Does the Student Career Employment Program Still Exist? Understanding Federal Pathways Programs in [Current Year]

Navigating the landscape of federal employment can often seem complex, especially for students and recent graduates eager to launch their careers in public service. A common question arises: Does The Student Career Employment Program Still Exist? The answer is yes, and it’s evolved into a robust framework known as the Pathways Programs. This initiative offers various routes for students and recent graduates to gain valuable experience and potentially transition into federal careers. This article will delve into the details of the Pathways Programs, clarifying its components, eligibility criteria, and how it serves as a vital bridge to federal employment.

Understanding the Pathways Programs Framework

The Pathways Programs is not a single entity but rather a framework comprising three distinct programs, each designed to cater to different stages of academic and early career development. These programs, operating under Schedule D excepted service appointments, provide structured pathways into federal agencies:

1. Internship Program: Launching Federal Careers While in School

The Internship Program is tailored for students currently enrolled in high school, undergraduate, or graduate programs. It offers paid work opportunities within federal agencies, allowing students to explore federal careers while continuing their education. This program is open to individuals enrolled at least part-time in various educational institutions, including traditional degree programs, Registered Apprenticeship Programs, and specific volunteer service programs.

To ensure a meaningful experience and potential for conversion to a competitive service position, interns are required to complete a minimum of 480 internship hours. However, in certain circumstances, a waiver can reduce this requirement to 320 hours.

2. Recent Graduates Program: Starting a Federal Career After Graduation

The Recent Graduates Program is designed to provide recent graduates with a structured entry into federal service. It offers developmental experiences, typically lasting one to two years, within federal agencies. Eligibility extends to individuals who have recently graduated from qualifying educational institutions or career and technical education programs.

Applicants are generally eligible to apply within two years of obtaining their degree or certificate. Recognizing the service commitments of veterans, the program extends the application window to six years post-graduation for those unable to apply earlier due to military service obligations.

3. Presidential Management Fellows (PMFs): Premier Leadership Development

The Presidential Management Fellows (PMF) Program represents the federal government’s flagship leadership development initiative. This highly competitive two-year program is aimed at advanced degree candidates and graduates who demonstrate exceptional leadership potential. PMFs are provided with a comprehensive developmental experience, including mentorship, professional development opportunities, a minimum of 160 hours of formal interactive training, and rotational assignments. This program is a prestigious pathway for those seeking leadership roles within the federal government.

Regulatory Foundation of the Pathways Programs

The rules and guidelines governing the Pathways Programs are formally documented in the Code of Federal Regulations (CFR), specifically within 5 CFR parts 362, 213, 302, and 315. Understanding these regulations is crucial for both agencies administering the programs and individuals seeking to participate.

5 CFR Part 362, Subpart A: Outlines the general rules applicable to all Pathways Programs, providing a foundational framework for the initiative.
5 CFR Part 362, Subpart B: Details the specific regulations exclusively for the Internship Program, covering aspects like eligibility, program structure, and conversion criteria.
5 CFR Part 362, Subpart C: Focuses on the rules specific to the Recent Graduates Program, including eligibility requirements, developmental program parameters, and conversion pathways.
5 CFR Part 362, Subpart D: Addresses the unique regulations of the PMF Program, outlining the selection process, program components, and conversion opportunities for fellows.
5 CFR 213.3401-2: Provides general provisions pertaining to Schedule D of the excepted service, the specific hiring authority under which Pathways Programs operate.
5 CFR Part 302: Governs the procedures for filling excepted service positions, including the application of veterans’ preference within the Pathways Programs.

Agencies are strongly advised to consult these regulatory provisions to ensure compliance when utilizing the Pathways Programs. Seeking guidance from agency counsel is recommended when questions or interpretations arise.

Eligibility Requirements: Who Can Apply?

Each Pathways Program has specific eligibility criteria to ensure that participants are appropriately matched to the program’s objectives.

Internship Program Eligibility:

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

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

It’s important to note that individuals nearing graduation who require less than half-time coursework to complete their degree are still considered eligible.

Alt text: A diverse group of students collaboratively studying in a library, symbolizing the academic focus of the Pathways Internship Program.

Recent Graduates Program Eligibility:

For the Recent Graduates Program, eligibility is based on educational attainment within the past two years. Applicants must have:

Obtained 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 within the two years preceding application.

Qualifying Career or Technical Education Programs:

The Pathways Programs recognize specific types of programs as meeting the criteria for career and technical education. These include:

Federally Administered Educational Programs: Programs with rigorous academic content, technical skill development, and recognized postsecondary credentials, designed to prepare individuals for further education or careers in current or emerging fields.
Registered Apprenticeship Programs: Structured programs combining on-the-job training with related technical instruction.
Federally Administered Volunteer Service Programs: Local, state, national, or international volunteer service programs overseen by federal agencies.

Federally Administered Program Oversight:

Federally administered career or technical education programs are characterized by programmatic oversight from a federal agency. This oversight encompasses:

Defining the nature and scope of work participants will undertake.
Specifying the type and extent of training provided.
Identifying the skills participants will acquire (e.g., technical, leadership, administrative).
Establishing mentoring frameworks for participants.
Defining metrics for successful program completion.

This programmatic oversight is often formalized through partnership or cooperative agreements.

Acceptable Documentation for Eligibility Verification:

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

Internship Program Documentation: Agencies may accept:

Transcripts (official or unofficial).
Copies of diplomas.
Letters from educational institutions or career/technical programs confirming enrollment or acceptance.

Recent Graduate Program Documentation: Agencies may accept similar documentation, ensuring it sufficiently demonstrates eligibility according to 5 CFR 362.302. Key information includes:

Applicant’s name.
Degree or program name.
Completion date (or expected completion date).
Program length (for certificate programs or volunteer service programs).

Application Timing for Recent Graduates Program:

Applicants do not need to have fully completed their degree or program to apply for the Recent Graduates Program. Students in their final weeks or months of study are eligible to apply. However, they must meet the definition of a recent graduate (5 CFR 362.302) by the time of appointment.

Agencies can set specific application deadlines based on program completion dates, as outlined in their Pathways policy and application procedures (5 CFR 302.301).

Defining Valid Certificate Programs:

A certificate program, for Pathways Programs eligibility, is defined as post-secondary education at a qualifying institution, equivalent to at least one academic year of full-time study. This can be:

A program at a trade or vocational school, 2-year or 4-year college/university, or graduate/professional school, accredited at the college level.
A qualifying career or technical education program of at least one year awarding a recognized postsecondary credential.

Citizenship Requirements:

While there isn’t a blanket U.S. citizenship requirement for excepted service positions, including Pathways Programs, it’s nuanced:

Agency-Specific Restrictions: Many agencies have funding restrictions or enabling statutes limiting the employment of non-citizens. Agencies must consult their counsel to determine applicability.
Lawful Residency: Non-citizens may be appointed to Pathways Programs positions only if they are lawfully admitted permanent residents or otherwise authorized for employment in the U.S.
Conversion to Competitive Service: To be eligible for non-competitive conversion to permanent federal employment in the competitive service after completing a Pathways Program, participants must possess full U.S. citizenship.

Public Notification for Pathways Positions

Transparency and open competition are fundamental principles in federal hiring. The Pathways Programs incorporate public notification requirements to ensure broad awareness of opportunities.

Options for Public Notification:

Agencies have two primary methods to fulfill the public notification requirement (5 CFR 326.104(c)(6)(iii) and 362.105(b)):

USAJOBS.gov Posting: Publishing a searchable job announcement on the official federal job portal, USAJOBS.gov.
Agency Website Posting with USAJOBS Link: Posting job information on the agency’s public-facing career webpage, including a direct link to a custom job announcement on USAJOBS.

In addition to these core methods, agencies are encouraged to expand outreach through third-party websites and social media platforms. PMF appointment opportunities are posted within the PMF Program’s Talent Management System (TMS).

Required Information in Job Announcements:

Job announcements for Internship and Recent Graduate Programs must include, at a minimum:

Position title, series, and grade level.
Starting salary.
Geographic location(s).
Minimum qualifications.
Application instructions or a link to the agency’s website for details.
Reasonable Accommodation statement.
Veterans’ preference information.
Conversion potential (if applicable).
Promotion potential (if applicable).

OPM also recommends including:

Brief job description.
Work schedules.
Links to Pathways Programs information.
Relocation expenses or recruitment incentives (if applicable).

Career Fairs and Public Notification:

Agencies cannot solely rely on career fairs for recruitment without broader public notification. While career fairs can be valuable outreach tools, agencies must also provide public notification through USAJOBS or their website and offer an alternative application method for candidates unable to attend the event.

Managing Application Volume:

Agencies have strategies to manage potentially high application volumes for Pathways positions:

Limited Announcement Period: Agencies can set specific opening and closing dates for job announcements, considering factors like position type, grade level, and location.
Application Limits: Agencies can establish “cut-offs,” limiting the number of applications reviewed (e.g., first 75 or 100 received). OPM recommends accommodating applications received until 11:59 p.m. on the cut-off day to account for time zones.
Specific Eligibility Requirements: Agencies can incorporate specific eligibility criteria, such as required work hours per week or minimum GPA, as long as these are job-related and consistent with merit system principles. Agencies can also require applicants to confirm their ability to work in specified locations.

Any limitations used must be clearly stated in the job opportunity announcement, and agency procedures (5 CFR 302.201) must address these options. Agencies must ensure fair and open competition and consult with agency counsel.

Custom Postings on USAJOBS

USAJOBS offers a “custom posting” feature that provides agencies with flexibility in their recruitment efforts.

What is a USAJOBS Custom Posting?

A custom posting is a job announcement within USAJOBS accessible only through a unique link or URL. It is not searchable on the general USAJOBS platform. If the “Apply Online” option is enabled, applicants can track their application status, and agencies receive applicant flow data.

Using Custom Postings for Public Notification:

Utilizing a custom posting meets the Pathways public notification requirement when the agency shares the custom posting link publicly, typically by posting it on the agency’s website. This link can also be distributed through other recruitment channels.

When to Use Custom Postings:

While OPM encourages standard USAJOBS postings for broad visibility, custom postings offer an alternative. Agencies might opt for custom postings when they want to target specific audiences or recruitment channels while still leveraging the USAJOBS platform for application management and data collection.

Creating Custom Postings:

Custom postings are created within the Talent Acquisition System (TAS). Upon creation, the HR specialist receives the unique URL to share.

Resources for Custom Postings:

For detailed steps on creating custom postings, agencies should consult their agency’s TAS point of contact. Additional questions can be directed to [email protected].

Recruitment Strategies for Pathways Programs

Effective recruitment is crucial for attracting qualified candidates to Pathways Programs.

Outreach Activities:

Agencies can conduct outreach activities, including campus visits, before or without posting a USAJOBS announcement. These activities can be informational, awareness-building events, or liaison efforts.

Strategic Recruitment for Diversity:

Strategic recruitment efforts are encouraged to build a diverse applicant pool. Agencies should ensure these activities are part of a broader recruitment plan and that public notice of opportunities remains accessible to all.

On-Campus Recruitment Events:

If agencies hold on-campus recruitment events where applications are accepted, the public announcement (on USAJOBS or the agency website) must include:

Event location, date, and time.
Access information, including reasonable accommodation details.
Position title, series, and grade level.
Geographic location(s).
A public source (e.g., agency webpage link) with event details and alternative application methods for those unable to attend.
Veterans’ preference information.

Effective Recruitment Practices:

OPM recommends agencies adopt the following effective recruitment practices:

Workforce Planning-Based Strategy: Align recruitment with agency workforce planning goals.
Diverse Talent Sources: Actively recruit from a variety of sources to attract qualified candidates from all segments of society.
Spectrum of Campuses/Schools: Recruit from a diverse range of educational institutions.
Open On-Campus Events: Ensure on-campus events are open to all students, not limited to the host campus. Provide alternative application methods and comprehensive information for those unable to attend.
Promote USAJOBS and Pathways Portals: Raise awareness of USAJOBS, the Federal Internship Portal (https://intern.usajobs.gov/), and the Recent Graduate Portal (https://recentgrad.usajobs.gov/).
Consider Campus Proximity: When planning on-campus recruitment, consider the feasibility of commuting to the job location for students.

Veterans’ Preference and Pass Overs in Pathways Programs

Veterans’ preference is a legally mandated principle applied to federal hiring, including the Pathways Programs.

Application of Veterans’ Preference:

Yes, agencies are required to apply veterans’ preference when making selections for Pathways Programs positions (5 CFR 362.105(c)(2)).

Procedures for Applying Veterans’ Preference:

Agencies must adhere to procedures outlined in 5 U.S.C. 3320, 5 CFR 302, and applicable agency policies. The specific application method depends on the selection process chosen by the agency:

Ranked List: Similar to the “rule of three” in competitive service. Applicants are scored, preference points are added for eligible veterans, and selection is made from the top three ranked candidates. 10-point disabled veterans are placed at the top of the list. Pass over procedures are required to select a non-preference eligible over an equally or higher-ranked preference eligible veteran.
Unranked List: Applicants are categorized by veterans’ preference (10-point disabled, other 10-point, 5-point, non-preference). Agencies must consider candidates in the highest preference category first. Pass over procedures are required to select a non-preference eligible before exhausting preference eligibles.
Category Rating-Like Process: Agencies can establish their own systems (5 CFR part 302.105) provided they offer at least equivalent advantage to preference eligibles as ranked or unranked methods. Many agencies use a category rating-like process, similar to category rating in competitive service. Applicants are placed in quality categories, and preference eligibles are listed ahead of non-preference eligibles within each category, with 10-point disabled veterans in the highest category. Selection must be from the highest quality category. Pass over procedures apply to select non-preference eligibles before preference eligibles in the top category are exhausted. If fewer than three candidates are in the top category, agencies can merge categories, ensuring preference eligibles from both categories are listed first.
Professional Order: For GS-9 and above professional/scientific positions, agencies can use ranked or unranked lists. Ranked lists apply preference points. Unranked lists categorize applicants by preference status, with preference eligibles considered first. Pass over procedures apply before selecting non-preference eligibles.

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

A preference eligible veteran without a 30% or more compensable disability can be passed over only if the agency sustains the selecting official’s objection for adequate reason. Reasons must be documented and can include medical disqualification (5 CFR Part 339), suitability concerns (5 CFR 731.202), or other agency-considered reasons. Agencies should consult 5 U.S.C. 3320 and 5 CFR 332.406 and agency counsel to ensure reasons meet the “same manner and under the same conditions” standard. OPM approval is needed for medical disqualification pass overs. The veteran is entitled to the agency’s pass over reasons upon request.

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

Special procedures apply to medically disqualifying or passing over veterans with a 30% or more compensable service-connected disability (5 U.S.C. 3312, 5 CFR 339.102(c), 332.406):

Medical Disqualification:

Agency notifies both OPM and the veteran in writing of the disqualification reasons and the veteran’s right to respond to OPM within 15 days.
Agency provides OPM proof of timely notification to the veteran’s last known address.
OPM determines the veteran’s physical ability, considering veteran input and agency evidence, including the infeasibility of reasonable accommodation and inability to perform essential functions without endangering safety.
OPM may request further agency evidence.
If OPM agrees with disqualification, the agency can select another candidate. If OPM disagrees, the agency cannot pass over the veteran for medical reasons.
This procedure does not prevent agencies from filling other positions if multiple vacancies exist.
OPM notifies the agency and veteran of its decision, which is binding.
OPM cannot delegate these functions.

Non-Medical Pass Over:

Agency notifies both OPM and the veteran in writing of the pass over reasons and the veteran’s right to respond to OPM within 15 days.
Agency provides OPM proof of timely notification.
OPM determines if the pass over request is for proper and adequate reason, considering veteran input and agency evidence.
OPM may request further agency evidence.
If OPM sustains the pass over request, the agency can select another candidate. If OPM disagrees, the agency cannot pass over the veteran for the presented reason.
This procedure does not prevent agencies from filling other positions if multiple vacancies exist.
OPM notifies the agency and veteran of its decision, which is binding.
OPM cannot delegate these functions.

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 for Pathways Programs positions. These are separate hiring authorities with distinct eligibility and processes. Applicants with disabilities can apply for Pathways Programs positions through standard announcements on USAJOBS (external link) and are considered in the same manner as other applicants (5 CFR part 302). Agencies are required to provide reasonable accommodations as legally mandated.

Qualifications and Assessments for Pathways Programs

Ensuring qualified candidates are selected for Pathways Programs involves appropriate qualification standards and assessments.

Assessment Requirements:

For the Internship and Recent Graduate Programs, agencies must use valid job-related assessments. Examples include:

Crediting plans (rating schedules or occupational questionnaires).
Structured interviews.
Administrative Careers With America (ACWA) rating schedules.

Depending on the selection method (5 CFR part 302), agencies may assess only for general eligibility/minimum qualifications. OPM uses assessments to create PMF finalist lists.

OPM Qualification Standards for Recent Graduates:

Yes, agencies must use OPM Qualification Standards or OPM-approved standards for positions filled through the Recent Graduates Program. Agency-specific qualification standards are not permitted. Agencies must use OPM standards, OPM-approved standards, or legally mandated qualification standards.

OPM Qualification Standards for Internships:

No, agencies are not required to use OPM Qualification Standards for Internship positions. Agencies have the option to:

Establish agency-specific qualification requirements.
Use OPM qualification requirements for the competitive service.
Use the [Group Coverage Qualification Standard for Schedule D, Pathway Internship Positions]([invalid URL removed]).

Further Clarification on Assessment Requirements:

To reiterate, for Intern and Recent Graduate Programs, agencies must employ job-related assessments like crediting plans, rating schedules, structured interviews, or ACWA tools. Assessment depth may vary based on the selection methodology, potentially focusing solely on minimum qualifications. OPM manages assessments for PMF finalist selection.

Promotions and Reassignments within Pathways Programs

Pathways Programs offer opportunities for growth and development, including potential promotions and reassignments.

Intern Promotions:

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

The agency having an excepted service policy for promoting employees in excepted service positions.
The intern meeting the qualification requirements for the higher-graded position.

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, but internal public notification is required. Agencies must provide notice to similarly situated agency interns who may be interested. If multiple interns express interest, agencies must apply selection procedures (5 CFR part 302), including veterans’ preference and pass over procedures. This applies to reassignments within the same series, to different series, or to positions with career ladders.

Reassignment of Interns (General):

Agencies must adhere to their own policies regarding the movement of excepted service personnel when reassigning interns. The intern must meet the qualification requirements for the new position.

Reassignment of Recent Graduates:

Similar to interns, reassigning Recent Graduates within the same agency requires adherence to agency policies for excepted service personnel movement. The Recent Graduate must meet the qualification requirements of the new position.

Time-in-Grade Limitations:

No, Interns, Recent Graduates, and PMFs are not subject to time-in-grade limitations (5 CFR 300 subpart F) prior to promotion. Time-in-grade restrictions apply only to movement within the competitive service. However, Pathways participants must still meet the qualification requirements for promotion to higher grade levels. Promotions are never guaranteed, and agencies must have an excepted service policy covering promotions within excepted service positions.

Training and Development in Pathways Programs

Training and development are integral components of the Pathways Programs, ensuring participants gain valuable skills and experience.

Individual Development Plans (IDPs) for Interns:

OPM requires agencies to provide all interns with appropriate training and development activities, regardless of appointment length (5 CFR 362.203(i)). For interns appointed for over a year or NTE interns for over 90 days, OPM recommends documenting activities in a training plan, Individual Development Plan (IDP), or Pathways Participant Agreement within 45 days of appointment.

Types of Training Activities for Interns:

Appropriate training activities for interns may include:

On-the-job training.
Formal training classes.
Mentoring sessions.
Product/tool testing.
Assisting colleagues with projects.

Temporary Detail Assignments:

Yes, interns and recent graduates can participate in temporary detail assignments at other agencies, at the discretion of their home agency.

Conversion to the Competitive Service from Pathways Programs

A key goal of the Pathways Programs is to provide a pipeline for talented individuals to transition into permanent federal careers.

Changes to Intern Conversion Requirements:

Recent updates to the conversion process for interns include:

Extended conversion timeframe: Agencies now have 180 days (increased from 120 days) after degree completion to convert interns.
Reduced minimum work hours: The minimum work hour requirement for conversion has been lowered to 480 hours (reduced from 640 hours). However, agencies can set higher minimums.

180-Day Conversion Clock for Interns:

The 180-day conversion period begins when the student completes their educational requirements (as determined by their institution), not necessarily upon formal graduation or degree conferral. Agencies should defer to the educational institution’s determination of completion.

Impact of Extended Conversion Period on Current Interns:

The extension to 180 days, effective June 11, 2024, applies to interns who have not yet exceeded the previous 120-day limit by that date. For example, an intern completing their degree on May 4, 2024, now has until October 31, 2024, for conversion (180 days) instead of the previous September 1, 2024 (120 days).

Agency Authority to Require More Than 480 Work Hours for Conversion:

Yes, agencies are allowed to require more than 480 work hours for intern conversion and can set different minimums for different positions. The agency’s Pathways Policies must specify the minimum hour requirement for conversion.

Criteria for Waiving Intern Work Hour Requirement:

Agencies can waive up to half of the minimum service hour requirement if an intern meets specific criteria (5 CFR 362.204(d)):

Completion of at least 320 hours of career-related work experience under a Pathways Internship Program appointment.
Exceptional job performance: Demonstrated through a formal performance evaluation (rating higher than “fully successful” or equivalent).
High potential: Evidenced by at least one of the following:
- GPA of 3.5 or higher (on a 4.0 scale).
- Top 10% class ranking.
- Induction into a nationally recognized scholastic honor society.
- Recommendation letter from an instructor or program administrator attesting to outstanding performance.

Examples of Waiver Application:

Example 1: 320 hours worked – agency can waive 160 hours (towards 480).
Example 2: 420 hours worked – agency can waive 60 hours (towards 480).
Example 3: 220 hours worked – no waiver possible yet (must reach 320 hours).
Example 4 (Agency minimum 640 hours): 320 hours worked – agency can waive 320 hours (towards 640).
Example 5 (Agency minimum 800 hours): 480 hours worked – agency can waive 320 hours (towards 800).

Determining Exceptional Job Performance for Waiver:

Exceptional job performance is determined through a formal evaluation by the intern’s supervisor, consistent with the agency’s performance appraisal program, resulting in a rating exceeding “fully successful” or its equivalent.

Determining High Potential for Waiver:

High potential is demonstrated through at least one of the following achievements:

GPA of 3.5 or higher.
Top 10% class ranking.
Induction into a nationally recognized scholastic honor society.
Recommendation letter from an instructor or program administrator.

Crediting Non-Federal Internship Experience:

Agencies may grant credit for up to half of the minimum service hour requirement for interns with prior non-federal internship experience at a federal agency through a third-party provider, provided the intern has completed at least 320 hours under a Pathways Internship appointment.

Examples of Crediting Non-Federal Internship Experience:

Example 1: Non-federal internship + 320 Pathways hours – agency can credit 160 hours (towards 480).
Example 2: Non-federal internship + 420 Pathways hours – agency can credit 60 hours (towards 480).
Example 3: Non-federal internship + 220 Pathways hours – no credit possible yet (must reach 320 Pathways hours).
Example 4 (Agency minimum 640 hours): Non-federal internship + 420 Pathways hours – agency can credit 220 hours (towards 640).
Example 5 (Agency minimum 800 hours): Non-federal internship + 420 Pathways hours – agency can credit 320 hours (towards 800).

Documentation for Waiver Approval:

Agencies should consider documentation demonstrating both exceptional job performance and high potential when approving waivers. Acceptable documentation includes:

Performance rating exceeding “Fully Successful” or equivalent, and one of the following:
- Transcript showing GPA of 3.5 or higher or top 10% class ranking.
- Letter of acceptance into a national honor society.
- Recommendation letter from an instructor or program administrator.

Conversion from Internship to Recent Graduates Program:

No, agencies cannot non-competitively convert a Pathways intern directly to the Recent Graduates Program. Interns are eligible only for non-competitive conversion to positions in the competitive service. The Internship Program is designed for potential permanent placement or exploration of federal careers, not as a stepping stone to another developmental program. Public notification is required for filling Recent Graduates Program positions (5 CFR 362.303(a)).

Conversion to Excepted Service vs. Competitive Service:

Pathways Programs are designed as an exception to competitive hiring processes, facilitating entry into positions that would typically be filled competitively. Therefore, non-competitive conversion from Pathways Programs leads to positions in the competitive service, not excepted service. The Pathways Programs Executive Order and regulations do not provide for conversion to excepted service positions for interns or recent graduates.

Conversion of Interns with NTE Appointments:

Yes, interns with NTE appointments can be non-competitively converted to competitive service positions if the initial job opportunity announcement stated conversion potential and all other conversion requirements are met. However, NTE intern positions are intended for temporary projects, labor-intensive tasks, or summer jobs, so conversion should be infrequent.

Agency Obligation to Convert Interns:

No, agencies are not obligated to convert any Pathways participant, including interns, to a competitive service position, even upon program completion. Conversion is discretionary, not an entitlement. However, agencies may convert interns if the job announcement indicated conversion potential and all requirements are fulfilled.

180-Day Grace Period for Interns with NTE Appointments:

No, interns with NTE appointments do not have a 180-day grace period post-graduation to remain in the program. Their appointments end upon the NTE expiration date (5 CFR 362.205). However, agencies may convert NTE interns before their appointment expires if it falls within 180 days of degree completion, provided conversion potential was stated in the job announcement and other requirements are met.

Retaining Interns After Graduation:

Yes, agencies can retain interns (including NTE interns) 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 allows students transitioning to further education (e.g., from college to master’s) to maintain intern status.

Conversion to Positions with Career Ladders:

Yes, interns meeting conversion requirements can be non-competitively converted to positions with established career ladders if the initial job announcement indicated the career ladder potential. For example, an intern GS-0299-04 Human Resources Trainee 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 mandating trial periods for all excepted service employees.

Conversion to Term or Permanent Appointments:

Yes, agencies can convert interns, recent graduates, or PMFs to either term or permanent positions upon completion of all conversion requirements. Conversion to term appointments offers flexibility for agencies facing budgetary or resource constraints. Individuals initially converted to term appointments can later be non-competitively converted to permanent competitive service positions before the term appointment expires.

Conversion at a Different Agency

Pathways Programs also facilitate conversion to positions in agencies other than the participant’s initial employing agency.

Intern Conversion to a Different Agency:

Yes, interns meeting conversion requirements can be converted to term or permanent positions in a different federal agency.

Resources for Interns Seeking Conversion in Other Agencies:

The Pathways Internship Talent Program, accessible through the USAJOBS Agency Talent Portal (ATP), assists interns unable to be converted by their current agency to find opportunities in other agencies. Interns are offered participation in this program upon notification of non-conversion by their employing agency. Agencies with early career openings can utilize the program to recruit interns for conversion. For further information, Pathways participants and agency managers should contact their agency Pathways Program Officer, and Pathways Program Officers can contact [email protected]. Agency managers and Pathways Program Officers can find resources at the ATP Help Center.

Recent Graduate Conversion to a Different Agency:

Yes, recent graduates meeting conversion requirements can be converted to term or permanent positions in a different agency if their initial employing agency cannot convert them. Reasons for conversion to another agency may include budgetary issues, reorganizations, position abolishment, cohort program completion, or other valid reasons.

Extending Recent Graduate Appointments for Inter-Agency Conversion:

Yes, agencies may extend recent graduate appointments for up to 120 days to allow time for conversion to a different agency. Extensions beyond 120 days are not permitted.

Career Ladder Positions in Different Agencies for Recent Graduates:

Yes, recent graduates converted to a different agency can be placed in positions with career ladders. The full performance level of the new position must be equivalent to or lower than the position they would have been converted to at their original agency.

Termination of Pathways Appointments

Understanding the terms of appointment and termination processes is essential for both agencies and participants.

Intern Termination Prior to 180-Day Expiration:

Intern appointments typically expire 180 days after academic completion unless converted. If termination occurs before the 180-day mark, agencies must assess if the intern meets the definition of “employee” under chapter 75 of title 5, which determines appeal rights. If appeal rights exist, adverse action procedures in 5 CFR 752 apply. Termination as a condition of employment only occurs upon separation at the end of the 180-day period.

Reduction in Force (RIF) Rules and Recent Graduates:

No, RIF rules do not apply to recent graduates terminated upon appointment expiration (5 CFR 362.306(a)).

Pathways Memorandum of Understanding (MOU) and Agency Policy

Agency-level policies and agreements are critical for effective Pathways Programs implementation.

MOU and Pathways Policy Requirements:

OPM has replaced MOUs with a requirement for agencies to have a Pathways Policy (§ 362.104) to utilize Pathways authorities. This policy outlines agency-specific program parameters, similar to the former MOU. Agencies must make their Pathways policies available to OPM, applicants, employees, and stakeholders upon request.

Continued Use of Existing MOUs:

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

Information to Include in Agency Pathways Policy:

Agency Pathways Policies must reflect requirements in 5 CFR 362.104, including:

Agency-specific program labels (following federal naming conventions, e.g., “OPM Internship Program”).
Delegations of authority for Pathways Programs use (department-wide vs. bureau/component level).
Implementing policies or guidance for program administration.
Description of formal training/development and assignment types/durations.
Agency commitment to:
- Provide OPM with requested Pathways Programs information.
- Adhere to OPM-imposed program caps.
- Provide information to OPM about Pathways opportunities (including PMF postings).
- Establish meaningful onboarding processes.
- Align Pathways usage with workforce and recruiting plans.
Criteria/procedures for agency-approved recent graduate/PMF extensions (up to 120 days), limited to circumstances making regulatory compliance impracticable.
Criteria/procedures for determining resource availability for Pathways participant conversion to term/permanent positions, including a timeline for informing participants (no later than 60 days prior to appointment end).
Minimum service hour requirements for intern conversion (§ 362.204).
Program length for Recent Graduate Programs (justification required for programs longer than one year).
Agency Pathways Programs Officer (PPO) and Presidential Management Fellows (PMF) Coordinator contact information.

Establishing Longer Recent Graduate Programs:

The Recent Graduates Program is intended as a one-year entry-level developmental experience. Agencies may establish programs longer than one year if position-specific training needs warrant it. Longer programs must be justified in the agency’s Pathways Policy and participant agreements. Individual managers cannot unilaterally extend program durations.

Presidential Management Fellows (PMF) Program: Specifics

The PMF Program has unique aspects within the broader Pathways framework.

Developmental Assignments Outside Federal Government for PMFs:

No, PMFs must complete developmental assignments within their organization, agency, another federal agency (5 U.S.C. 105), or a participating Legislative Branch agency. Optional rotations outside their agency may be permitted according to agency policy.

PMF Finalist Appointment Eligibility Period:

PMF finalists have 12 months from their official selection date to accept and begin a PMF appointment. Extensions may be granted in limited circumstances (e.g., background investigation delays).

Career Ladder Positions for PMFs:

Yes, PMFs can be appointed to positions with established career ladders if the PMF appointment opportunity stated the career ladder potential.

ERB Certification Deadline for PMF Program Completion:

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

Online Training as “Formal Interactive Training” for PMFs:

Yes, online training can qualify as “formal interactive training” for PMFs if it aligns with their IDP competencies and prepares them for their target position. Interactive training includes communication between instructors and students. The agency ERB ultimately determines if training requirements are met. Agencies may clarify training definitions in their Pathways Policies.

Agency-Wide Initiatives as Developmental Assignments for PMFs:

Yes, PMFs can participate in agency-wide, Presidential, or Administration initiatives to fulfill the 4-to-6-month developmental assignment requirement (5 CFR 362.405(b)(4)(i)). Such experiences must be 4-6 months in duration (can be non-consecutive).

Waivers for PMF Training Requirements Due to Budget Constraints:

No, OPM will not grant waivers or extensions for yearly PMF training requirements due to budget constraints. Agencies must provide at least 80 hours of formal interactive training per year and a 4-to-6-month developmental assignment. The PMF Program Office offers training opportunities that can contribute to these requirements. ERB certification ensures training completion.

Participation in PMF Program by Excepted Service Agencies and Non-Executive Branch Agencies:

Yes, agencies whose positions are excepted by statute or non-Executive Branch agencies (e.g., FBI, Library of Congress) can participate in the PMF Program by entering into a Memorandum of Agreement (MOA) with OPM. Upon MOA approval, these agencies can appoint fellows, but conversion is to excepted service positions only. Participating agencies must also have PMF Program policies.

Part-Time Work Schedules for PMFs:

Agencies may approve part-time work schedules for PMFs for limited periods (up to 6 months) upon fellow request. PMFs on part-time schedules must still meet all program requirements within the 2-year program (or extended period) and adjust training/development activities accordingly.

Agency Obligation to Approve Part-Time Work Schedules for PMFs:

No, agencies are generally not required to approve part-time work schedule requests from PMFs.

Considerations for Part-Time Work Schedules for PMFs:

PMFs and agencies should consider how part-time schedules might impact the fellow’s ability to meet program requirements and qualification requirements for promotions within the program timeframe.

Timeline for Informing PMFs About Non-Conversion:

Agencies must inform PMFs about non-conversion decisions no later than 60 calendar days before the end of their appointment or any approved extension. OPM encourages agencies to make conversion determinations and inform PMFs as early as possible. Agency Pathways Policies should include procedures and criteria for conversion decisions and communication timelines. OPM encourages agencies to indicate a conversion decision timeframe in the Pathways Participant Agreement.

PMF Conversion to a Different Agency:

Yes, PMFs meeting conversion requirements can be converted to term or permanent positions in a different agency if their initial agency cannot convert them. Reasons for inter-agency conversion can include budgetary issues, reorganizations, position abolishment, cohort program completion, or other valid reasons.

Extending PMF Appointments for Inter-Agency Conversion:

Yes, agencies may extend PMF appointments for up to 120 days to allow time for conversion to a different agency. Extensions beyond 120 days are not permitted.

Career Ladder Positions in Different Agencies for PMFs:

Yes, PMFs converted to a different agency can be placed in positions with career ladders. The career ladder of the new position must be equivalent to or lower than the position they would have been converted to at their original agency.

Reduction in Force (RIF) Rules and PMFs:

No, RIF rules do not apply to PMFs separated upon appointment expiration.

OPM Authority to Waive PMF Requirements:

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

Questions and Contact Information

For agency headquarters-level HR 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 HR office. Applicants with questions about specific opportunities should use the contact information provided in the job opportunity announcement.