The Internship Program

[Donavan Rajawi]

Ifyou are a student or recent graduate seeking federal career opportunities through the Pathways Programs, please visit USAJOBS and Presidential Management Fellows (PMF) Program as the below guidance is for human resources practitioners. The Pathways Regulations published on April 12, 2024, will not be effective until June 11, 2024. Agencies may begin using the new provisions of the rule at that time, provided they have updated their policies and procedures to reflect the changes in the final rule. In the meantime, the existing Pathways Programs requirements and guidance are in effect.

The initial Pathways regulations were issued in 2012. In the decade since, new generations have entered the workforce with different skillsets and interests, hiring and educational trends have changed, and agencies have learned more about how the programs can better support their talent needs.

To modify the regulations, OPM issued a Notice of Proposed Rulemaking on August 16, 2023, to invite the public to comment on proposed updates. The comment period ended on October 2, 2023, and OPM considered this public feedback while revising the draft. OPM is now releasing the final rule, which contains requirements and procedures for agencies that hire early career talent through the Pathways Programs.

Agencies may begin using the new provisions of this rule on June 11, 2024 (the effective date of the final rule) provided that they have updated their policies and procedures to reflect the changes in the final rule. Some agencies may require more time to implement the changes and have until December 9, 2024, to be in full compliance with the final rule. This means some agencies may begin using the new provisions sooner than others.

The Pathways Programs framework consists of three separate programs that give students and recent graduates access to federal internships and potential federal careers through Schedule D excepted service appointments:

An agency may accept a transcript (official or unofficial), a copy of the diploma, or other written documentation from the educational institution or career or technical education program (such as a letter confirming enrollment or acceptance into a qualifying educational program).

An agency may accept a transcript (official or unofficial), a copy of the diploma, or other written documentation from the educational institution or career and technical education program. The documentation must be sufficient to allow the agency to determine that the eligibility criteria in 5 CFR 362.302 has been met. Such information includes but is not limited to:

No. Students who have not completed their educational degree requirements or career and technical education programs may apply and be considered for a Recent Graduates job in the weeks/months prior to the job being filled. These individuals must, however, meet the definition of a recent graduate in 5 CFR 362.302 prior to appointment.

It depends. There is no overarching requirement that applicants for positions in the excepted service be U.S. citizens. Many agencies, however, are restricted from paying non-citizens by their annual appropriations legislation or other agency-specific enabling statutes. Each agency will need to consider whether any such restrictions apply to it, in conjunction with its agency counsel. Moreover, an agency may appoint a non-citizen to a Pathways Program position only if the student or recent graduate is lawfully admitted to the United States as a permanent resident or is otherwise authorized to be employed. A Pathways intern, recent graduate, or fellow must possess full U.S. citizenship by the end of the Program to be eligible for consideration for non-competitive conversion to permanent Federal employment in the competitive service.

No. Agencies must provide public notification (as described above) when recruiting and accepting applications for Pathways internship or recent graduate positions. Additionally, the agency must post an adequate alternative method of applying for candidates who do not attend the career fair or other event.

What options does an agency have to manage its Pathways job announcement to avoid situations where the response to the USAJOBS announcement is an unmanageably high number of applications?

An agency's procedures for receiving applications (see 5 CFR 302.201) must address the use of these options. Additionally, when one or more of limitations are used the agency must state the limitation in the Pathways job opportunity announcements. Agencies must consider the merit systems principles when posting notices and consider whether the notice and time allowed will provide for a fair and open competition that assures that potential applicants for the position will receive fair and equitable treatment. Consultation with agency counsel is always desirable.

A USAJOBS custom posting is a USAJOBS announcement that may only be accessed using a unique link or URL. The job posting is stored in USAJOBS but is not searchable on USAJOBS. If the Apply Online option is enabled on the custom job posting, the applicant can see their application status in USAJOBS, and the agency also receives post-audit applicant flow data to inform hiring trends.

OPM encourages agencies to post Pathways job announcements using a standard USAJOBS posting for all student and recent graduate jobseekers to see. However, if the hiring agency does not want to use a traditional USAJOBS announcement for the Pathways job announcements, OPM permits agencies to use a custom job posting, and the hiring agency can receive applicant flow data as with a traditional USAJOBS announcement.

The custom job posting is created in the Talent Acquisition System (TAS). Once the posting is created, the HR specialist receives a unique URL that can be shared on social media platforms, agency career sites, or third-party job boards.

As part of a broad overall recruitment plan, agencies may conduct strategic recruitment activities to enhance the diversity and size of the applicant pool. Agencies should ensure that such activities are one part of an overall recruitment plan, and that public notice of the opportunities is available to everyone.

To the extent practicable, agencies should conduct outreach events to make students and recent graduates aware of the USAJOBS website, the Federal Internship Portal ( ), and the Recent Graduate Portal ( ) and encourage them to apply for positions when they become available.

When conducting on-campus recruitment, agencies should consider the proximity of the campus to the actual location of the job to be filled. The commute must be feasible for students to benefit from the event.

In accordance with 5 U.S.C. 3312 and 5 CFR 339.102(c) and 332.406, the following special provisions apply to medically disqualifying a disabled veteran with a compensable service-connected disability of 30 percent or more, based on inability to perform the physical requirements of the position:

In accordance with 5 U.S.C. 3318 and 5 CFR 332.406, the following special provisions apply to passing over a disabled veteran with a compensable service-connected disability of 30 percent or more, for nonmedical reasons:

Can an agency use the Schedule A hiring authority for People with Intellectual Disabilities, Severe Physical Disabilities, and Psychiatric Disabilities to appoint a person with a disability to a position in the Pathways Program?

No. The Schedule A hiring authority cannot be used to fill Pathways Programs positions. The Pathways Programs hiring authority is Schedule D. The Pathways Programs and the Schedule A authority for persons with disabilities are two separate hiring authorities with separate eligibility requirements and hiring processes. An applicant with a disability may apply to positions in the Pathways Programs by following the instructions found in the job opportunity announcement on USAJOBS (external link). When doing so, students with disabilities are considered for Pathways Programs positions in the same manner as other, non-disabled students in accordance with the provisions of 5 CFR part 302. An agency is, of course, required to provide reasonable accommodations, as required by law, and may wish to consult with counsel or its human resources office concerning such matters.

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

The Pathways regulations require recent graduates to meet OPM Qualification Standards. Does this mean agency-specific qualification standards may not be used for the Recent Graduates Program?

Yes. Agencies may not develop their own qualification standards for positions filled through the Pathways Recent Graduates Program. Agencies must use the OPM or OPM-approved qualification standards for the position being filled (or any qualification standards for the position required by law, if applicable).

No. Agencies may establish agency-specific qualification requirements, or use the OPM qualification requirements for the competitive service in place of the Group Coverage Qualification Standard for Schedule D, Pathway Internship Positions. (See 5 CFR 362.303(d))

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