1. Purpose
This Order issues and transmits General Services Administration (GSA) policy governing the use of the Pathways Programs to include the appointment and employment of individuals under the three Pathways Programs (i.e., Intern Program, Recent Graduates Program and Presidential Management Fellows (PMF) Program). It authorizes GSA to make appointments under Schedule D in the excepted service to any Pathways Program, and provides guidance establishing GSA’s plan for recruitment, selection, appointment, and employment in the Pathways Programs in accordance with Title 5, United States Code (USC), Sections 3302 and 2301(b)(1), and the Code of Federal Regulations, 5 CFR Parts 213, 302, and 362. It also defines requirements for non-competitive conversion to the competitive service upon successful completion of the Pathways Programs.
2. Background
The Pathways Programs are part of the overall hiring reform through which the Federal Government seeks to streamline and improve the Federal hiring process, and specifically enable the Federal Government to compete effectively for students and recent graduates. The initial Pathways Program regulations were issued following the Executive Order (EO) 13562, Recruiting and Hiring Students and Recent Graduates, signed by President Barack Obama on December 27, 2010, creating the Pathways Programs as a solution to undo the “complexity of the rules governing admission to the career civil service” which “creates a barrier to recruiting and hiring students and recent graduates.” In the decade since then, new generations have entered the workforce with different skill sets and interests, hiring and educational trends have changed, and agencies have learned more about how the program could improve to best support their talent needs. In response to the evolving workforce the Office of Personnel Management (OPM) has updated the regulations to better enable the Federal government to compete with other sectors for early career talent.
3. Scope and Applicability
This order applies to all GSA Human Resources practitioners and the GSA workforce involved in the hiring and employment of all Pathways Programs’ Intern, Recent Graduate, and PMF appointments under Schedule D, 5 CFR 213.3402(a), (b), and (c).
a. The Office of Inspector General (OIG) has independent personnel authority. See Section 6 of the Inspector General Act of 1978, (5 U.S.C. App.3), as amended (Inspector General is authorized “to select, appoint, and employ such officers and employees as may be necessary for carrying out the functions, powers, and duties of the Office of Inspector General”) and GSA Order ADM 5450.39D CHGE 1 GSA Delegations of Authority Manual (Delegations Manual), Chapter 2, Part 1 (“the Inspector General has independent authority to formulate policies and make determinations concerning human capital issues within the [OIG]” and GSA determinations/delegations do not limit that authority). Similarly, GSA specifically recognizes that the Inspector General has independent authority to formulate policies and make determinations concerning training, employee development, and career management.
b. This Order only applies to the Civilian Board of Contract Appeals (CBCA) only to the extent that the CBCA determines it is consistent with the CBCA’s independent authority under the Contract Disputes Act and it does not conflict with other CBCA policies or the CBCA’s mission.
4. Cancellation
This Order cancels and supersedes HRM 9362.1, GSA’s Pathways Programs, dated September 9, 2016.
5. Nature of Revisions
The provisions of this policy are updated to include OPM’s changes to the regulations for the Pathways Programs. The following subjects have been adjusted:
a. Revised definitions for key terms like “advanced degree” and “qualifying career or technical education program” clarify program entry requirements (5 CFR 362.102).
b. Replaced OPM’s memorandum of understanding (MOU) requirement with the requirement of agency Pathways policy (5 CFR 362.104).
c. Modified public notice requirement for vacancy announcements for Pathways Interns and Recent Graduates, as mandated in 5 CFR 362.203 and 5 CFR 362.303.
d. Increased conversion period to 180 days for graduating interns as reflected in 5 CFR 362.204.
e. Reduced intern work experience requirements to 480 hours, with the waiver provision adjusted to allow for only 160 hours, ensuring a minimum of 320 hours are completed as outlined in 5 CFR 362.204.
f. Increased potential initial appointment starting salary of Recent Graduates to up to GS-11 level as outlined 5 CFR 362.303(b).
g. Updated organizational flexibility and identified criteria in determining the duration of the Recent Graduate Program, within limitations defined in 5 CFR 362.301.
h. Adjustments for the Recent Graduate Extended Training Programs related to oversight, announcement notification and trial period.
i. Conversion to permanent or term positions at a different federal agency is allowed under specific conditions for both Recent Graduates (5 CFR 362.305) and Presidential Management Fellows (5 CFR 362.409).
k. Part-time work schedules are authorized for Presidential Management Fellows under certain circumstances, as per 5 CFR 362.404(e).
l. Specific requirements are outlined for Individual Development Plans, developmental assignments, mentors and certification for Presidential Management Fellows, detailed in 5 CFR 362.405.
6. Implementation Action
Implementation under this issuance must be carried out in accordance with applicable laws, regulations, and bargaining agreements followed within GSA.
U.S. General Services Administration