Navigating Your Federal Career Path with Pathways Career Programs

I. Understanding Pathways Career Programs: A Comprehensive Guide

For students and recent graduates aspiring to launch a fulfilling career within the U.S. Federal Government, Pathways Career Programs offer an exceptional gateway. This framework encompasses three distinct programs meticulously designed to provide enriching internships and developmental experiences, paving the way for potential federal careers. Understanding the intricacies of these programs is the first step towards unlocking these valuable opportunities.

What Exactly are Pathways Programs?

The Pathways Programs framework is structured around three key initiatives:

  • Internship Program: This program is tailored for students from high school through graduate levels, offering paid internships 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 qualifying educational institutions or programs, including Registered Apprenticeships and certain volunteer service programs. A minimum of 480 internship hours is typically required for potential conversion to a competitive service role, though waivers can reduce this to 320 hours under specific conditions.

  • Recent Graduates Program: Designed for individuals who have recently graduated from qualifying educational institutions or career and technical education programs, this program provides a developmental experience lasting one to two years within federal agencies. Applicants are eligible within two years of graduation, with an extended window of up to six years for veterans hindered by service obligations.

  • Presidential Management Fellows (PMF) Program: This prestigious two-year leadership development program is aimed at advanced degree candidates and graduates. PMFs are provided with mentorship, professional development opportunities, and significant training, including at least one developmental rotational assignment. Eligibility is within two years of completing a master’s, professional, or doctoral degree.

Regulatory Foundation of Pathways Programs

The regulations governing Pathways Programs are officially documented within the Code of Federal Regulations (CFR), specifically in 5 CFR parts 362, 213, 302, and 315. These regulations provide a detailed legal framework for the programs.

  • 5 CFR Part 362, Subpart A: Outlines the overarching rules applicable to all Pathways Programs, ensuring consistency and standardized practices across the board.
  • 5 CFR Part 362, Subpart B: Focuses specifically on the Internship Program, detailing rules and guidelines pertinent to internships within the federal government.
  • 5 CFR Part 362, Subpart C: Provides specific regulations for the Recent Graduates Program, addressing the unique aspects of this career development pathway.
  • 5 CFR Part 362, Subpart D: Details the rules and operational framework for the Presidential Management Fellows (PMF) Program, highlighting its leadership development focus.
  • 5 CFR 213.3401-2: Clarifies general provisions related to Schedule D of the excepted service, the specific hiring authority used for Pathways Programs.
  • 5 CFR Part 302: Governs the procedures for filling excepted service positions, including the application of veterans’ preference, a critical aspect of federal hiring.

Agencies are strongly advised to consult these regulatory provisions to ensure compliance and clarity when utilizing Pathways Programs. Seeking legal counsel is also recommended for any interpretive questions or complex scenarios.

II. Eligibility Criteria for Pathways Programs: Is It For You?

Understanding the eligibility requirements for each Pathways Program is crucial to determine your qualification and application strategy. Each program has specific criteria focusing on educational status and degree attainment.

Pathways Internship Program: Are You Eligible?

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

  • Enrollment in a Degree Program: Applicants must be formally accepted for enrollment or currently enrolled in a degree-seeking program (diploma, certificate, etc.) at a qualifying educational institution. Enrollment must be at least on a half-time basis, as defined by the institution.
  • Enrollment in a Career or Technical Education Program: Eligibility also extends to those accepted for enrollment or enrolled in a qualifying career or technical education program. These programs must award a recognized postsecondary credential, such as a Registered Apprenticeship Program or Job Corps certification.

Importantly, individuals nearing graduation who require less than half-time course load to complete their degree are still considered eligible. This flexibility accommodates students in their final stages of academic programs.

Pathways Recent Graduate Program: Meeting the Requirements

For the Recent Graduate Program, eligibility hinges on recent educational attainment. Applicants must have:

  • Obtained a Qualifying Degree or Certificate: Received an associate’s, bachelor’s, master’s, professional, doctorate, vocational, or technical degree, or a certificate from a qualifying educational institution.
  • Completed a Qualifying Career or Technical Education Program: Finished a program meeting the federal standards for career and technical education.
  • Recent Graduation Timeline: Graduation must have occurred within the 2 years prior to application. Veterans who were unable to apply due to military service obligations have an extended window of up to 6 years post-graduation.

Qualifying Career and Technical Education Programs: Defined

To clarify, qualifying career or technical education programs encompass three primary categories:

  • Federally Administered Educational Programs: These programs are overseen by federal agencies and provide rigorous academic content, technical skill development, and a recognized postsecondary credential. They are designed to prepare individuals for advanced education or careers in current and emerging professions.
  • Registered Apprenticeship Programs: Formally recognized apprenticeship programs that combine on-the-job training with related technical instruction.
  • Federally Administered Volunteer Service Programs: These include local, state, national, or international volunteer service programs under federal administration, offering structured skill development and experience.

Understanding Federally Administered Programs

A Federally administered career or technical education program is characterized by federal agency oversight that includes specific elements:

  • Scope of Work: Defining the nature and extent of work participants will undertake.
  • Training Provided: Specifying the type and depth of training to be delivered to participants.
  • Skill Development: Identifying the skills participants will acquire, which can range from technical expertise to soft skills like teaching, communication, or project management.
  • Mentoring: Defining the level and nature of mentoring support participants will receive.
  • Performance Metrics: Establishing measurable criteria for successful program completion and participant progress.

This programmatic oversight is often formalized through partnership or cooperative agreements, ensuring structured and accountable program delivery.

Acceptable Documentation for Eligibility Verification

Agencies require documentation to verify applicant eligibility for both Internship and Recent Graduate Programs.

Internship Program Documentation:

  • Transcripts: Official or unofficial academic transcripts.
  • Diplomas: Copies of diplomas or certificates of degree completion.
  • Enrollment Verification: Written documentation from the educational institution or career/technical program, such as enrollment letters or acceptance confirmations.

Recent Graduate Program Documentation:

  • Transcripts: Official or unofficial academic transcripts.
  • Diplomas: Copies of diplomas or certificates.
  • Program Completion Letters: Documentation confirming completion of a degree or career/technical program.

Documentation must clearly indicate:

  • Applicant’s full name.
  • Name of the degree or career/technical program.
  • Date of degree or program completion (or expected completion date).
  • Program length information for certificate programs or volunteer service programs, to confirm they meet minimum duration requirements (at least one academic year equivalent for certificate programs).

Applying Before Program Completion

Applicants are not required to have fully completed their degree or career/technical program to apply for the Recent Graduates Program. Applications can be submitted and considered in the months leading up to program completion. However, applicants must meet the definition of a recent graduate as defined in 5 CFR 362.302 prior to their official appointment start date.

Agencies may also set specific application deadlines related to educational completion, such as the announcement closing date, certificate issuance date, or appointment date. Such conditions must be clearly stated in the agency’s Pathways policy and application procedures.

Defining Valid Certificate Programs

For Pathways Programs, a certificate program is defined as post-secondary education that meets specific criteria:

  • Qualifying Educational Institution: Must be at a trade or vocational school, 2-year or 4-year college or university, or graduate/professional school.
  • Duration: Equivalent to at least one academic year of full-time study.
  • Accreditation: Part of an accredited college-level, technical, trade, vocational, or business school curriculum.
  • Qualifying Career or Technical Education Program: Alternatively, a qualifying career or technical education program of at least one year that awards a recognized postsecondary credential also qualifies.

Citizenship Requirements

Citizenship requirements for Pathways Programs vary:

  • General Rule: There is no overarching U.S. citizenship requirement for excepted service positions in general.
  • Agency-Specific Restrictions: However, many agencies face restrictions based on annual appropriations legislation or agency-specific statutes that may limit the employment of non-citizens. Agencies must consult their legal counsel to determine applicable restrictions.
  • Lawful Permanent Residency: Agencies can appoint non-citizens to Pathways Program positions only if they are lawfully admitted permanent residents or otherwise authorized for employment in the U.S.
  • Conversion to Permanent Employment: To be eligible for non-competitive conversion to permanent federal employment in the competitive service at the end of their Pathways Program, interns, recent graduates, and fellows must possess full U.S. citizenship.

III. Public Notification for Pathways Programs: Ensuring Transparency

Public notification is a critical aspect of Pathways Programs, ensuring open access and fair competition for these federal opportunities. Agencies are required to publicly announce Pathways positions to maximize reach and attract diverse talent.

Public Notification Options

Agencies have two primary methods to satisfy the public notification requirement under Pathways Programs, as outlined in 5 CFR 326.104(c)(6)(iii) and 362.105(b):

  • USAJOBS.gov Posting: Posting a searchable job announcement directly on USAJOBS.gov, the federal government’s official job site.
  • Agency Website Posting with USAJOBS Link: Posting job information on the agency’s public-facing career or job information webpage, which must include a direct link to a custom job announcement on USAJOBS.

In addition to these mandatory methods, agencies are encouraged to broaden their outreach through supplementary recruitment activities, such as:

  • Third-party job websites.
  • Social media platforms.
  • Professional networking sites.

For PMF positions, announcements are typically posted on the PMF Program’s Talent Management System (TMS) when recruiting finalists.

Essential Information in Job Announcements

Job announcements for Pathways Internship and Recent Graduate Programs must include at least the following key information:

  • Position Details:
    • Official position title, including the job series and grade level.
    • Starting salary range for the position.
    • Geographic location(s) of the job.
  • Qualifications: Minimum qualifications required for the position.
  • Application Instructions: Clear guidance on how to apply, or a direct link to the agency’s website with detailed application instructions.
  • Equal Opportunity & Accessibility:
    • Reasonable Accommodation statement, ensuring accessibility for applicants with disabilities.
    • Information on how to claim veterans’ preference, acknowledging and applying veteran priority.
  • Program Specifics:
    • Information about the possibility of conversion to permanent appointment, if applicable.
    • Promotion potential, if relevant to the position trajectory.

OPM also recommends including additional details to enhance the announcement’s effectiveness:

  • Job Description: A concise summary of the primary duties and responsibilities of the position.
  • Work Schedule Options: Available work schedules (e.g., full-time, part-time, flexible).
  • Pathways Program Links: Direct links to official Pathways Programs information pages for applicant reference.
  • Incentives: Details on relocation expenses or recruitment incentives, if offered.

Career Fairs and Public Notification

Agencies cannot solely rely on career fairs for recruitment without broader public notification. While career fairs can be valuable recruitment tools, they must be supplemented by public job announcements.

  • Public Announcement Required: Agencies must still provide public notification through USAJOBS or their website with a USAJOBS link, even if they recruit at a career fair.
  • Alternative Application Method: Agencies must provide an accessible alternative method for candidates to apply if they cannot attend the career fair. This ensures equitable opportunity for all interested applicants, regardless of their ability to attend specific events.

Managing Application Volume

Agencies have several strategies to manage potentially high application volumes from public job announcements for Pathways positions:

  • Limited Announcement Period: Agencies can set specific opening and closing dates for job announcements. The duration should be carefully considered based on factors like position type, grade level, and geographic location. For example, a short-term summer internship in a specific location might require a shorter announcement period than a specialized technical internship at a headquarters location.
  • Application Limits: Agencies can establish “cut-offs” or limits on the number of applications they will review (e.g., reviewing only the first 75 or 100 applications). If using such limits, agencies are strongly encouraged to accept all applications received until 11:59 p.m. on the day the limit is reached, to accommodate applicants in different time zones.
  • Specific Eligibility Requirements: Agencies can set specific eligibility criteria beyond the basic Pathways requirements. For Internship Programs, this might include requiring a certain minimum number of work hours per week or maintaining a minimum GPA. However, agencies cannot impose specific coursework requirements for occupations that do not typically have positive education requirements in general federal hiring. Agencies may also require applicants to confirm their availability to work in the specific location(s) listed in the announcement.

Any limitations on application procedures must be clearly documented in the agency’s application policies (5 CFR 302.201) and explicitly stated in the Pathways job opportunity announcements. Agencies must also ensure that their notification and application processes adhere to merit system principles, promoting fair and open competition and equitable treatment for all potential applicants. Consultation with agency legal counsel is advisable when implementing these strategies.

IV. Custom Postings on USAJOBS: A Targeted Approach

USAJOBS custom postings offer a unique way for agencies to manage and target their Pathways job announcements. These postings provide flexibility and tracking capabilities while still meeting public notification requirements.

What is a USAJOBS Custom Posting?

A USAJOBS custom posting is a job announcement created and hosted on USAJOBS but accessed through a unique, non-public URL. Unlike standard USAJOBS announcements, custom postings are not searchable on the general USAJOBS platform.

Key features of custom postings:

  • Unique URL Access: Applicants can only access the announcement via a specific link provided by the agency.
  • Application Tracking: If the “Apply Online” option is enabled, applicants can track their application status within USAJOBS.
  • Applicant Flow Data: Agencies receive post-audit applicant flow data, valuable for analyzing hiring trends and recruitment effectiveness.

Using Custom Postings for Public Notification

Custom postings effectively meet the Pathways public notification requirement when agencies:

  • Share the Custom Link Publicly: Post the unique custom posting link on the agency’s public website, typically on their careers or jobs page.
  • Wider Distribution: Agencies can also share the link in other recruitment materials, such as on third-party websites, social media, and targeted emails.

By posting the custom link on their public website, agencies ensure broad accessibility while controlling who directly receives the announcement link.

When to Use Custom Postings

While OPM encourages the use of standard, searchable USAJOBS postings for maximum visibility, custom postings are beneficial in specific scenarios:

  • Targeted Recruitment: When agencies want to target specific groups or communities with a job announcement, without making it broadly searchable on USAJOBS.
  • Controlled Application Flow: Custom postings can help manage application volume by limiting direct access to the announcement link.
  • Data Tracking: Agencies wanting to leverage USAJOBS application tracking and applicant flow data while using a more targeted distribution strategy can benefit from custom postings.

Creating a Custom Posting

Custom postings are created within the Talent Acquisition System (TAS), the system used by federal HR specialists to manage job announcements on USAJOBS.

Process for creating a custom posting:

  1. Access TAS: HR specialists log into the Talent Acquisition System.
  2. Create Posting: Create a new job announcement in TAS, specifying it as a custom posting.
  3. Generate Unique URL: Once the posting is created and finalized in TAS, the system generates a unique URL.
  4. Publicize Link: The HR specialist then distributes this unique URL by posting it on the agency’s website and other chosen channels.

Further Information on Custom Postings

For detailed, step-by-step instructions on creating custom postings, agencies should contact their agency’s Talent Acquisition System (TAS) point of contact. Additional questions about custom postings can be directed to [email protected].

V. Recruitment Strategies for Pathways Programs: Building a Strong Talent Pipeline

Effective recruitment is essential for Pathways Programs to attract highly qualified students and recent graduates. Agencies are encouraged to implement proactive and strategic recruitment strategies to build a diverse and talented applicant pool.

Outreach Before Public Announcement

Agencies have the flexibility to conduct outreach activities even before or without posting a formal USAJOBS announcement or custom posting.

Permissible outreach activities include:

  • Campus Visits: Informational sessions and awareness events on college and university campuses.
  • Liaison Activities: Building relationships with academic institutions and career services offices.

These outreach efforts can raise awareness about federal career opportunities and the Pathways Programs, even before specific job openings are formally announced.

Strategic Recruitment for Diversity

Agencies are encouraged to use strategic outreach and recruitment to enhance the diversity of their applicant pools.

Key considerations for diversity-focused recruitment:

  • Targeted Recruitment Plans: Develop recruitment plans specifically aimed at increasing diversity across various dimensions (e.g., race, ethnicity, gender, disability, socioeconomic background).
  • Diverse Recruitment Channels: Utilize a variety of recruitment channels to reach diverse talent pools, including minority-serving institutions, disability organizations, and community groups.
  • Inclusive Outreach Events: Ensure recruitment events and materials are inclusive and accessible to all potential applicants.

Strategic recruitment activities should be part of a broader, comprehensive recruitment plan, ensuring that public notice of opportunities remains available to everyone.

On-Campus Recruitment Events

When agencies hold or attend on-campus recruitment events where applications for Pathways positions are accepted, specific information must be publicized in advance:

Required announcement information for campus events:

  • Event Details:
    • Location of the event (specific campus building or area).
    • Date and time of the event.
    • Directions and accessibility information, including reasonable accommodation details for individuals with disabilities.
  • Position Information:
    • Position title, series, and grade level of the jobs being filled.
    • Geographic location(s) of the jobs.
  • Application Alternatives: Provide a public source (e.g., agency website link) with information on how to apply for interested individuals who cannot attend the event.
  • Veterans’ Preference: Information on how to claim veterans’ preference when applying, even at the event.

This information must be announced publicly on USAJOBS or the agency’s public-facing career webpage in advance of the recruitment event.

Effective Recruitment Practices

OPM encourages agencies to adopt the following best practices for Pathways recruitment:

  • Workforce Planning Integration: Base recruitment strategies on agency workforce planning to align talent acquisition with organizational needs.
  • Diverse Talent Sources: Actively recruit from a variety of talent sources to attract qualified applicants from all segments of society.
  • Spectrum of Institutions: Recruit from a diverse range of campuses and schools, not just a select few, to broaden reach and diversity.
  • Open Campus Events: Ensure on-campus recruitment events are open to all interested students, not limited to students of that specific campus. Provide alternative application methods and comprehensive information for those unable to attend in-person events.

Agencies should also proactively promote awareness of key federal job resources:

  • USAJOBS Website: Direct students and recent graduates to www.USAJOBS.gov as the central portal for federal job opportunities.
  • Federal Internship Portal: Highlight the Federal Internship Portal (https://intern.usajobs.gov/) as a dedicated resource for internship opportunities.
  • Recent Graduate Portal: Promote the Recent Graduate Portal (https://recentgrad.usajobs.gov/) for those seeking entry-level positions after graduation.

When planning on-campus recruitment, agencies should consider the proximity of the campus to the actual job location. Commute feasibility is an important factor for student participation and long-term engagement.

VI. Veterans’ Preference and Pass Overs in Pathways Programs: Honoring Service

Veterans’ preference is a fundamental principle in federal hiring, and it fully applies to Pathways Programs. Agencies must adhere to veterans’ preference regulations when making selections for Pathways positions.

Applying Veterans’ Preference

Yes, agencies are required to apply veterans’ preference when filling positions through Pathways Programs, as mandated by 5 CFR 362.105(c)(2).

Procedures for Applying Preference

The specific application of veterans’ preference depends on the selection method used by the agency, as outlined in 5 U.S.C. 3320 and 5 CFR 302, as well as any relevant agency-specific policies. Agencies generally choose from three selection methods for excepted service positions:

  1. Ranked List: Similar to the “rule of three” in competitive service. Applicants are scored numerically based on assessment criteria. Preference-eligible veterans receive 5 or 10 points added to their scores. Applicants are ranked by score, and selection is made from the top three ranked candidates. Veterans with a 10% or more disability are placed at the top of the list, achieving the highest ranks. Agencies cannot select a non-preference eligible candidate over a preference-eligible veteran with an equal or higher score without following pass over procedures.

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

    • 10-point preference eligibles (including those with 10% or more disability).
    • Other 10-point preference eligibles.
    • 5-point preference eligibles.
    • Non-preference eligibles.
      Agencies must consider candidates in the highest preference group first. A non-preference eligible veteran cannot be selected until all preference eligibles have been considered or appropriate pass over procedures have been followed.
  3. Category Rating-like Process: Agencies can establish their own systems, provided they give preference eligibles at least as much advantage as ranked or unranked methods. Many agencies use a category rating-like system, similar to category rating in competitive service. Applicants are placed into quality categories (e.g., “Highly Qualified,” “Qualified”) based on agency-defined criteria. 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 all non-preference eligibles in that category. Selection must be made from the highest quality category. Agencies cannot select a non-preference eligible over a preference eligible in the top category without completing pass over procedures. Agencies can select any preference eligible veteran within the highest quality category. If fewer than three candidates are in the top category, the agency can merge the top two categories, ensuring all preference eligibles from both categories are listed ahead of non-preference eligibles in the merged category.

  4. Professional Order (GS-9 and Above): For professional and scientific positions at GS-9 and above, rules differ slightly. Agencies can use ranked lists by score or unranked lists by preference status.

    • Ranked List: Preference points (5 or 10) are added to passing scores. Applicants are ranked by score, and selection is from the top three.
    • Unranked List: Qualified preference eligibles are listed first, by preference status (10-point then 5-point), followed by all other qualified applicants. Agencies must consider preference eligibles in the highest preference group first. Non-preference eligibles can only be considered after all preference eligibles have been considered or pass over procedures are followed.

Pass Over Procedures for Preference Eligibles

Pass over procedures are required when an agency proposes to select a non-preference eligible candidate over a preference eligible veteran. The process varies depending on the veteran’s disability status.

Pass Over for Veterans with Less Than 30% Compensable Disability:

A preference eligible veteran without a 30% or more compensable disability can only be passed over if the agency sustains the selecting official’s objection for adequate reason. Acceptable reasons, which must be documented, include:

  • Medical disqualification criteria under 5 CFR Part 339.
  • Suitability determination criteria listed at 5 CFR 731.202.
  • Other valid reasons determined 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 “same manner and under the same conditions required for the competitive service” standard. OPM approval is required for medical disqualification pass overs. The preference eligible veteran (or representative) is entitled to a copy of the agency’s pass over reason(s) upon request.

Pass Over for Veterans with 30% or More Compensable Disability:

For veterans with a 30% or more compensable service-connected disability, special procedures apply for medical disqualification (5 U.S.C. 3312 and 5 CFR 339.102(c) and 332.406):

  1. Notification to OPM and Veteran: Agency must simultaneously notify OPM and the disabled veteran in writing of the desire to disqualify and the reasons, informing the veteran of their right to respond to OPM within 15 days.
  2. Evidence to OPM: Agency must provide proof of timely notification to the veteran’s last known address.
  3. OPM Determination: OPM will determine the veteran’s physical ability to perform the job duties, considering any veteran response. Agency must provide sufficient evidence, including why reasonable accommodation is not possible and why the veteran cannot perform essential job functions without endangering themselves or others.
  4. OPM Decision: OPM may request more information from the agency. If OPM agrees with disqualification, the agency can select another candidate. If OPM disagrees, the agency cannot pass over the veteran for physical ability reasons.
  5. Notification of Decision: OPM notifies both the agency and veteran of its decision, which is binding.
  6. OPM’s Non-Delegable Authority: OPM cannot delegate these pass over determinations to agencies.

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

  1. Notification to OPM and Veteran: Agency must simultaneously notify OPM and the veteran in writing of the desire to pass over and the reasons, informing the veteran of their right to respond to OPM within 15 days.
  2. Evidence to OPM: Agency must provide proof of timely notification.
  3. OPM Determination: OPM determines if the pass over request is for proper and adequate reason under regulations and assesses evidence, considering veteran input.
  4. OPM Decision: OPM may request more information. If OPM sustains the pass over, the agency can select another candidate. If OPM rejects the pass over, the agency cannot pass over the veteran for the presented reason.
  5. Notification of Decision: OPM notifies both agency and veteran of its decision, which is binding.
  6. OPM’s Non-Delegable Authority: OPM cannot delegate these pass over determinations.

Schedule A Hiring Authority and Pathways Programs

The Schedule A hiring authority for People with Intellectual Disabilities, Severe Physical Disabilities, and Psychiatric Disabilities cannot be used to appoint individuals to Pathways Programs positions.

Key distinctions:

  • Separate Hiring Authorities: Schedule A and Pathways (Schedule D) are distinct hiring authorities with different eligibility criteria and processes.
  • Pathways Application Process for People with Disabilities: Applicants with disabilities apply for Pathways positions through the standard Pathways application process on USAJOBS, just like non-disabled applicants. They are considered for Pathways positions under the same provisions of 5 CFR part 302.
  • Reasonable Accommodation: Agencies are legally obligated to provide reasonable accommodations to individuals with disabilities in the Pathways Programs, as in all federal employment. Agencies should consult with legal counsel and HR offices on accommodation matters.

VII. Qualifications and Assessments in Pathways Programs: Ensuring Competency

Pathways Programs emphasize valid and job-related assessments to ensure that interns and recent graduates are qualified for their roles and potential future federal careers.

Assessment Requirements

For both the Internship and Recent Graduate Programs, agencies are required to use valid, job-related assessments as part of the selection process.

Acceptable assessment methods include:

  • Crediting Plans (Rating Schedules/Occupational Questionnaires): Standardized questionnaires designed to evaluate applicant qualifications against job requirements.
  • Structured Interviews: Interviews with pre-defined questions and scoring criteria to ensure consistent and objective evaluation.
  • Administrative Careers With America (ACWA) Rating Schedules: Agencies may use ACWA rating schedules for Pathways Programs positions.

Depending on the chosen selection method (5 CFR part 302), agencies may assess applicants for general eligibility/minimum qualifications or more comprehensively for ranking and selection. For the PMF Program, OPM utilizes assessments to establish a list of finalists.

OPM Qualification Standards for Recent Graduates

Recent Graduates Program positions are subject to OPM Qualification Standards.

Key implications:

  • OPM Standards Mandatory: Agencies cannot develop their own qualification standards for Recent Graduates Program positions.
  • OPM or OPM-Approved Standards: Agencies must use either OPM’s government-wide qualification standards or OPM-approved agency-specific standards for the relevant position. If legally required qualification standards exist for a specific position, those must be used.

Qualification Standards for Internships

For Pathways Internship Positions, agencies have more flexibility regarding qualification standards.

Options for Internship Qualification Standards:

  • Agency-Specific Standards: Agencies may develop and use their own agency-specific qualification requirements for internship positions.
  • OPM Standards: Agencies can choose to use OPM qualification standards for the competitive service as an alternative to agency-specific standards.
  • Group Coverage Qualification Standard for Schedule D, Pathway Internship Positions: Agencies can use this specific OPM standard designed for Pathways Internships.

Consistent Assessment Application

It’s important to reiterate that agencies are required to use valid, job-related assessments for both Intern and Recent Graduate Programs. Acceptable assessment tools remain crediting plans, rating schedules, occupational questionnaires, and structured interviews. Agencies may also utilize the ACWA written test or ACWA rating schedules. Assessment may focus on general eligibility or more detailed qualification ranking, depending on the selection method. OPM handles assessments for PMF finalists.

VIII. Promotions and Reassignments within Pathways Programs: Career Advancement

Pathways Programs offer opportunities for career growth and development through promotions and reassignments, subject to specific program rules and agency policies.

Intern Promotions

Interns without Not-to-Exceed (NTE) Dates:

  • Promotion Eligibility: Yes, interns appointed without NTE dates may be promoted.
  • Requirements: Promotion is permissible if the agency has an excepted service promotion policy and the intern meets the qualification requirements for the higher-grade position.

Interns with NTE Dates:

  • Promotion Ineligible: Interns with NTE appointments are similar to temporary employees and are not eligible for promotion.

Reassignment of Interns with NTE Dates

Agencies can reassign interns with NTE dates to different intern positions under certain conditions:

  • Internal Public Notification: Agencies must provide internal notification (within the agency, not on USAJOBS) to similarly situated agency interns who might be interested in the intern position.
  • Competitive Selection if Multiple Interested: If more than one intern expresses interest, the agency must apply selection procedures under 5 CFR part 302, including veterans’ preference and pass over procedures.
  • Reassignment Scope: This applies whether the new intern position is on a career ladder, in a different job series, in a different series with a career ladder, or is the same series and grade level as the original intern NTE position.

Reassignment of Interns (General)

For intern reassignments in general, agencies must:

  • Follow Agency Policies: Adhere to their own agency policies regarding the movement of excepted service personnel.
  • Meet Qualification Requirements: Ensure the intern meets the qualification requirements for the position they are being reassigned to.
  • Public Notification and Competition Not Required: Reassignment within the intern program generally does not require public notification or open competition.

Reassignment of Recent Graduates

Reassignment rules for Recent Graduates within the same agency are similar to those for interns:

  • Follow Agency Policies: Agencies must follow their own policies for movement of excepted service personnel.
  • Meet Qualification Requirements: The Recent Graduate must meet the qualification requirements for the new position.
  • Public Notification and Competition Not Required: Reassignment within the agency generally does not require public notification or competition.

Time-in-Grade Limitations

Interns, Recent Graduates, and PMFs in Pathways Programs are not subject to time-in-grade limitations (5 CFR 300 subpart F) prior to promotion.

Key points:

  • Time-in-Grade Not Applicable: Time-in-grade restrictions only apply to movement within the competitive service, not within the excepted service Pathways Programs.
  • Qualification Requirements Still Apply: Interns, recent graduates, and PMFs must still meet the qualification requirements for promotion to a higher grade level.
  • Promotions Not Entitlements: Promotions are never guaranteed and depend on agency needs and policies.
  • Agency Promotion Policies Required: Agencies must have an excepted service policy in place that covers promotions for positions within the excepted service, including Pathways positions.

IX. Training and Development in Pathways Programs: Investing in Future Leaders

Training and development are integral components of Pathways Programs, designed to equip participants with the skills and knowledge needed for successful federal careers.

Individual Development Plans (IDPs) for Interns

While not mandatory for all interns, OPM recommends IDPs for most Internship Program participants.

  • OPM Recommendation: OPM encourages agencies to provide all interns with appropriate training and development activities, regardless of appointment length (5 CFR 362.203(i)).
  • IDP for Longer Appointments: For interns appointed for more than 1 year initially and intern NTEs for more than 90 days, OPM recommends documenting activities in a training plan, IDP, or Pathways Participant Agreement approved by their supervisor within 45 days of appointment.

Types of Training Activities for Interns

Agencies should provide diverse training opportunities for Pathways interns, which may include:

  • On-the-Job Training: Practical, hands-on learning through work assignments and projects.
  • Formal Training Classes: Structured courses and workshops to develop specific skills and knowledge.
  • Mentoring Sessions: Guidance and support from experienced professionals within the agency.
  • Product/Tool Testing: Opportunities to test and evaluate agency products or tools, gaining practical experience.
  • Project/Task Assistance: Contributing to colleagues’ projects and tasks, broadening exposure and skills.

Temporary Detail Assignments

Interns and recent graduates can participate in temporary detail assignments at other federal agencies, at the discretion of their home agency. Detail assignments offer valuable cross-agency experience and networking opportunities.

X. Conversion to Competitive Service: Transitioning to Permanent Federal Roles

A key goal of Pathways Programs is to provide a pathway for interns and recent graduates to transition into permanent federal careers. Conversion to the competitive service is a significant benefit of these programs.

Changes to Intern Conversion Requirements

Recent regulatory changes have adjusted the conversion process for interns:

  • Extended Conversion Period: The time period allowed for agencies to convert interns after degree completion has been extended from 120 days to 180 days.
  • Reduced Minimum Work Hours: The minimum work hours required for conversion has been lowered from 640 hours to 480 hours.

Agencies may still require more than the minimum 480 hours for conversion, as detailed in their Pathways Policies.

180-Day Conversion Clock

The 180-day conversion clock for interns starts when the student completes their educational requirements, as determined by their educational institution or career/technical program. Agencies should defer to the institution’s determination of completion date.

Impact on Current Interns

The extension to 180 days for conversion, effective June 11, 2024, applies to current interns. Interns who had not yet reached the previous 120-day limit by this date now have the benefit of the 180-day period. For example, an intern completing their degree on May 4, 2024, now has until October 31, 2024, for conversion, instead of the previous September 1, 2024, deadline.

Agency Authority to Require More Than Minimum Work Hours

Yes, agencies are allowed to require more than 480 work hours for intern conversion. Agencies can set higher minimum hour requirements and can differentiate these requirements for different positions. The specific minimum hour requirement for conversion must be clearly stated in the agency’s Pathways Policies.

Waivers for Intern Work Hour Requirement

Agencies have the option to waive a portion of the intern work hour requirement under specific conditions (5 CFR 362.204(d)).

Waiver criteria:

  • Minimum 320 Hours Worked: The intern must have completed at least 320 hours of career-related work experience under a Pathways Internship Program appointment.
  • Exceptional Job Performance: Demonstrated through a formal performance evaluation by the supervisor, resulting in a rating higher than “Fully Successful” or equivalent.
  • High Potential: Demonstrated high potential in their academic or career/technical program.

Waiver limits:

  • Agencies can waive up to one-half of the minimum service hour requirement.
  • Maximum waiver amount is 160 hours if the minimum requirement is 480 hours, or up to 320 hours if the minimum is 640 hours or more.

Examples of waiver application:

  • Example 1: 320 hours worked, agency can waive 160 hours (for 480-hour minimum).
  • Example 2: 420 hours worked, agency can waive 60 hours (for 480-hour minimum).
  • Example 3: 220 hours worked, no waiver possible yet. Must work at least 320 hours first.
  • Example 4: 320 hours worked, agency with 640-hour minimum can waive 320 hours.
  • Example 5: 480 hours worked, agency with 800-hour minimum can waive 320 hours.

Determining Exceptional Job Performance for Waivers

Exceptional job performance for waiver purposes is defined as a formal performance evaluation by the intern’s supervisor(s) that results in a rating of record (or summary rating) higher than “Fully Successful” or its equivalent within the agency’s performance appraisal system.

Determining High Potential for Waivers

Demonstrating “high potential” in an academic or career/technical program can be achieved through any of the following:

  • GPA: Achieving an overall grade point average of 3.5 or better on a 4.0 scale.
  • Class Rank: Standing in the top 10% of their graduating class.
  • Honor Society Induction: Induction into a nationally recognized scholastic honor society.
  • Recommendation Letter: A letter of recommendation from an instructor or program administrator attesting to outstanding performance.

Crediting Non-Federal Internship Experience

Agencies can grant credit towards the Internship work hour requirement for prior non-federal internship experience under specific conditions.

Credit for non-federal internships:

  • Third-Party Federal Agency Internships: Credit can be granted for service in non-federal internships at a federal agency through a third-party internship provider.
  • Minimum 320 Pathways Hours: The intern must have completed at least 320 hours of career-related work under a Pathways Internship Program appointment before non-federal hours can be credited.

Credit limits:

  • Agencies can credit up to half of the minimum service work hour requirement.
  • Maximum creditable hours are 160 hours if the minimum requirement is 480 hours, or up to 320 hours if the minimum is 640 hours or more.

Examples of crediting non-federal experience:

  • Example 1: Non-federal internship + 320 Pathways hours, agency can credit 160 hours.
  • Example 2: Non-federal internship + 420 Pathways hours, agency can credit 60 hours.
  • Example 3: Non-federal internship + 220 Pathways hours, no credit yet. Must reach 320 Pathways hours.
  • Example 4: Non-federal internship + 420 Pathways hours, agency with 640-hour minimum can credit 220 hours.
  • Example 5: Non-federal internship + 420 Pathways hours, agency with 800-hour minimum can credit up to 320 hours.

Documentation for Waiver Approval

When approving waivers, agencies should consider documentation that substantiates both exceptional job performance and high potential.

Acceptable waiver documentation examples:

  • Performance Rating: Performance rating (record or summary) higher than “Fully Successful” or equivalent.
  • Academic Excellence Documentation (one of the following):
    • Official or unofficial transcript showing GPA of 3.5 or higher or top 10% class rank.
    • Letter of acceptance into a nationally recognized scholastic honor society.
    • Letter of recommendation from instructor or program administrator attesting to outstanding program performance.

Conversion from Intern to Recent Graduate Program

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

Key points:

  • Internship to Competitive Service: Pathways Internship Program is designed for potential conversion to positions in the competitive service only.
  • No Conversion to Other Developmental Programs: The intent is not to transition interns into another developmental program like Recent Graduates.
  • Recent Graduate Program Public Notification: Filling Recent Graduates Program positions requires public notification (5 CFR 362.303(a)).

Conversion to Excepted Service Positions

Pathways Intern and Recent Graduate appointments are designed for conversion to positions in the competitive service, not excepted service positions.

Rationale:

  • Exception to Competitive Process: Pathways authorities are meant to be an exception to the standard competitive hiring process, leading to competitive service roles.
  • Executive Order 13562: The Pathways Programs Executive Order and implementing regulations specifically focus on conversion to the competitive service.

Conversion of Interns with NTE Dates

Yes, interns with NTE (Not-to-Exceed) appointments may be non-competitively converted to competitive service positions, provided the original job announcement for the intern NTE position stated the possibility of conversion and all other conversion requirements are met. However, conversion of intern NTEs should be rare, as these positions are intended for temporary projects, labor-intensive tasks, or summer jobs.

Agency Obligation to Convert Interns

Agencies are not obligated to convert any Pathways participant (intern, recent graduate, or PMF) to a competitive service position, even upon program completion. Conversion is not an entitlement. However, agencies have the discretion to convert an intern if the job announcement indicated conversion potential and all requirements are met.

180-Day Grace Period for Interns with NTE Dates

No, interns with NTE appointments do not have a 180-day grace period after graduation to remain in the program. Their NTE appointment ends when the temporary appointment expires (5 CFR 362.205). However, agencies can convert an intern NTE before the original appointment expires if the expiration date falls within 180 days of degree completion, again, provided the job announcement mentioned conversion potential and all requirements are met.

Retention of Interns Post-Graduation if Enrolling in Another Program

Yes, agencies can retain an intern (including intern NTEs) after graduation without public notification or competition if the intern is accepted into another qualifying educational program at the time of graduation (5 CFR 362.203(b)). This is common for students progressing from undergraduate to graduate programs. In such cases, acceptance into a new qualifying program maintains the student’s eligibility for intern employment.

Conversion to Positions with Career Ladders

Yes, Pathways interns who meet all conversion requirements can be non-competitively converted to positions with established career ladders, provided the job announcement for the internship position stated the career ladder potential. For example, an intern in a GS-0299-04 Human Resources Trainee position could be converted to a GS-0201-05/7/9/11 Human Resources Specialist career ladder position.

Trial Periods for Interns

Interns are not required to serve a trial period unless the agency has a general policy requiring trial periods for all employees in the excepted service.

Conversion to Term or Permanent Appointments

Agencies can convert interns, recent graduates, and PMFs to either term or permanent appointments in the competitive service upon successful program completion. When converting to a term appointment, agencies retain the option to subsequently non-competitively convert the individual to a permanent competitive service position at any point before the term appointment expires. This flexibility allows agencies to manage budgetary and resource constraints that might prevent immediate conversion to a permanent position.

XI. Conversion at a Different Agency: Expanding Opportunities

Pathways Programs also facilitate conversion to positions in different federal agencies, providing broader career pathways for participants.

Intern Conversion to Another Agency

Yes, interns who meet conversion requirements can be converted to term or permanent positions in a different federal agency. This offers interns expanded job prospects if their current agency cannot convert them.

Resources for Interns Seeking Conversion in Other Agencies

The Pathways Internship Talent Program is designed to connect interns who cannot be converted within their current agency with job opportunities in other agencies. This program operates through the USAJOBS Agency Talent Portal (ATP).

How the Talent Program works:

  1. Agency Informs Intern of Non-Conversion: Once an agency determines it cannot convert an intern, the intern is offered participation in the Pathways Internship Talent Program.
  2. ATP Access: Interns gain access to the Agency Talent Portal.
  3. Agency Recruitment via ATP: Agencies with early career openings can use the ATP to recruit interns for conversion to permanent or term positions.

Interns and agency hiring managers should contact their agency Pathways Program Officer for more information. Pathways Program Officers can contact [email protected]. Agency hiring managers and PPOs can find more information on the USAJOBS Agency Talent Portal at the ATP Help Center.

Recent Graduate Conversion to Another Agency

Yes, recent graduates who meet conversion requirements can be converted to term or permanent positions in a different agency if their original employing agency is unable to convert them. Reasons for conversion to another agency can include budgetary constraints, reorganizations, position abolishment, cohort-based program completion, or other valid reasons.

Extending Recent Graduate Appointments for Inter-Agency Conversion

Agencies can extend a Recent Graduate’s appointment for up to 120 days to allow time for conversion to a position in a different agency. Extensions beyond 120 days are not permitted.

Career Ladders for Inter-Agency Conversion of Recent Graduates

Yes, a recent graduate converted to a permanent position in another agency can be converted to a position with a career ladder. However, the full performance level of the new position’s career ladder must be equivalent to or lower than the position they would have been converted to at their original agency.

XII. Termination of Appointments: Program Completion and Separation

Understanding the termination conditions for Pathways appointments is important for both agencies and participants.

Intern Appointment Expiration and Termination

Generally, intern appointments expire 180 days after completion of their academic course of study, unless they are non-competitively converted to the competitive service.

Termination before 180 days:

  • Condition of Employment Termination: Termination as a “condition of employment” only occurs at the end of the 180-day period after degree completion.
  • Termination Before 180 Days: If termination occurs before the 180-day mark, the agency must determine if the intern meets the definition of “employee” in chapter 75 of title 5, which would grant appeal rights.
  • Adverse Action Procedures: If appeal rights exist, adverse action procedures in 5 CFR 752 would apply to terminations before the 180-day expiration.

Intern appointment expiration is defined as 180 calendar days after degree or career/technical program completion, unless non-competitively converted under § 362.204.

Reduction in Force (RIF) and Recent Graduate Termination

No, reduction in force (RIF) rules do not apply to a recent graduate whose appointment is terminated upon expiration (5 CFR 362.306(a)). Expiration of a Recent Graduate appointment is specifically excluded from RIF requirements in 5 CFR 351.

XIII. Pathways Memorandum of Understanding (MOU) and Agency Policy: Framework for Implementation

Agencies are required to establish and maintain Pathways Policies to govern their use of the programs, replacing the previous MOU requirement.

Pathways Policies vs. MOUs

OPM has replaced the MOU requirement with a Pathways Policy requirement (5 CFR 362.104). Agencies must have a Pathways Policy in place to utilize the Pathways authority. The policy outlines the agency’s specific parameters for implementing and managing Pathways Programs. Agencies must make their Pathways policies available to OPM, applicants, employees, and other stakeholders upon request.

Existing Pathways MOUs

Agencies with existing Pathways MOUs can continue to use the Pathways Programs under the new regulations, using their MOUs temporarily while developing and updating their policies to fully comply with the new regulations. Agencies without existing MOUs must establish a Pathways Policy before making any Pathways appointments.

Required Content of Agency Pathways Policies

Agency Pathways Policies must include the requirements listed in 5 CFR 362.104 and should detail various aspects of program implementation:

Mandatory policy elements:

  • Agency-Specific Program Labels: Any agency-specific names used for Pathways Programs, adhering to federal naming conventions (§ 362.101(a)) (e.g., “OPM Internship Program”).
  • Delegations of Authority: Specify authority levels for Pathways Program usage within the agency (e.g., department-wide vs. bureau/component level).
  • Implementing Guidance: Any agency-specific policy or guidance to facilitate successful program implementation and administration for each Pathways Program.
  • Training and Development Documentation: Description of how the agency will design, implement, and document formal training and/or development, including assignment types and durations.
  • Agency Commitments: Formal agency commitment to:
    • Provide OPM with requested information on Pathways Programs.
    • Adhere to any Pathways Programs caps set by the OPM Director.
    • Provide information to OPM on Pathways Program opportunities (including PMF appointment postings on TMS).
    • Provide meaningful onboarding processes for each Pathways Program.
    • Align Pathways Program usage with agency workforce and recruitment plans.
  • Extension Criteria (Recent Graduates and PMFs): Criteria and procedures for agency-approved extensions for recent graduates and PMFs (up to 120 days), limited to circumstances making regulatory compliance impractical or impossible.
  • Conversion Resource Determination: Criteria and procedures for determining agency resource availability for converting Pathways Participants to term or permanent competitive service positions. Policies must specify a timeline for making this determination and informing participants no later than 60 calendar days before appointment end whether conversion is possible.
  • Minimum Intern Service Hours: Minimum service-hour requirement(s) for intern conversion (§ 362.204).
  • Recent Graduate Program Length: Program length for Recent Graduate Programs. If programs longer than one year are used, the policy must justify the longer duration.
  • Program Officials: Identification of the agency’s Pathways Programs Officer (PPO) and Presidential Management Fellows (PMF) Coordinator.

Establishing Longer Recent Graduate Programs

The standard Recent Graduates Program is intended as a 1-year, entry-level developmental experience leading to potential permanent employment. Agencies can establish Recent Graduate Programs longer than 1 year if the training demands of specific positions justify a more extended and structured program. Any positions designated for longer programs must be identified in the agency’s Pathways Policy and described in the Pathways Participant Agreement. Individual managers or organizations cannot unilaterally decide program length.

XIV. Presidential Management Fellows (PMF) Program: Premier Leadership Development

The Presidential Management Fellows (PMF) Program is the federal government’s flagship leadership development program for advanced degree holders.

Developmental Assignments Outside Federal Government

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

Permissible developmental assignment locations:

  • Within their PMF’s organization.
  • Within their PMF’s agency.
  • In another Federal agency (defined in 5 U.S.C. 105).
  • In a participating Federal agency within the Legislative Branch.

PMFs can still pursue optional rotations outside their agency at their agency’s discretion and following agency policies.

PMF Finalist Appointment Eligibility Period

PMF finalists have a 12-month window from their official finalist selection date to accept and begin a PMF appointment (5 CFR 362.404). Under limited circumstances (e.g., background investigation delays), agencies can request appointment eligibility extensions. This practice aligns with PMF regulations predating the Pathways Programs regulations.

PMF Appointments to Career Ladder Positions

Yes, individuals participating in the PMF Program can be appointed to positions with established career ladders, provided the PMF appointment opportunity for the position specified the career ladder potential.

ERB Certification Deadline for PMF Program Completion

The deadline for an Executive Resources Board (ERB) to certify a fellow’s successful PMF Program completion is 30 days prior to the fellow’s 2-year anniversary date, including any fellowship extensions up to 120 days. ERB certification is mandatory before conversion.

Online Training as “Formal Interactive Training”

Yes, “formal interactive training” for PMFs can include online training.

Conditions for online training to qualify:

  • Competency Alignment: The online training must address competencies outlined in the fellow’s IDP and prepare them for their target position.
  • Interactivity: The training must be “interactive,” involving communication between instructor and students, and among students.

Ultimately, the agency’s ERB determines if the fellow has met all program requirements, including training type and amount. Agencies may want to clarify training definitions in their Pathways Programs policies.

Agency-Wide or Presidential Initiatives for Developmental Assignments

Yes, PMFs can participate in agency-wide, Presidential, or Administration initiatives to fulfill their 4-to-6-month developmental assignment requirement (5 CFR 362.405(b)(4)(i)). Such initiatives must be 4-6 months in duration to provide equivalent developmental experience. The duration does not need to be consecutive months.

Training Requirement Waivers Due to Budget Constraints

No, OPM will not grant waivers or extensions to the yearly PMF training requirements due to agency budget constraints.

Mandatory training requirements:

  • 80 Hours per Year: Agencies must provide each fellow a minimum of 80 hours of formal interactive training per year.
  • 4-6 Month Developmental Assignment: Each fellow must complete at least one 4-to-6-month developmental assignment during their 2-year fellowship.

The PMF Program Office offers several training opportunities for PMFs that can count towards these requirements. The ERB certification process ensures training completion.

Participation of Non-Executive Branch Agencies and Agencies Excepted by Statute

Yes, agencies whose positions are excepted by statute from title 5 competitive service provisions, and non-Executive Branch agencies (e.g., FBI, Library of Congress, Congressional Research Service) can participate in the PMF Program.

Requirements for participation:

  • Memorandum of Agreement (MOA): Agencies must enter into a MOA with OPM to participate.
  • PMF Program Policies: Participating agencies must have PMF Program policies in effect.
  • Excepted Service Placement: Upon program completion, fellows in these agencies are eligible only for placement into excepted service positions, not competitive service positions.

Part-Time Work Schedules for Fellows

Yes, an agency may approve a part-time work schedule for a PMF, at the fellow’s request, for a limited period up to 6 months.

Conditions for part-time schedules:

  • Program Requirements Met: The fellow must still meet all PMF Program requirements within their 2-year program (and any approved extension).
  • Training and Development Adjustments: The fellow and agency must account for adjustments to training and developmental activities for each fellowship year.

Agency Obligation to Approve Part-Time Schedules

No, agencies are generally not required to approve PMF requests for part-time work schedules. Approval is at the agency’s discretion.

Factors to Consider for Part-Time Schedules

Fellows and agencies should consider the impact of a part-time schedule on:

  • Program Completion: The fellow’s ability to meet all program requirements by the appointment expiration.
  • Promotion Qualifications: Potential impact on meeting qualification requirements for promotions.

Timeline for Informing Fellows of Non-Conversion

Agencies must inform PMFs about whether they will be converted no later than 60 calendar days before the end of their appointment or any approved fellowship extension. OPM encourages agencies to make conversion resource determinations and inform PMFs as early as possible. Agencies must include procedures and criteria for conversion decisions and communication in their Pathways Policies and are encouraged to indicate a conversion decision timeframe in the Pathways Participant Agreement.

Fellow Conversion to Another Agency

Yes, PMFs who meet conversion requirements can be converted to term or permanent positions in a different agency if their original agency cannot convert them. Reasons for inter-agency conversion are similar to those for recent graduates (budget constraints, reorganizations, etc.).

Extending Fellow Appointments for Inter-Agency Conversion

Yes, agencies can extend a fellow’s appointment for up to 120 days to allow time for conversion to a position in another agency. Extensions beyond 120 days are not allowed.

Career Ladders for Inter-Agency Conversion of Fellows

Yes, a PMF converted to a permanent position in another agency can be placed in a position with a career ladder. The new position’s career ladder must be equivalent to or lower than the career ladder of the position they would have been converted to at their original agency.

Reduction in Force (RIF) and PMF Appointment Expiration

No, separation due to PMF appointment expiration is not subject to RIF requirements in 5 CFR part 351.

OPM Authority to Waive PMF Requirements

No, current PMF regulations do not grant OPM the authority to waive any PMF Program requirements upon agency request. The PMF Program allows for appointment eligibility and fellowship extensions, but not waivers of core requirements.

XV. Questions and Contact Information

For headquarters-level human resources offices, inquiries can be directed to OPM at [email protected]. Component-level HR offices should contact their agency headquarters for assistance. Employees should contact their agency human resources office. Applicants with questions about specific job opportunities should use the contact information provided within the job opportunity announcement.

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