening and closing dates for job announcements. By strategically limiting the announcement period, agencies can control the application window. The duration should be reasonable, considering factors like the position type, grade level, and geographic location. For instance, a short-term summer internship in a specific location might not require as long an open period as a specialized technical internship at headquarters.
• Application Limits: Agencies can set ‘cut-offs’ or limits on the number of applications they will review. For example, they might decide to consider only the first 75 or 100 applications received. If using such limits, OPM strongly recommends agencies accept all applications submitted up to 11:59 p.m. on the day the limit is reached to accommodate applicants in different time zones.
• Specific Eligibility Requirements: Agencies can establish specific eligibility criteria beyond the basic Pathways requirements to narrow down the applicant pool. For Internship Programs, this might include requirements like the ability to work a specified number of hours per week or maintaining a minimum GPA. However, agencies must be careful not to impose educational requirements for positions that don’t typically require specific coursework, unless there is a valid job-related justification. Agencies may also require applicants to confirm their availability to work in the specific location(s) listed in the announcement.

Any procedures for limiting applications must be clearly outlined in the agency’s procedures for receiving applications (5 CFR 302.201) and must be stated in the Pathways job opportunity announcements themselves. Agencies must always consider merit system principles, ensuring fair and open competition and equitable treatment for all potential applicants. Consulting with agency counsel is advisable when implementing these strategies.

Utilizing USAJOBS Custom Postings

What is a USAJOBS Custom Posting?

A USAJOBS custom posting offers agencies a more targeted approach to public notification. Unlike standard USAJOBS announcements that are broadly searchable on the USAJOBS website, a custom posting is accessible only through a unique link or URL. While the job posting is stored within the USAJOBS system, it is not discoverable through general searches on USAJOBS.

If the “Apply Online” option is enabled for a custom posting, applicants benefit from being able to track their application status within USAJOBS, and agencies gain access to post-audit applicant flow data, which can be valuable for analyzing hiring trends and recruitment effectiveness.

Meeting Public Notification with Custom Postings

The Pathways Programs public notification requirement can be effectively met using USAJOBS custom postings. This is achieved when the agency actively shares the custom posting link with the public. The most common method is to post the link prominently on the agency’s own website, particularly on its careers or jobs page.

Agencies can further leverage custom postings by distributing the link through other recruitment and advertising channels, such as social media platforms or third-party job boards that cater to specific student or recent graduate audiences.

Strategic Use Cases for Custom Postings

While OPM encourages agencies to utilize standard USAJOBS postings for broad visibility, there are situations where custom postings are particularly advantageous. Custom postings are beneficial when agencies want to target specific applicant pools or manage visibility in certain contexts.

Even when using custom postings instead of traditional USAJOBS announcements for Pathways positions, agencies still retain the benefit of receiving applicant flow data, similar to standard USAJOBS postings. This data can inform future recruitment strategies and program adjustments.

Creating a USAJOBS Custom Posting

The process of creating a custom job posting is managed within the Talent Acquisition System (TAS), the system used by federal HR professionals for job postings on USAJOBS. Once a custom posting is created within TAS, the HR specialist responsible for the posting receives a unique URL. This URL is the key to accessing the custom posting and is what the agency will share on its website, social media, or other recruitment materials.

Resources for Custom Posting Information

For detailed, step-by-step instructions on how to create a custom posting, agencies should reach out to their agency’s designated Talent Acquisition System (TAS) point of contact. These contacts are trained on using TAS and can provide specific guidance. For broader questions or support related to custom job postings, agencies can also contact the dedicated recruiter help email address provided by USAJOBS: [email protected].

Recruitment Strategies for Pathways Programs

Outreach Activities Before Public Posting

Agencies have the flexibility to engage in outreach activities even before or without formally posting a USAJOBS announcement or custom posting for Pathways positions. These outreach efforts can take various forms:

• Informational Events: Hosting or participating in events aimed at raising awareness about federal careers and the Pathways Programs.
• Liaison Activities: Establishing and nurturing relationships with educational institutions, career services offices, and relevant student organizations.

These preliminary outreach activities are valuable for building interest in federal careers and creating a pipeline of potential Pathways applicants.

Strategic Outreach for Diverse Applicant Pools

To build a diverse and high-quality applicant pool, agencies are encouraged to incorporate strategic outreach and recruitment efforts as part of their overall recruitment plan. This proactive approach helps ensure that opportunities are accessible to individuals from all segments of society.

It’s essential that strategic outreach is viewed as one component of a broader recruitment strategy. Crucially, public notice of Pathways opportunities through USAJOBS or agency websites remains a fundamental requirement to maintain fairness and open competition. Outreach should complement, not replace, public notification.

On-Campus Recruitment Events: Announcement Requirements

When agencies decide to hold or attend on-campus recruitment events with the intention of accepting applications for Pathways Program positions, specific information must be included in the public announcement. This announcement should be posted on USAJOBS or the agency’s public-facing career or job information web page to ensure broad awareness. The announcement must include:

• Event Details:
  • Location of the event (campus, building, room).
  • Date and time of the event.
  • Any relevant information on accessing the event location, including accessibility information for persons with disabilities (reasonable accommodation details).
• Position Information:
  • Position title, series, and grade level of the jobs being filled.
  • Geographic location of the jobs.
• Application Information:
  • A publicly accessible source (e.g., a link on the agency’s webpage) that provides information on how to attend the event and, importantly, how to apply for those who cannot attend in person. This ensures that individuals not able to attend the event are not excluded from consideration.
• Veterans’ Preference: Information on how to claim veterans’ preference during the application process, ensuring veterans are aware of their rights and how to exercise them.

By providing this comprehensive information, agencies ensure that on-campus recruitment events are transparent, accessible, and effectively publicized.

Effective Practices for Pathways Recruitment

OPM encourages agencies to adopt effective practices to enhance their recruitment for Pathways positions. Key recommendations include:

• Workforce Planning Driven Recruitment: Align recruitment strategies with agency workforce planning goals to ensure Pathways programs effectively address future workforce needs.
• Diverse Talent Sources: Conduct strategic recruitment across a variety of talent sources to attract qualified applicants from all segments of society, promoting diversity and inclusion.
• Spectrum of Campuses/Schools: Recruit from a diverse range of campuses and schools, not just a select few, to broaden the reach and attract talent from various academic backgrounds.
• Open On-Campus Events: Ensure that on-campus recruitment events are open to all interested individuals, not exclusively to students of the host campus. Agencies must provide an adequate alternative means of applying for those who cannot attend, along with comprehensive information about the opportunities.

To further enhance outreach, agencies should make students and recent graduates aware of key online resources:

• USAJOBS Website: Promote USAJOBS.gov as the central hub for federal job opportunities.
• Federal Internship Portal: Direct students to the Federal Internship Portal (https://intern.usajobs.gov/) for internship-specific listings.
• Recent Graduate Portal: Guide recent graduates to the Recent Graduate Portal (https://recentgrad.usajobs.gov/) for program-specific opportunities.

When planning on-campus recruitment, agencies should consider the proximity of the campus to the job location. A feasible commute is essential for students to benefit from on-campus events and subsequent Pathways opportunities.

Veterans’ Preference and Pass Overs in Pathways Programs

Application of Veterans’ Preference

Yes, agencies are required to apply veterans’ preference when making selections for Pathways Programs positions. This is mandated by 5 CFR 362.105(c)(2), reinforcing the federal government’s commitment to supporting veterans’ employment.

How Veterans’ Preference is Applied

The specific procedures for applying veterans’ preference in Pathways Programs are governed by 5 U.S.C. 3320, 5 CFR 302, and any relevant agency policies. The application method depends on the selection process chosen by the agency, which generally falls into three categories under 5 CFR part 302:

• Ranked List: This method resembles the ‘rule of three’ used in the competitive service.

  • Applicants are evaluated against job-related criteria and receive numerical scores.
  • Preference eligibles who achieve a passing score receive additional points (5 or 10 points, as applicable) added to their score.
  • Applicants are ranked by score, and selections are made from the top three available names on the list.
  • Veterans with a 10% or more disability are placed at the top of the list, ensuring highest ranking.
  • Agencies cannot select a non-preference eligible veteran over a preference eligible veteran with an equal or higher score without following proper ‘pass over’ procedures.

• Unranked List: Applicants meeting basic eligibility are categorized by veterans’ preference status:

  • 10% or more disabled veterans (highest preference).
  • Other 10-point preference eligible veterans.
  • 5-point preference eligible veterans.
  • Non-preference eligible veterans (lowest preference).
  • Agencies must consider candidates in the highest preference group first.
  • A non-preference eligible veteran can only be selected if all preference eligibles are exhausted or if proper ‘pass over’ procedures are completed for remaining preference eligibles.

• Category Rating-Like Process: Agencies can create their own systems for applying veterans’ preference, provided they offer at least as much advantage to preference eligibles as the ranked or unranked methods (5 CFR part 302.105). Many agencies use a category rating-like process, similar to category rating in the competitive service:

  • Applicants are assessed against agency-established criteria and placed into quality categories (e.g., ‘highly qualified,’ ‘qualified’).
  • Preference eligibles are listed ahead of non-preference eligibles within each quality category.
  • Veterans with a 10% or more disability are placed in the highest quality category, ahead of non-preference eligibles.
  • Selections are made from the highest quality category.
  • A non-preference eligible can only be selected if preference eligibles in the top category are exhausted or after ‘pass over’ procedures for remaining preference eligibles in that category.
  • Agencies can select any preference eligible veteran within the highest quality category.
  • If fewer than three people are in the top category, agencies can merge the highest and second highest categories, ensuring all preference eligibles from both are listed before non-preference eligibles in the merged category.

• Professional Order (GS-9 and Above): For professional and scientific positions at the GS-9 level and above, rules differ slightly.

  • Ranked List: Preference points (5 or 10) are added to scores for preference eligibles who achieve a passing score. Ranking and selection from the top three are similar to the general ranked list method, but there is no ‘floating’ of 10-point disabled veterans to the top.
  • Unranked List: Qualified preference eligibles are listed by preference status (10-point veterans then 5-point veterans), followed by other qualified applicants. Agencies must consider preference eligibles in the highest preference group first. Non-preference eligibles can only be considered after preference eligibles are exhausted or after ‘pass over’ procedures.

Pass Over Procedures for Veterans with Less Than 30% Disability

For preference eligible veterans without a compensable disability of 30% or more, a ‘pass over’ is required if an agency wishes to select a non-preference eligible candidate. A pass over means the agency must justify why a preference eligible veteran is not selected.

A preference eligible veteran can be removed from consideration only if the agency sustains the selecting official’s objection for adequate reasons. These reasons must be documented and can include:

• Medical Disqualification: Reasons based on medical criteria as per 5 CFR Part 339.
• Suitability Determination: Reasons based on suitability criteria outlined in 5 CFR 731.202.
• Other Agency-Considered Reasons: Other valid reasons deemed appropriate by the agency.

Agencies must be mindful of 5 U.S.C. 3320 and 5 CFR 332.406 when considering pass over reasons and should consult legal counsel to ensure reasons meet the standard of selections being made “in the same manner and under the same conditions required for the competitive service.”

OPM approval is required for medically disqualifying or passing over a preference eligible to select a non-preference eligible based on medical reasons. The preference eligible veteran (or their representative) is entitled to receive a copy of the agency’s pass over reasons upon request.

Pass Over Procedures for Veterans with 30% or More Disability

For preference eligible veterans with a compensable disability of 30% or more, special ‘pass over’ procedures are in place, as mandated by 5 U.S.C. 3312, 5 CFR 339.102(c), and 332.406, particularly when medical disqualification due to physical requirements is considered:

• Dual Notification: The agency must simultaneously notify both OPM and the disabled veteran in writing about the reasons for potential disqualification and the veteran’s right to respond to OPM within 15 days.
• Proof of Notification: The agency must provide evidence to OPM that the notification was sent to the veteran’s last known address in a timely manner.
• OPM Determination: OPM is responsible for determining the veteran’s physical ability to perform the job duties, considering any information provided by the veteran. The agency must provide sufficient evidence supporting their request, including proof that reasonable accommodation is not feasible and that the veteran cannot perform essential job functions without endangering themselves or others.
• Further Information: OPM may request more detailed information from the agency.
• OPM Decision and Agency Action: If OPM agrees with the agency, the agency can select another qualified candidate. If OPM finds the veteran capable, the agency cannot pass over the veteran based on physical requirements.
• Position Availability: These procedures do not prevent the agency from filling other positions if multiple openings exist from the same candidate list, allowing the position for the veteran in question to remain open pending OPM’s decision.
• OPM Notification and Compliance: OPM will notify both the agency and the disabled veteran of its decision, which the agency must adhere to.
• Non-Delegation: OPM’s authority in these pass over procedures cannot be delegated to any agency.

For non-medical reasons for passing over a veteran with a 30% or more disability, the following special provisions apply (5 U.S.C. 3318 and 5 CFR 332.406):

• Dual Notification: Similar to medical pass overs, the agency must notify both OPM and the disabled veteran in writing, stating the reasons for the proposed pass over and the veteran’s right to respond to OPM within 15 days.
• Proof of Notification: Agency must provide evidence of timely notification to the veteran’s last known address.
• OPM Review and Determination: OPM will assess if the pass over request is for a proper and adequate reason under regulations and evaluate the sufficiency of evidence, considering any veteran-provided information.
• Further Information: OPM may request more details from the agency.
• OPM Decision and Agency Action: If OPM sustains the pass over request, the agency can select another qualified candidate. If OPM does not sustain the request, the agency cannot pass over the veteran based on the presented reason.
• Position Availability: Similar to medical pass overs, these procedures do not prevent filling other positions if multiple openings exist.
• OPM Notification and Compliance: OPM will notify the agency and the preference eligible or disabled veteran of its decision, which is binding on the agency.
• Non-Delegation: OPM’s pass over authority cannot be delegated.

Schedule A Hiring Authority and Pathways Programs

Agencies cannot use the Schedule A hiring authority for People with Intellectual Disabilities, Severe Physical Disabilities, and Psychiatric Disabilities to appoint individuals to Pathways Program positions. Schedule A and Pathways Programs are distinct hiring authorities with separate eligibility criteria and processes.

Applicants with disabilities can apply for Pathways Programs positions through the standard application process detailed in job opportunity announcements on USAJOBS (https://help.usajobs.gov/working-in-government/unique-hiring-paths/students). Students with disabilities are considered for Pathways positions under the same provisions as non-disabled students, as per 5 CFR part 302. Agencies are legally obligated to provide reasonable accommodations as needed and should consult with their HR or legal offices on these matters.

Qualifications and Assessments for Pathways Programs

Assessment Requirements in Selection Processes

For both the Internship and Recent Graduate Programs, agencies are mandated to use valid, job-related assessments as part of their selection process. These assessments can include:

• Crediting Plans (Rating Schedules/Occupational Questionnaires): These are structured tools used to evaluate applicants based on their knowledge, skills, and abilities relevant to the position.
• Structured Interviews: Standardized interview processes designed to systematically assess candidates’ qualifications and competencies.

Agencies are also permitted to use the Administrative Careers With America (ACWA) rating schedules when evaluating candidates for Pathways Programs positions.

Depending on the specific selection methodology used for a particular job (refer to 5 CFR part 302), agencies may choose to assess only for general eligibility or minimum qualifications at certain stages of the process. For the PMF Program, OPM itself uses assessments to create a list of finalists, reflecting a centralized assessment process for this program.

OPM Qualification Standards for Recent Graduates

The Pathways regulations stipulate that recent graduates must meet OPM Qualification Standards. This means agencies cannot create their own agency-specific qualification standards for Recent Graduates Program positions.

Agencies are required to use the OPM or OPM-approved qualification standards that are applicable to the specific position being filled. If any qualification standards are mandated by law for a particular position, those must also be followed. This ensures consistency and government-wide standards for Recent Graduate positions.

Qualification Standards for Pathways Internship Positions

In contrast to the Recent Graduate Program, agencies are not required to use OPM Qualification Standards for Pathways Internship Positions. Agencies have greater flexibility and can choose to:

• Establish agency-specific qualification requirements tailored to their needs.
• Use the OPM qualification requirements for the competitive service as a guideline.
• Utilize the Group Coverage Qualification Standard for Schedule D, Pathway Internship Positions. This standard provides a government-wide framework but is not mandatory.

This flexibility allows agencies to design internship qualification requirements that best suit the nature and objectives of their internship programs.

Assessments in Selection Process (Reiterated)

(This section is a duplicate in the original text and is therefore also repeated here for completeness, though it should be noted that the content is identical to the first “Assessment Requirements in Selection Processes” section.)

For the Intern and Recent Graduate Programs, agencies must use valid job-related assessments such as crediting plans, which are the same thing as rating schedules (i.e., occupational questionnaires) or structured interviews. Agencies may also use the Administrative Careers With America (ACWA) written test or ACWA rating schedules when making selections for Pathways Programs positions. Depending on the selection methodology used to fill a particular job (see 5 CFR part 302), agencies may assess only for general eligibility/minimum qualifications. OPM assesses for a list of Finalists for the Fellows Program.

Promotions and Reassignments within Pathways Programs

Promotion Eligibility for Interns

Yes, interns appointed without a “not to exceed” (NTE) date are eligible for promotion without further public notification or competition. This is possible if:

• The agency has an excepted service policy in place that specifically allows for the promotion of employees in excepted service positions.
• The intern meets the qualification requirements for the higher-graded position.

However, interns appointed with an NTE date are considered similar to temporary employees and are not eligible for promotion.

Reassignment of Interns with NTE Dates

Agencies can reassign an intern with an NTE date to a different intern position, but there are specific procedures to follow:

• Internal Public Notification: The agency must provide minimum public notification, but internally within the agency (not on USAJOBS). This notification should be directed to similarly situated agency interns who might also be interested in the intern position.
• Competitive Selection if Multiple Interests: If more than one intern expresses interest in the reassignment, the agency must apply selection procedures as outlined in 5 CFR part 302. This includes applying veterans’ preference and following pass over procedures, ensuring fairness and transparency.
• Application Across Positions: These procedures apply whether the new intern position is part of a career ladder, in a different job series, in a different series with a career ladder, or even if it’s at the same series and grade level as the intern’s current NTE position.

Reassignment of Interns Without NTE Dates

For interns without NTE dates, agencies have more flexibility in reassignment:

• Agency Policy: Agencies must adhere to their own established policies for the movement of excepted service personnel.
• Qualification Requirements: The intern must meet the qualification requirements for the position to which they are being reassigned.

Public notification and competition are not required for reassignments of interns without NTE dates, provided agency policies and qualification requirements are met.

Reassignment of Recent Graduates

Similar to interns without NTE dates, reassignments for Recent Graduates within the same agency are governed by:

• Agency Policy: Agencies must follow their internal policies for the movement of excepted service personnel.
• Qualification Requirements: The Recent Graduate must meet the qualification requirements for the new position.

Public notification and competition are not mandatory for reassignments of Recent Graduates within the same agency, provided agency policies and qualification standards are met.

Time-in-Grade Limitations for Pathways Participants

No, Interns, Recent Graduates, and PMFs in Pathways Programs positions are not subject to time-in-grade limitations (5 CFR 300 subpart F) before being promoted. Time-in-grade restrictions only apply to movements within or into the competitive service.

However, it’s important to note that:

• Qualification Requirements Still Apply: Pathways participants must still meet the qualification requirements for promotion to a higher grade level.
• Promotions are Not Automatic: Promotions are never guaranteed.
• Agency Policy Required: Agencies must have an excepted service policy in place that governs promotions for positions within the excepted service, including Pathways positions.

Training and Development for Pathways Programs

Individual Development Plans (IDPs) for Interns

Yes, OPM mandates that agencies provide all Pathways interns with appropriate training and development activities, regardless of the length of their appointment (5 CFR 362.203(i)).

While not strictly required for all interns to have a formal IDP, OPM recommends the following:

• IDP or Training Plan for Longer Appointments: For interns appointed for an initial period expected to last more than 1 year, and for intern NTEs appointed for more than 90 days, agencies should ensure that a training plan, Individual Development Plan (IDP), or a Pathways Participant Agreement is documented within 45 days of appointment and approved by the supervisor. This plan should outline the intern’s training and development activities.

Types of Training Activities for Interns

Agencies have flexibility in the types of training activities they provide to Pathways interns. Appropriate options may include, but are not limited to:

• On-the-Job Training: Practical learning through direct experience and guidance from supervisors and colleagues.
• Formal Training Classes: Structured courses and workshops to develop specific skills and knowledge.
• Mentoring Sessions: Guidance and support from experienced professionals within the agency.
• Practical Assignments: Engaging in activities like testing products or tools relevant to their field.
• Project Support: Assisting colleagues with ongoing projects and tasks, contributing to real-world agency work.

The key is to provide interns with diverse learning experiences that contribute to their professional growth and understanding of federal service.

Temporary Detail Assignments for Interns and Recent Graduates

Yes, at the discretion of the home agency, both interns and recent graduates can participate in temporary detail assignments at another federal agency. This provides valuable opportunities for:

• Broadening Experience: Gaining exposure to different agency missions, functions, and work environments.
• Networking: Expanding professional networks and building relationships across the federal government.
• Skill Development: Acquiring new skills and perspectives through diverse assignments.

The decision to allow detail assignments rests with the intern’s or recent graduate’s home agency, considering factors such as program goals and operational needs.

Conversion to Competitive Service from Pathways Programs

Changes to Intern Conversion Requirements

Recent updates to the Pathways Internship Program have brought about positive changes to the conversion process, making it more accessible and flexible:

• Extended Conversion Period: The timeframe for agencies to convert interns non-competitively to the competitive service has been extended from 120 days to 180 days after the completion of the intern’s degree or educational program. This provides agencies with more time to complete the conversion process.
• Reduced Minimum Work Hours: The minimum number of work hours required for intern conversion has been reduced from 640 hours to 480 hours. This lower threshold makes conversion eligibility more attainable for many interns.

However, agencies retain the option to require more than the minimum 480 hours for conversion, as detailed below.

Start of the 180-Day Conversion Clock

The 180-day period for non-competitive conversion begins when the student completes their educational requirements, as officially determined by their educational institution or career and technical education program.

It’s important to note that this clock starts upon completion of requirements, not necessarily on the formal graduation date or degree conferral date, which may occur later. Agencies should rely on the educational institution’s determination of when degree or program requirements are fulfilled.

Impact of Extended Conversion Period on Current Interns

The extension of the conversion period to 180 days, effective June 11, 2024, benefits current interns who are in the process of completing their degrees.

• Retroactive Benefit: Any intern who had not yet exceeded the previous 120-day limit as of June 11, 2024, becomes eligible for the extended 180-day conversion period.
• Example: An intern who completed their degree on May 4, 2024, would have had a conversion deadline of September 1, 2024, under the 120-day rule. With the new 180-day rule, their deadline is now extended to October 31, 2024, providing additional time for conversion.

Agency Authority to Require More Than Minimum Work Hours

Yes, while the minimum work hour requirement for intern conversion has been reduced to 480 hours, agencies are permitted to require more than 480 hours for conversion.

• Agency Discretion: Agencies have the authority to set higher minimum hour requirements and may even establish different minimums for various positions or job types based on their specific needs and program goals.
• Policy Specification: Any agency-specific minimum hour requirements above 480 hours must be clearly outlined in the agency’s Pathways Policies, ensuring transparency for interns.

Criteria for Waiving Intern Work Hour Requirements

Agencies have the flexibility to waive a portion of the intern work hour requirement under specific conditions (5 CFR 362.204(d)). A waiver can be approved if:

• Minimum Hours Completed: The intern has completed at least 320 hours of career-related work experience under a Pathways Internship Program appointment. No waiver is possible if fewer than 320 hours are worked.
• Exceptional Job Performance: The intern has demonstrated exceptional job performance, as evidenced by a formal performance evaluation from their supervisor(s) resulting in a rating of record or summary rating higher than “fully successful” or equivalent, consistent with the agency’s performance appraisal program.
• High Potential: The intern demonstrates high potential in their academic or career and technical education program, meeting at least one of the following criteria:
  • Overall GPA of 3.5 or better on a 4.0 scale.
  • Standing in the top 10% of their graduating class.
  • Induction into a nationally recognized scholastic honor society.
  • A letter of recommendation from an instructor or program administrator attesting to outstanding performance.

The maximum waiver amount is up to one-half of the minimum service hour requirement.

Examples of Waiver Application:

• Example 1: Intern works 320 hours; agency can waive 160 hours (half of 480 minimum).
• Example 2: Intern works 420 hours; agency can waive 60 hours (to reach 480 minimum).
• Example 3: Intern works 220 hours; no waiver possible until at least 320 hours are completed.
• Example 4 (640-hour agency minimum): Intern works 320 hours; agency can waive 320 hours (half of 640 minimum).
• Example 5 (800-hour agency minimum): Intern works 480 hours; agency can waive 320 hours (up to half of 800 minimum).

Determining Exceptional Job Performance for Waivers

To assess “exceptional job performance” for waiver eligibility, agencies must rely on a formal evaluation conducted by the intern’s supervisor(s). This evaluation should be:

• Formal: Not just informal feedback, but a structured assessment.
• Consistent with Agency Appraisal Program: Aligned with the agency’s established performance appraisal system.
• Higher Than Fully Successful: Resulting in a rating of record (official performance rating) or a summary rating that is above the “fully successful” level or its equivalent in the agency’s system.

This ensures a consistent and documented measure of high performance.

Determining High Potential in Education Programs for Waivers

To determine if an intern has demonstrated “high potential” in their academic or career and technical education program, agencies should look for evidence of at least one of the following indicators:

• High GPA: An overall grade point average of 3.5 or higher on a 4.0 scale.
• Class Rank: Standing in the top 10% of the student’s graduating class.
• Honor Society Membership: Induction into a nationally recognized scholastic honor society, signifying academic excellence.
• Recommendation Letter: A strong letter of recommendation from an instructor or program administrator that specifically attests to the intern’s outstanding performance and potential within their educational program.

These criteria provide objective and credible measures of an intern’s academic promise.

Crediting Non-Federal Internship Experience

Agencies can grant credit toward the Internship work hour requirement for prior non-Federal internship experience in specific circumstances. This is applicable when:

• Non-Federal Internship at Federal Agency: The non-Federal internship was served at a federal agency but through a third-party internship provider (not directly under a federal Pathways appointment).
• Minimum Pathways Hours Completed: The intern has subsequently completed at least 320 hours of career-related work experience under a Pathways Internship Program appointment. Credit for non-Federal experience is not possible until 320 Pathways hours are completed.

The maximum credit an agency can grant for non-Federal internship experience is up to half of the minimum service work hour requirement for Pathways interns.

Examples of Crediting Non-Federal Internship Experience:

• Example 1: Intern completes non-Federal internship, then 320 Pathways hours; agency can credit 160 non-Federal hours (half of 480 minimum).
• Example 2: Intern completes non-Federal internship, then 420 Pathways hours; agency can credit 60 non-Federal hours (to reach 480 minimum).
• Example 3: Intern completes non-Federal internship, then 220 Pathways hours; no non-Federal credit possible until 320 Pathways hours are completed.
• Example 4 (640-hour agency minimum): Intern completes non-Federal internship, then 420 Pathways hours; agency can credit 220 non-Federal hours (to reach 640 minimum).
• Example 5 (800-hour agency minimum): Intern completes non-Federal internship, then 420 Pathways hours; agency can credit up to 320 non-Federal hours (up to half of 800 minimum).

Documentation for Waiver Approval

When approving a waiver of the Internship work hour requirement, agencies should carefully review documentation that substantiates both exceptional job performance and high potential. Acceptable documentation includes:

• Performance Rating: Documentation of a performance rating (rating of record or summary rating) that is higher than “Fully Successful” or its equivalent.
• Evidence of High Potential (at least one of the following):
  • Official or Unofficial Transcript: Showing a GPA of 3.5 or better or class rank in the top 10%.
  • Honor Society Acceptance Letter: Proof of acceptance into a nationally recognized scholastic honor society.
  • Recommendation Letter: A letter from an instructor or program administrator specifically attesting to outstanding program performance and potential.

This documentation ensures a well-supported and justifiable waiver decision.

Conversion from Intern to Recent Graduate Program

No, agencies cannot non-competitively convert a Pathways intern to the Pathways Recent Graduates Program upon completion of their academic requirements.

• Intern Conversion to Competitive Service Only: Pathways Internship appointments are specifically designed for potential non-competitive conversion to positions in the competitive service only, provided all program requirements are met.
• Program Intent: The Internship Program aims to develop individuals for potential permanent placement in the federal workforce or to provide career exploration opportunities during schooling, not as a stepping stone to another developmental program like the Recent Graduates Program.
• Public Notification for Recent Graduates Program: It’s important to remember that 5 CFR 362.303(a) requires public notification for filling positions in the Pathways Recent Graduates Program, making non-competitive conversion from the Internship Program inappropriate.

Conversion to Excepted Service Positions

Employees in Pathways Internship and Recent Graduate appointments are eligible for conversion to competitive service positions only, not to excepted service positions.

• Pathways as Exception to Competitive Process: By definition, Pathways authorities are intended to be an exception to the typical competitive hiring process, leading to competitive service appointments.
• Executive Order 13562: Executive Order 13562 and its implementing regulations specifically provide for non-competitive conversion to positions in the competitive service.
• No Conversion to Excepted Service: The Pathways Programs framework does not include provisions for converting interns or recent graduates to excepted service positions.

Conversion of Interns NTE

Yes, an intern NTE (Not-to-Exceed) may be non-competitively converted to a position in the competitive service, but with specific conditions:

• Conversion Potential in Job Announcement: The original job opportunity announcement used to fill the intern NTE position must have explicitly stated the potential for conversion. Transparency about conversion potential is crucial.
• All Conversion Requirements Met: All other standard requirements for intern conversion must be fulfilled (e.g., work hours, performance, education, training).
• Rare Occurrence: Conversion of intern NTEs should be infrequent, as these positions are primarily intended for temporary projects, labor-intensive tasks without deep subject matter expertise, or traditional summer jobs. Conversion is not the primary purpose of NTE intern appointments.

Agency Obligation to Convert Interns After Graduation

No, agencies are not obligated to convert any Pathways intern to a position in the competitive service after they complete their academic requirements or program.

• Conversion is Discretionary: Conversion is not an entitlement or guarantee for Pathways participants.
• Agency Discretion: Agencies retain the discretion to decide whether to convert an intern.
• Conversion Potential Condition: However, if the job opportunity announcement for the intern position indicated conversion potential and all other conversion requirements are met, the agency has the option to convert the intern.

180-Day Grace Period for Intern NTEs

No, intern NTEs do not automatically have a 180-day grace period after graduation to remain in the program.

• NTE Appointment End Date: As per 5 CFR 362.205, an intern NTE appointment ends when the temporary appointment period expires, as specified in the appointment documentation.
• Conversion Before Expiration: However, an agency can convert an intern NTE to a competitive service position before the original NTE appointment expires, provided that the expiration date falls within 180 days of degree completion.
• Conversion Potential Requirement: Crucially, this conversion is only permissible if the job opportunity announcement for the intern NTE position explicitly mentioned the possibility of conversion and all other conversion requirements are met.

Retaining Interns After Graduation for Further Education

Yes, agencies have the flexibility to retain a participant in the Internship Program, even after graduation, without requiring public notification or competition, if:

• Acceptance into Another Qualifying Program: The intern has been accepted into another qualifying educational program (degree program) at the time of graduation.
• Continuous Eligibility: Acceptance into a new qualifying program maintains the student’s eligibility for continued employment as an intern. This is common for students transitioning from undergraduate to master’s or professional degree programs.
• No Public Notification Required for Continuation: In these situations, agencies can continue the intern’s appointment without further public notification or competition.

Conversion to Career Ladder Positions

Yes, interns in the Pathways Program can be non-competitively converted to positions that have established career ladders, provided certain conditions are met.

• Program Requirements Met: The intern must meet all program requirements for conversion (work hours, performance, education, training, etc.).
• Career Ladder in Job Announcement: The job opportunity announcement for the intern position must have stated the potential for conversion to a position with a career ladder.
• Example: An intern in a GS-0299-04 Human Resources Trainee position could be non-competitively converted to a GS-0201-05/7/9/11 Human Resources Specialist career ladder position, if the initial announcement indicated this career ladder potential.

Trial Periods for Interns

Interns are not automatically required to serve a trial period upon conversion.

• Agency Policy Dependent: The requirement for a trial period depends on whether the agency has a general policy mandating trial periods for all employees in the excepted service.
• If Agency Policy Exists: If an agency has such a policy, it would likely apply to converted interns in excepted service positions.
• No Federal Mandate: There is no federal government-wide requirement for interns to serve a trial period upon conversion from a Pathways Internship.

Conversion to Term or Permanent Appointments

Yes, agencies have the option to convert interns, recent graduates, or PMFs to either term or permanent appointments in the competitive service after they have successfully completed all program requirements for conversion.

• Flexibility for Term Appointments: Conversion to a term appointment provides agencies with flexibility, especially when facing budgetary constraints or resource limitations that might prevent immediate conversion to a permanent position.
• Subsequent Conversion to Permanent: If an individual is initially converted to a term appointment, the agency retains the option to non-competitively convert them to a permanent competitive service position at any point before the term appointment expires.
• Executive Order 13562 Intent: The option for term appointments is provided in accordance with Executive Order 13562 to offer agencies flexibility while still providing Pathways participants with a pathway to federal employment.

Conversion at a Different Agency

Intern Conversion to a Different Agency

Yes, an intern who meets all requirements for conversion can be converted to a term or permanent position in a different federal agency.

• Inter-Agency Conversion Possible: Pathways interns are not limited to conversion within their original employing agency.
• Talent Program Support: The Pathways Internship Talent Program is designed to facilitate these inter-agency conversions.

Pathways Internship Talent Program

To assist interns who cannot be converted within their current agency, the Pathways Internship Talent Program provides a valuable resource. This program, accessible through the USAJOBS Agency Talent Portal (ATP), helps connect interns with potential employment opportunities in other federal agencies.

• Intern Participation: Once an agency informs an intern that conversion within their agency is not possible, the intern is offered the opportunity to participate in the Pathways Internship Talent Program.
• Agency Recruitment Tool: Agencies with early career positions available can utilize the Pathways Internship Talent Program to recruit interns for conversion to permanent and term positions, accessing a pool of pre-qualified and experienced candidates.
• Contact Points: For more information, Pathways interns and agency hiring managers should contact their agency Pathways Program Officer. Pathways Program Officers can reach out to [email protected]. Agency hiring managers and Pathways Program Officers can also find helpful resources at the ATP Help Center.

Recent Graduate Conversion to a Different Agency

Yes, a recent graduate who meets conversion requirements can be converted to a term or permanent position in a different federal agency if their original employing agency is unable to convert them.

• Reasons for Inter-Agency Conversion: Common reasons for conversion at another agency include:
  • Unforeseen budgetary constraints.
  • Agency reorganizations.
  • Abolishment of positions.
  • Completion of cohort-based Pathways programs where permanent positions are not guaranteed for all participants.
  • Other appropriate agency-specific reasons.

Extending Recent Graduate Appointments for Inter-Agency Conversion

Agencies have the option to extend a recent graduate appointment to allow time for conversion to a position at a different agency.

• Extension Limit: Agencies can extend the recent graduate appointment for up to 120 days for this purpose.
• No Extensions Beyond 120 Days: Extensions beyond 120 days are not permitted under the regulations.

Career Ladder in New Agency for Recent Graduates

Yes, if a recent graduate is being converted to a permanent position at a different agency, they can be converted to a position with a career ladder.

• Equivalent or Lower Career Ladder: However, the position at the new agency must have a full performance level that is equivalent to or lower than the position they would have been converted to at their original agency. This ensures appropriate career progression.

Termination of Pathways Program Appointments

Termination of Intern Appointments Before 180-Day Period

Generally, an intern’s appointment expires 180 days after completing their academic course of study, unless they are selected for non-competitive conversion. If an agency is not planning to convert an intern, they can terminate the intern before the end of the 180-day period, but specific procedures apply.

• Termination as Condition of Employment: Termination as a condition of employment (non-disciplinary separation) only occurs automatically at the end of the 180-day period post-degree completion.
• Termination Before 180 Days: If termination occurs before the 180-day mark, the agency must assess if the intern meets the definition of “employee” under Chapter 75 of Title 5 of the U.S. Code.
• Appeal Rights: If the intern is considered an “employee” under Chapter 75, they are entitled to appeal rights before any action to remove them can be taken.
• Adverse Action Procedures: In such cases, the agency must follow adverse action procedures outlined in 5 CFR Part 752 for any termination occurring prior to the end of the 180-day period.

The standard condition of employment is that an intern appointment expires 180 calendar days after completion of their academic program, unless they are converted to the competitive service under § 362.204.

Reduction in Force (RIF) Rules and Recent Graduate Terminations

No, the reduction in force (RIF) rules do not apply to a recent graduate who is terminated when their appointment expires at the end of the Recent Graduates Program.

• 5 CFR 362.306(a) Exemption: 5 CFR 362.306(a) explicitly states that the expiration of a Recent Graduate appointment is not subject to the RIF requirements in 5 CFR Part 351.
• Term Appointment Expiration: Termination at the end of a Recent Graduate term appointment is considered an expiration of a term appointment, not a RIF action.

Pathways Memorandum of Understanding (MOU) and Agency Policy

Agency Requirements for MOUs and Pathways Policies

OPM has shifted from requiring Memorandums of Understanding (MOUs) to mandating that each agency have a Pathways Policy (5 CFR 362.104) to make appointments under Pathways authority.

• Pathways Policy Replaces MOU: The Pathways Policy serves a similar purpose to the former MOU, outlining the agency’s approach to using the Pathways Programs.
• Policy Content: The agency policy details the parameters and guidelines under which the agency will utilize the Internship, Recent Graduates, and PMF Programs.
• Policy Availability: Agencies are required to make their Pathways policies readily available to OPM, applicants, agency employees, and other stakeholders upon request, ensuring transparency and accessibility.

Continued Use of Pathways Programs with Existing MOUs

Yes, agencies that already have existing Pathways MOUs can continue to use the Pathways Programs.

• Interim Use of MOUs: Agencies can operate under their existing MOUs while they are in the process of developing and updating their policies to fully align with the new regulations. The MOU serves as a temporary framework during this transition.
• Policy Development Required: However, agencies must prioritize developing and implementing a formal Pathways Policy that complies with the new regulations.
• Policy Prerequisite for New Agencies: Agencies that do not have existing MOUs must establish an agency Pathways Policy before they can begin making appointments under the Pathways Programs. A policy is a prerequisite for program implementation.

Required Information in Agency Pathways Policy

An agency’s Pathways Policy must comprehensively address the requirements outlined in 5 CFR 362.104. Essential elements to include are:

• Program Naming Conventions: Information about any agency-specific program labels that will be used, ensuring they adhere to federal naming conventions (e.g., “OPM Internship Program,” not just “Internship Program”).
• Delegations of Authority: Specification of the levels of authority within the agency for using Pathways Programs (e.g., department-wide, bureau-level, component-level).
• Implementing Policy/Guidance: Any supplementary agency-specific policy or guidance documents that facilitate the successful implementation and administration of each Pathways Program within the agency.
• Training and Development: A clear description of how the agency will design, implement, and document formal training and/or development opportunities for Pathways participants, including the types and duration of assignments they will receive.
• Agency Commitments: A formal commitment from the agency to:
  • Provide OPM with any requested information about the agency’s Pathways Programs for oversight and reporting purposes.
  • Adhere to any program caps or limitations imposed by the Director of OPM.
  • Provide information to OPM upon request about opportunities for individuals interested in participating in Pathways Programs, including posting PMF appointment opportunities to the PMF Program’s Talent Management System (TMS).
  • Establish a meaningful onboarding process for each Pathways Program to ensure participants are effectively integrated into the agency.
  • Align the utilization of Pathways Programs with the agency’s overall workforce and recruiting plans, ensuring strategic workforce management.
• Extension Criteria and Procedures: Clearly defined criteria and procedures for agency-approved extensions for recent graduates and PMFs, which must not exceed 120 days. Extension criteria must be limited to circumstances where regulatory compliance becomes impracticable or impossible due to unforeseen events.
• Conversion Resource Determination: Criteria and procedures outlining how the agency will determine if it has the resources available to convert a Pathways participant to a term or permanent position in the competitive service. These procedures must specify a timeline for making this determination and require the agency to inform the Pathways participant no later than 60 calendar days prior to the end of their appointment about whether conversion is possible.
• Intern Minimum Service Hours: The specific minimum service hour requirement(s) for intern conversion, as determined by the agency within the regulatory framework of § 362.204.
• Recent Graduate Program Length: The standard program length for Recent Graduate Programs within the agency. If programs longer than one year are established, the policy must include a clear justification for using the extended program duration.
• Program Officer and PMF Coordinator Identification: Designation of the agency’s Pathways Programs Officer (PPO) and Presidential Management Fellows (PMF) Coordinator, providing clear points of contact for program administration and inquiries.

Establishing Longer Durations for Recent Graduate Programs

The primary intent of the Recent Graduates Program is to provide a one-year, entry-level developmental experience that can lead to a permanent position within the agency workforce.

Agencies have the option to establish Recent Graduate Programs that exceed one year in duration only if the training requirements of specific positions necessitate a longer and more structured program.

• Justification Required: Any positions designated as having a program length longer than one year must be explicitly identified in the agency’s Pathways Policy.
• Policy and Participant Agreement Documentation: The justification for the extended program duration must be documented in the agency’s Pathways Policy and also described in the Pathways Participant agreement for affected recent graduates, ensuring transparency.
• Centralized Program Length Determination: Individual managers, organizations, or units within an agency cannot independently decide the length of the Recent Graduate Program. Program length decisions must be made at an agency-wide level and formalized through the Pathways Policy.

Presidential Management Fellows (PMF) Program – Specific Questions

Developmental Assignments Outside Federal Government for PMFs

No, PMFs cannot complete their required developmental assignments outside of the federal government.

• Permitted Locations: PMF developmental assignments are limited to:
  • Within their own organization.
  • Within their employing agency.
  • In another Federal agency (as defined in 5 U.S.C. 105, Executive Branch agencies).
  • In a participating Federal agency within the Legislative Branch (under specific agreements).
• Optional Rotations Outside Agency: PMFs may still participate in optional rotations outside their agency (e.g., in state or local government, non-profits, or private sector), but these do not fulfill the required developmental assignment component of the PMF Program. These optional rotations remain at the discretion of the agency and must follow agency policies.

PMF Finalist Appointment Eligibility Period

A PMF finalist has a 12-month appointment eligibility period from their official finalist selection date. This means they must accept and start a PMF appointment within 12 months of being selected as a finalist.

• Eligibility Extensions: Under limited circumstances, an agency can request an appointment eligibility extension from OPM if they are unable to bring the finalist onboard within the 12-month period. Common reasons for extensions include delays in completing background investigations or security clearances.
• Precedent: This practice of allowing extensions is consistent with PMF Program regulations that were in effect prior to the broader Pathways Programs regulations.

PMF Appointments to Career Ladder Positions

Yes, individuals participating in the PMF Program can be appointed to positions that have established career ladders.

• Career Ladder Disclosure in Announcement: The PMF appointment opportunity announcement for the specific position must have clearly stated that the position has a career ladder. Transparency in the announcement is essential.
• Career Progression: This allows PMFs to enter positions with structured career advancement potential within the agency.

ERB Certification Deadline for PMF Program Completion

The deadline for an Executive Resources Board (ERB) to certify that a fellow has successfully completed all requirements of the PMF Program is 30 days prior to the fellow’s 2-year anniversary date (or 2-year anniversary date plus any approved fellowship extension up to 120 days).

• Certification Prerequisite for Conversion: ERB certification is a mandatory step that must be completed before a PMF can be converted to a permanent position. Timely certification is crucial for seamless program completion and potential conversion.

Online Training for PMFs as “Formal Interactive Training”

Yes, online training can qualify as “formal interactive training” for PMFs, fulfilling the program’s training requirements.

• Competency Alignment: To be considered valid, online training must directly address the competencies outlined in the fellow’s Individual Development Plan (IDP). The training should contribute to preparing the fellow for their target position and career goals.
• Interactive Elements: “Interactive training” implies communication and engagement between the instructor and students, and among students themselves. Online training platforms that facilitate such interaction (e.g., live virtual sessions, discussion forums, group projects) can meet this requirement.
• ERB Determination: Ultimately, the agency’s ERB is responsible for determining whether a fellow has met all program requirements, including the adequacy and type of training completed. Agencies may want to provide further clarification on training definitions and acceptable formats within their internal Pathways Programs policies.

PMF Participation in Agency-Wide or Presidential Initiatives

Yes, a PMF can participate in an agency-wide, Presidential, or Administration initiative to fulfill the requirement for a 4-to-6-month developmental assignment.

• Regulatory Allowance: Per 5 CFR 362.405(b)(4)(i), such participation is explicitly permitted as a way to meet the developmental assignment requirement.
• Duration Requirement: The experience in the initiative must be of a 4-to-6-month duration to provide the PMF with the equivalent developmental experience they would gain through a traditional rotational assignment. The 4-6 months does not have to be consecutive.
• Developmental Value: The initiative should be designed to provide significant developmental value, expanding the PMF’s skills, knowledge, and experience in alignment with their IDP goals.

OPM Waivers or Extensions for PMF Training Requirements

No, OPM will not grant waivers or extensions to the yearly PMF training requirements for agencies that are unable to comply due to budget constraints or other reasons.

• Mandatory Training Hours: The regulations mandate that each agency must provide each PMF with a minimum of 80 hours of formal interactive training per year throughout their 2-year fellowship. Agencies are also required to provide each fellow with at least one 4-to-6-month developmental assignment during the fellowship.
• PMF Program Office Support: The PMF Program Office itself sponsors several training opportunities specifically for PMFs. These sponsored trainings can count towards the 80-hour annual training requirement, providing agencies with cost-effective training options.
• ERB Certification Enforcement: The ERB certification process serves as a key mechanism to ensure that each fellow has completed at least 160 hours of training (80 hours per year) as a core program requirement. Strict adherence to training requirements is expected.

Participation in PMF Program by Excepted Service Agencies

Yes, agencies whose positions are generally excepted by statute from Title 5 competitive service provisions, and non-Executive Branch agencies, can participate in the PMF Program. Examples include the FBI, Library of Congress, and Congressional Research Service.

• Memorandum of Agreement (MOA) Required: These agencies must enter into a formal Memorandum of Agreement (MOA) with OPM to participate in the PMF Program. The MOA outlines the terms of participation and mutual responsibilities.
• MOA as Enabling Mechanism: Once an MOA is approved and in place with OPM, the agency becomes authorized to appoint PMFs under the program.
• Excepted Service Placement: It’s crucial to note that upon successful completion of the PMF Program, fellows from these agencies are eligible only for placement into excepted service positions within their agency, not competitive service positions (unless the agency also has competitive service positions).
• Agency PMF Policies: Agencies participating through MOAs must also establish and implement their own PMF Program policies, ensuring internal program administration aligns with PMF regulations and OPM guidelines.

Part-Time Work Schedules for PMFs

Yes, an agency may approve a part-time work schedule for a PMF, but this is typically for a limited duration and subject to certain conditions.

• Fellow Request: Part-time work schedules are generally initiated at the request of the fellow.
• Limited Period: Approval is usually for a limited period, often up to a maximum of 6 months.
• Program Requirement Compliance: Even on a part-time schedule, the fellow must still be able to meet all PMF Program requirements within their 2-year program duration (and any approved extensions). This includes training, developmental assignment, and performance expectations.
• Training and Development Adjustments: The fellow and agency must account for any necessary adjustments to the fellow’s training and developmental activities to ensure program requirements are met within the part-time schedule. This may involve extending timelines or adjusting activity intensity.

Agency Obligation to Approve Part-Time Work Schedule Requests

No, an agency is generally not required to automatically approve a PMF’s request for a part-time work schedule.

• Agency Discretion: The decision to approve a part-time work schedule is typically at the agency’s discretion, considering factors such as operational needs, program feasibility, and impact on the fellow’s development.
• Case-by-Case Basis: Requests are usually evaluated on a case-by-case basis.

Considerations for Part-Time Work Schedules

When a PMF requests a part-time work schedule, both the fellow and the employing agency should carefully consider the potential impacts:

• Program Completion Feasibility: Assess how a part-time schedule would affect the fellow’s ability to complete all PMF Program requirements (training hours, developmental assignment, performance standards) within the standard 2-year appointment period or any approved extension. Time management and workload adjustments will be critical.
• Promotion Eligibility: Consider how a part-time schedule might impact the fellow’s ability to meet qualification requirements for promotions, both during and after the PMF Program. Some positions may require full-time experience or specific durations of full-time work for career advancement.

Open communication and planning between the fellow and agency are essential to determine if a part-time work schedule is feasible and appropriate without compromising program success or career progression.

Timing of Conversion Decision Notification for PMFs

An agency must inform a PMF no later than 60 calendar days prior to the end of their 2-year appointment (or any approved fellowship extension) if the agency is unable to convert them to a permanent position.

• Early Communication Encouraged: OPM strongly encourages agencies to make determinations about conversion resources at regular intervals throughout the fellowship, well before the 60-day deadline. Early communication is highly recommended to provide PMFs with ample time to plan their next steps.
• Pathways Policy Requirement: OPM requires agencies to include provisions in their Pathways Policies that address procedures and criteria for determining conversion feasibility and for communicating these decisions to PMFs. Transparency and clear communication processes are essential.
• Participant Agreement Recommendation: OPM also recommends that agencies indicate a timeframe for when the conversion decision will be made within the Pathways Participant Agreement signed at the beginning of the fellowship. This sets clear expectations from the outset.

PMF Conversion to a Different Agency

Yes, a PMF who meets conversion requirements can be converted to a term or permanent position in a different federal agency if their original employing agency is unable to convert them.

• Reasons for Inter-Agency Conversion: Similar to Recent Graduates, reasons for conversion at another agency may include:
  • Unforeseen budgetary constraints.
  • Agency reorganizations.
  • Abolishment of positions.
  • Completion of cohort-based PMF programs where permanent positions are not guaranteed for all participants.
  • Other valid agency-specific reasons.

Extending PMF Appointments for Inter-Agency Conversion

Yes, agencies have the option to extend a PMF’s appointment to allow time for conversion to a position at a different agency.

• Extension Limit: Agencies can extend a PMF appointment for up to 120 days for the purpose of facilitating inter-agency conversion.
• No Extensions Beyond 120 Days: Extensions beyond 120 days are not permitted under PMF regulations.

Career Ladder in New Agency for PMFs

Yes, if a PMF is being converted to a permanent position in a different agency, they can be converted to a position with a career ladder.

• Equivalent or Lower Career Ladder: However, similar to Recent Graduates, the position at the new agency must have a career ladder that is equivalent to or lower than the career ladder of the position they would have been converted to at their original agency. This maintains appropriate career progression within the program framework.

Reduction in Force (RIF) Rules and PMF Terminations

No, the reduction in force (RIF) rules do not apply to a PMF who is separated when their appointment expires at the end of the fellowship.

• 5 CFR Part 351 Exemption: Separation at the expiration of a PMF appointment is not subject to the RIF requirements in 5 CFR Part 351.
• Term Appointment Expiration: Termination at the end of the PMF term appointment is considered an expiration of a term appointment, not a RIF action.

OPM Authority to Waive PMF Program Requirements

No, the current PMF rules do not provide OPM with the authority to waive any provision of the PMF Program requirements upon an agency’s request.

• No Waiver Provision: The PMF regulations, as currently written, do not include a clause granting OPM the power to waive any program requirement.
• Limited Flexibility: The PMF Program regulations do allow for appointment eligibility extensions and fellowship extensions under specific, limited circumstances. These are the primary mechanisms for flexibility within the program, not waivers of core requirements.

Questions and Contact Information

For further questions or clarification, please use the following contact points:

• Agency Headquarters-Level Human Resources Offices: Contact OPM directly at [email protected].
• Component-Level Human Resources Offices: Contact your agency headquarters human resources office for initial assistance and guidance.
• Employees: Contact your agency human resources office for program-related inquiries and support.
• Applicants: For questions about specific job opportunities, please use the contact information provided within the relevant job opportunity announcement on USAJOBS.