November 22, 2019
  • 2:52 pm Gregg Semenza 2019 Nobel Prize Winner | Press Conference
  • 12:51 pm Pompeo on Ukraine conversation: I was on the phone call
  • 11:08 am Telephone Call: formal
  • 11:08 am Telephone Call With Relatives | MostlySane
  • 11:07 am President Trump holds rally in Orlando, Florida, live stream


Gail:  We’ll do a brief overview of the Pathways
programs themselves. I’m sure you’re all fairly familiar with them. We’ll discuss implementation
a little bit, because we are now in full implementation in Pathways. We will discuss some of the issues
of the impact that Pathways has on your recruitment efforts for students and recent grads, some
solutions, maybe, to some of the problems that you experience under Pathways. We’ll
also discuss Pathways and how it interacts with 5 CFR 302, which are the procedures when
filling any excepted service position in the federal government. Then, if we have time,
we’ll take questions, and as I said, you can stop me as we go along and ask questions.
We’re going to do a little more global look when we review the programs, because there
are a lot of similarities between the programs, and they have kind of a progression to them
that we want you to be able to see. Once you get one down, you’ve kind of got the others
down. We will focus largely on the internship program and the recent graduates program today,
because OPM essentially manages the PMF. The internship program. When I hire an intern,
that appointment is generally tied to the length of the education program that that
individual is pursuing. We also have a provision under the internship program that allows you
to hire intern and intern not to exceed. The intern not to exceed was designed to give
agencies the flexibility to still hire summer students, summer hire, to help get you through
the summer when you have a lot of employees on annual leave, things like that, Christmastime,
whatever, project work. The intern not to exceed has a different purpose than the intern
itself. They’re similar, but, really, they have two different purposes.
Interns, you can hire them on a full or a part time basis. The recent graduate program
is designed as a one year program. Agencies can request programs that exceed one year,
but they have to provide justification for a longer program and OPM approves that, and
that’s all done through the MOU process. The PMF program is a two year program.
Who are these programs for? They’re for only current students and recent graduates. The
education to qualify as a student or as a recent grad, that education had to have been
obtained from a qualifying educational institution, as defined in the regs, and it can be high
school, college degrees, vocational, technical schools, certificate programs, et cetera.
Certificate programs. How many people have issues with certificate programs? OK, good.
At least a couple. Unlike the previous regs, certificate program
is clearly defined under Pathways. I’m not going to read it to you verbatim, but it has
to be a bona fide program that’s equal to an academic year of full time study, et cetera,
et cetera. OK? It also has to be in a qualifying educational institution.
I have a question in the back. Kermit Howard:  This is Kermit Howard again.
Going back to one of the key slides, where it talked about recent graduates and that
OPM approves longer programs, could you briefly describe what are the criteria for approval
of these programs? Gail:  Kermit asked, what are the criteria
for approval of a longer program? There is no black and white criteria. Generally speaking,
we haven’t had too many. At least that’s my recollection
the agency just makes their case. They provide
the [inaudible 0:04:55] as long as you have something that makes sense in there, and has
good reason. Kermit:  Thank you. [silence]
Gail:  I’m sorry. We’re having some difficulties. [silence]
Gail:  OK. Better? Generally they are tied to educate and training requirements. Because
it’s a more complicated career field, some didn’t like that. If you’re asking me if OPM
as a list of specific criteria that must be met, no we do not.
Kermit:  Thank you. Gail:  Yes sir. I’m sorry. We have another
question. [silence] Audience Member:  We had a request come in
for individual certificate programs that consist of 18 hours in total. We assume that [inaudible
0:06:32] . Even still, if it’s graduate, it would be even different hours. Most of the
graduate programs that we come across, I would say nine hours would be considered full time.
It just depends on the program. AP could, if it was graduate, AP, might be able to try,
but if it’s undergraduate, of course, it’s going to be four.
Gail:  That’s what I would say too. You have to look within the parameters of what is the
acceptable norm in the educational community. You have that flexibility, we’re not going
to dictate. Maybe you look at what the requirement is at that particular school that the applicant
is going to, etc., and you come out with that. To find this, we’ve tried to help narrow it
down, was largely by request, when we were drafting Pathways, so that HR, so that they’d
have something more definitive when trying to explain to a manager why a two week certificate
course isn’t qualifying to get a student appointment. You do have some flexibility in there.
Who’s eligible? For interns, we have current students, and they can still be in high school.
They can be in college. They can be doing some kind of vocational, or technical curriculum,
and they have to be at least a half time…this was my boo boo. It’s just they have time to
do this as defined by that particular educational institution that they’re attending. Because
different schools define half time differently. Just everything is going to give me trouble
this afternoon. The Pathways Program, they have a little bit
of an escalation to them. When it comes to eligibility for the recent grads, high school
drops off. So you can’t hire a high school student as a recent grad, but you can still
hire college graduates from either an undergraduate or graduate program.
They have to apply within two years of the announcement, and that two year time period
is extended for certain veterans. They get two full years of eligibility upon separation
or release from their active service, but under no circumstance can it exceed six years
from the date they graduated. Audience Member:  You’re talking about undergraduate,
graduate. Where does the associate’s degree fall into this mix?
Gail:  OK, I just didn’t put it on there. It would be the same thing. An associate’s
degree would qualify as a recent grad if that’s… Audience Member:  OK.
Gail:  The question was associate’s degree isn’t on here, and it should be. It’s included.
Audience Member:  Thank you. Gail:  PMFs, once again, some of the education
drops off. The associate’s, the graduate degrees, they drop off. PMFs, only advanced degree
graduates are eligible for the PMF program. We maintain the provision that allows individuals
who will complete their advanced, the educational requirements for the advanced degree by August
31st of the year we’re doing the announcements. So, for example, right now we’re in 2013 cycle,
right, or the class of 2013 so individuals who will complete by August of this year were
permitted to apply to this year’s PMF’s announcement. Quals you need to remember that there are
eligibility criteria and then there are qualification requirements for the positions you’re filling
under Pathways. So for interns agencies have the option. They can develop agency specific
qualification standards for their interns or they can use OPM Quals.
We are currently working on Quals for the interns. They’re not quite final yet. We hope
they will be out shortly, whatever shortly is. So you have some options there when you’re
filling your intern positions. When it comes to your recent grads and PMFs, however, they
must follow OPM Qualification Standards. So under the recent graduates program if you’re
filling…I don’t know. Give me something. If you’re filling a 201 I always use that
because it’s the one I can always remember if you’re filling a 2017 they’ve got to meet
the OPM Quals for the 201 series, OK? Yes, we have another question.
Audience Member:  Are we still considering work experience?
Gail:  For? Audience Member:  As part of the qualification
process? It wasn’t completely clear to me. Before we used to be able to count certain
types of work in addition to education. Are we still able to…?
Gail:  You mean for recent grads? Audience Member:  For interns.
Gail:  OK, interns. You can always consider that if you establish your own qualification
standards for the interns then those standards would have to provide for that provision to
combine education and experience. For the recent graduates program, the recent graduate…you
need to keep in mind the reason the recent graduates or justification for the recent
graduates program was because these individuals have no work experience. Because of their
lack of work experience they cannot successfully compete against individuals who do have work
experience. Now that doesn’t preclude a recent grad from…with experience from applying,
OK, and using it, but when you’re doing this for your recent graduates program, you need
to keep that in mind. OK? Audience Member:  My question is and this
is pretty much the cusp of what…why we’re here anyway. And I’m not an HR person so I’ll
just tell you that right up front. I’m the Director for the Department of the Army Logistics
Intern program, and we go about 100 people a year that we hire. Now, the OPM qualification
for recent graduates, very familiar with that. However, we have always in the past…our
qualifications have always been much higher, much more demanding, because we have shown
that the way we hire with our qualifications the return on investment has been 15 years
or more of government service so it’s actually done quite well.
However, the OPM Qualifications now with the recent graduates has lowered those qualifications
considerably. Is there any way that…is there any avenue that we have or any recourse that
we have to request a waiver for specific programs which has identified the past return on investment
quite much larger than most organizations have to get them into the specific program
such as the one that we run? It’s a 346 series, and it does not have an
educational requirement, positive educational requirement, because, as you know, that would
have to be for army wide, and everybody gets hired into that series. So I understand why
we can’t specifically request it just for the program.
I guess that’s why we’re here, because we’re hiring a lot of folks that, well, they meet
the minimum qualifications that OPM sets. We have to, you know. And we’re just trying
to figure out how we can get to the point where we can get back to where we were so
we can get the quality folks that we’ve been getting.
Gail:  So you’re talking about what you used to be able to do under the Federal Career
Intern program. Audience Member:  That is correct.
Gail:  OK. So APSIP is gone. So did everybody hear what he said? His agency is concerned
that OPM Quals are actually less than the quals that his agency used to use under the
old Federal Career Intern program. So we are going to get into that a little more a little
father into the briefing, things you can do. It is what it is so the short answer is, no,
there’s nothing to be done for that. The OPM Quals Standards apply.
Mike Mahoney:  Hello, my name is Mike Mahoney. I manage the hiring policy office at OPM.
You have to apply the government wide qualification standard, as Gail said, but that doesn’t preclude
you from getting highly qualified candidates in that. That might be borne out through the
selection method that you use and Gail’s going to talk about that in a little bit when she
talks about the 302 procedure. So I don’t want you to think that you are just left with
selecting minimally qualified people. Again, there’s a qualification standard but you can
still select highly qualified people depending on how you go about that, and she’ll get into
that in a few minutes. Audience Member:  We were hiring 50 people
and 80 people, great, but… Mike:  Well, but they meet the qualifications
for the job. Audience Member:  [off mic conversation]
Mike:  Right, because there are no more your qualifications. There aren’t any and if you
are filling the job through the recent graduate program, yeah.
Gail:  OK, so the training and development piece at Pathways also kind of escalates as
you go through the programs for IDPs are required for all Pathways program participants. An
exception would be the intern “not to exceed” who is hired for short time summer employment.
The recent grads in the PMF, you are required to provide interactive formal training 40
hours for the recent grads, 80 hours/year for the PMF. The recent grad and PMF also
has a mentor requirement. You must provide a mentor to these individuals. I believe it’s
45 days to 90 days within the time you appoint them.
Now, this doesn’t mean that you couldn’t provide your interns with that same mentor opportunity,
OK, or that you can’t provide your intern’s formal interactive training. In fact you should
have some kind of training and development plan for your interns. And of course the PMFs
also have a requirement for a developmental assignment during their two years.
Audience Member:  And one of my question with this slide, just so I follow you, there’s
a “not to exceed” intern but then there’s also an intern, the program tied to the length
of their education that’s specific in during…do they require an IDP as well?
Gail:  Yes. Audience Member:  OK, so everyone except
the short summer… Gail:  The short summer. You are going to
follow, I believe 430 as the performance management and all that kind of stuff. So even if you
hired that intern not to exceed for a year, what you know is they are employees. They
are federal employees and they are subject to all the provisions of the CFR just like
any other employee. So I believe that cut off is 90 days or less, no IDP. I just want
to call to your attention that OK, so for that true summer hire that you are only hiring
for the traditional month, no, you don’t have an IDP requirement. If you are using that
intern for something that not to exceed for something a little longer, or some kind of
special project or something, then you are probably going to need to fulfill that requirement.
Audience Member:  OK. Audience Member:  Yes, are you saying…
Mike:  No, not during the…ones that are not to exceed.
Gail:  There is no mentor. There is no regulatory requirement for a mentor for the internship
program. That kicks in it for the recent grads. Audience Member:  Thanks!
Gail:  But like I said, that doesn’t mean you can’t and then it’s a good idea. Remember,
the Pathways programs are designed…they are programs. It no longer works like it used
to where a manager could just decide to use his authority because he wanted to, OK? Similar
to like they don’t work like people with disabilities or the DRA or other accepted authority. This
is a program. These are programs that have a very specific purpose and the purpose of
the intern is to train that intern for the future so as to help with your workforce planning
and hopefully which will lead to conversion and to a permanent employment. Just like you
said that you had very good luck with the ASSET program. OK, all Pathways program’s
participants are potentially eligible for non competitive conversion to the competitive
service. You can convert them to a term or to a perm. If you convert to a term first,
you may subsequently non competitively convert them to a permanent competitive service appointment.
The potential for that conversion needs to be identified in your Pathways announcement
for the position and you must also identify that potential in the participant agreement
and provide that intern recent grad PMF or whatever the case maybe, you need to tell
them in the participant agreement what the expectations are for successful completion.
OK, one second, let me finish this slide, and then that non competitive conversion,
the Pathways participant that is non competitively converted to the competitive service must
meet the OPM qualification requirement of the positions that you are going to convert
them to. OK, so we have a couple of questions. Audience Member:  Yes, the question is you
say that potential must be identified in the vacancy announcement, so that’s potential
for conversion of the potential for the poor performance level on position.
Gail:  Well you should identify both but the potential for conversion should be identified
in the vacancy announcements. Audience Member:  OK, the follow up question
for that is this we are doing announcement, we’ve put it out there for an intern without
an NTE date. Poor performance level positions, they know upon conversion they’ll be going
to a career ladder position. When we are converting or when we get ready to convert individuals
who are traditionally on a NTE date but have met all the program requirements, the extensions
or probably via renewal of the NTE, whatever the case maybe, and they are being converted.
When they apply for that position, that position was built as a short term position probably
something little bit more clearer from not long term, now you are getting ready to convert
them. Can we start the same entitlement converting them to a career ladder position, provided
that we haven’t specified that upfront? Gail:  Well!
Audience Member:  And these are the questions I get.
Gail:  Yes, I know. I hate this question. Potentially yes, but really there is a requirement
to identify that potential in the announcement. So really you shouldn’t find yourself in that
situation for anybody that’s recruited and then appointed fully under Pathways. Where
you may find yourself in that situation is for individuals who were transitioned into
Pathways. But you are correct that potentially that intern not to exceed could be non competitively
converted to the competitive service. Now, like you said, keep in mind too that the ranks
are very specific about why you are supposed to hire; when and how and why you should hire
a not to exceed. So really you are not supposed to use the not to exceed when your intent
is an intern, OK? Pathways has a bunch of pieces that kind of
mess together, so you’ve got to look at the whole picture. So did you hire that person
for the right reason. See what I am saying, but yes, you are correct they are potentially
eligible for non competitive conversion and that would be your agency’s decision, according
to your agency policy. Now remember, when I started I said you guys
need to keep in mind that it’s your executive agency interior treasury, defense etc. they
are the ones who establish the policy. So you have, just because I say that it could
potentially happen according to our regs, doesn’t mean that your agency will allow it.
So you have to look to that as well. I get beaten up every once in a while for
answering you guys when the executive agency is saying something else. So please do keep
that in mind. Audience Member:  I have a question about
the term. If the term, time period is like 2 or 4 years or…
Gail:  A term appointment in the competitive service is any appointment that exceeds one
year and does not exceed four. Audience Member:  [off mic conversation]
Gail:  Is that working now, because I’d really like to put it…no, you don’t. Just that
the potential is there. Audience Member:  [off mic conversation]
Gail:  Oh I am sorry. His question was, do you have to put on the vacancy announcement
that the conversion would be to term or to perm. No, you just have to identify that the
potential is there to be converted to the competitive service.
Mike:  Yeah, I just want to add to that that the real intent is that you are bringing these
people in with the intention of converting them into your permanent workforce, OK? We
allow for the conversion to the term appointment and if it’s a safe landing place, if you will,
if for whatever reason, budgetary reasons, there isn’t a permanent slot available to
them, OK, the government’s invested a certain amount of resources in these folks and we
want these folks to be good ambassadors of the program, so if there’s not a slot, we
allow agencies to put them in a term job until a slot opens and then non competitively converting
from that. But you shouldn’t be putting announcements out that say you’ll be put into a term job
when you finish your academic requirements. The real destination is into the permanent
workforce. Audience Member:  Sorry, one more question
about, when you announce and you are trying to announce a position that’s not a not to
exceed, not a short part but for the period of their schooling, do you announce that as
a temporary…you just announce it? Gail:  The question is, if I am hiring an
intern, how do I announce the position? You announce it as an intern, OK? Because even
though, it’s just like the former SCAPs or like the FSPP used to be. They do not have
a not to exceed date on their appointment, OK? And if it takes some five years to complete
their education you can keep them on that intern for appointment for five years. So
you wouldn’t announce it with a time limit unless you were actually looking for an intern
not to exceed a short term need. Audience Member:  So this happened with us.
We announced during kind of interim phase, and I guess I am hoping, are we misleading
applicants by saying, we want you for your full period of education, there may be a chance
to convert you but we can’t guarantee that. I just want to make sure they are aware that
the job may not be permanent? Gail:  But you are still hiring the intern,
right. So conversion is possible, it is not guaranteed. And given today’s environment,
there is probably more and more chance that we wouldn’t be able to know even to the extent
we know today what we might or might not be able to convert to permanent. But you must
notify them of the possibility of conversion. And at the end of the day they’ve still gained
the experience. They’ve been paid etc, etc. So because that’s how the program operates,
so you don’t have to worry about misleading them.
Audience Member:  Right. Gail:  We are OK this? Sweet. You guys are
way calmer than the morning session. Must be you all had a really good lunch, right.
Is that it? OK, so now we are at Full Implementation of Pathways, right. What that means for you
is that unless your agency has a signed MOU with OPM, you may not use any Pathways program.
Period, end of story. You know you can’t use it unless your agency has an MOU. We understand
that there are some agencies that have some individuals that were recruited for under
the old student authority that have not been brought on board. Some agency. I see some
people going what? Well, some agencies really they forecast their
recruitment out a year or more for students, OK. Some of those students that they hired
and gave tentative offers to before Pathways or during the transition period have not yet
been appointed. If your agency has any of those individuals they may not be appointed
under Pathways, your agency is going to have to start the recruitment all over again using
the public notice requirements of Pathways. We provided the transition period for Pathways
and that was largely to give agencies some time to get existing STEPs, SCEPs, PMFs transitioned
under the Pathways authorities. Some agencies have discovered that some of them fell through
the crack and they weren’t transitioned, under Pathways they weren’t converted to the Pathways
during the transition period. If you discover you have any individuals like that similarly
situated, please contact us and we’ll help you work through how to get them under the
Pathways authority. OK. So now we are full implementation, like
I said you have to have approved agency MOU employees to be able to use Pathways and these
are the things that the agency MOU covers. It identifies what programs that your agency
is going to use, not all agencies have opted to use all three Pathways programs. It also
provides delegations of authority. So like I said, if you are not the executive
agency, if you are not DOD and maybe you are Air Force, then you need to look to DOD’s
policy to see what kind of authority Air Force has been give to establish any of its own
policy, OK. It also identifies the Pathways Program Officer
for your agency. It certifies that your agency has policies and procedures in place to run
the Pathways programs. It certifies that you are going to use public notification which
for Pathways largely is defined as a USA jobs vacancy announcement and that would be any
Pathways opportunity that your agency is offering. And then it also certifies that you are going
to follow the procedures of 5 CFR 302 for the accepted service and the veteran’s preference
provisions that are also included in that part of the CFR.
OK. So I kind of see a little bit of what you thought the single biggest thing was,
but so now that we have been through some of the stuff, any other things that you can
think of. So we said vacancy announcements, and it takes a longer ride and quals are an
issue for some of you, any other things that you’ve discovered that Pathways is impacting.
Audience Member:  I guess the impact is the interpretation at least for us and others
I talked to in the Pathways community on what is deemed public notification, especially
in the areas of recruitment fairs, job fairs, career fairs and those kinds of things. Any
clarity that can be provided on that would be greatly appreciated.
Gail:  We are going to discuss that for sure. Mike:  I think our biggest impact is we are
actually being prevented from reaching the best and the brightest to come in to the Federal
Government and I believe that’s hard thing to swallow and hard for me to say, but it’s
a fact, it’s just a fact. Gail:  I get it. I do. I don’t know what
to tell you about that. That’s preferences above all. So it’s here to stay. But there
are some things, maybe like Mike was saying before, maybe there are some things that you
haven’t thought of. So like, traditionally did you….
Mike:  I was just to that point. I was just going to say though, we now have the public
notification requirement, we didn’t in the past. So we are going to be identifying a
lot more people that now know about these opportunities. So to say that we are not getting
the best and the brightest, how do we know we are getting the best and the brightest
when in the old days we weren’t even putting a job announcement out, OK. One of the reasons
behind Pathways was to be transparent. We wanted students and recent graduates to know
where these opportunities were in the government so that the best and the brightest could apply
and be given consideration. There is a couple of ways of looking at that. I just wanted
to add that point. Gail:  OK, so like we discussed, there are
not just appointing authorities that you just get to say, give me Gail Perryman because
I want her, OK. And these are more structured programs for workforce planning. You have
a projection. Your agency has to project numbers for how much they will fill under each program
under the Pathways recent grads. Then they actually have to report actual usage, OPM
under the regulations we have authority to establish limits and caps on the hiring of
students and recent grads if it starts to go the way of other program. All these things
impact, right. And then on top of that now you have to deal with your executive agency
policy which before under the old student programs you didn’t necessarily have to worry
about, right. It was kind of like this flexible authority that was there for you to use and
you just had to do what the reg says. Now, this other layer has been added on top
for your executive agency policy. The public notice, the perception that veterans’ preference
did not apply under the old student programs. It did. We have strengthened it and it was
done on purpose, for lack of a better word. OK, let me finish. And there is also some
restricted movement, right. So now we have some questions and comments. So we’ll stop
here. Audience Member:  [inaudible 0:40:18] the
DA Logistics Intern program. Don’t get me wrong, I have no grievance with veterans’
preference. I think preference is a wonderful thing absolutely. It’s just that with the
qualifications that OPM has set, it actually lowered the bar of some programs where the
qualifications were higher. Gail:  He says he still feels that the OPM
qualification requirements for recent grads are lower than what they established in Army.
So the qualifications we use to fill recent grads are the same quals we used to fill any
competitive service position. If you were filling it through an open competitive examination
you will use those same OPM quals. Audience Member:  Well, right. I just want
to make sure, it’s perfectly clear, I have nothing against veterans’ preference. So I
am all for that. But when I have to a vet who doesn’t have a certificate, no education,
or anything else…. Gail:  So we’ll get to some of those issues.
Audience Member:  But then I [indecipherable 0:41:28] 4.0 graduate.
Gail:  Well, you cannot use grade point average as a qualification requirement. You can use
it as an eligibility requirement for your program or to stay in your program. But you
cannot qualify an individual based on GPA. You can’t do it. OK. We got some anomalies
in our system. Are there any other questions before I move on.
Audience Member:  On question, it’s just picking on what he is talking about. One of
the limiting factors that I’ve heard from managers is you take a GS4 for example, and
the way the quals are, it’s almost like you are putting these interns into clerical type,
you [indecipherable 0:42:24] it in terms of what you can classify their duties to be.
They want to be able to give them more substantive work. But then if they are restricted to a
four, in terms of budget, they feel like they don’t….
Gail:  OK. We can’t help you if you are restricting your grade levels due to budget. OK. So if
you are doing that, then there is nothing to be done with that but I would disagree
that just because it is an intern does not mean that that PD cannot have any substance
or that the assessment tool that you use to decide to…and we are going to get to this
in more detail but, just because it’s an intern and the person is a student, it doesn’t mean
you just have to give them menial tasks, OK. But if you are limited by budget, that’s a
whole different ballgame. Audience Member:  I am new to this training.
And my question is what does MOU stands for. Gail:  Oh, I am sorry. It’s a memorandum
of understanding between the executive agency, treasury, interior, department of defence,
commerce and OPM. So it’s an agreement, OK. It’s kind of like we say there are certain
things we are going to do for you. You say there are certain things you are going to
do, that you are going to abide by and play in the sandbox, like you are supposed to,
for lack of better way, OK. OK, solutions, I am just going to skip right past this one
and go to this one, OK. So we’ve heard how you all feel about some of the impacts of
Pathways, so whether some of the things that we can do to help mitigate those that impact
that you are feeling. And how many hiring managers are in here? Oh, you are the lone
ranger…oh another one. OK, so there are a couple of you. You know,
for my money won’t get you a cup of coffee but the hiring manager probably has a biggest
adjustment of anybody because you used to be able to decide what you wanted to do if
you wanted to use one, the student authority, and you could pretty much handpick who you
wanted etc, etc. You can’t do that anymore. So it’s a huge
shift in what you’ve been able to do and then when you take that and you factor in that
you also have to worry about what your agency is saying about your limits, how your piece
falls into that etc. It starts to become a challenge.
But some of the things that we can do is we could issue our intern or our recent grad
announcements we could issue them for a shorter period of time. Correct, if we typically announce
them for 30 days, and if you are getting like a lot and lot of applications on a 30 day
announcement, maybe you want to cut that back to a week or two weeks.
You have that flexibility when you establish your policy. The other thing you could do
is you could limit the number applications with there we would follow the same procedures
that are in the delegated examining handbook for the competitive service. There are very
specific rules, you have to clearly identify in the vacancy announcement that you are only
accepting x number of applications or so
you are going to accept 100 applications. You do have some of those flexibilities, right.
We have targeted recruitment not necessarily targeted recruitment the way we used to know
with under the old programs but we do have some flexibilities there. You can cast a smaller
net, right. If you are looking to hire, individuals who are looking to hire, be more specific
about the types of education that are desired for this position.
Tell them the kind of competencies or skills or abilities that you are looking for. If
you tell me you are looking for somebody interested in rocket science and I may join in basket
weaving, if I not have to believe I’d apply for your rocket science position, OK. So there
are things we can do with our announcements and public notice is a big impact on you.
But there are things that we can do in those announcements that will help more clearly
identify what it is we are looking for. So your intern announcements should be way different
than your summer announcement, kind of like the cattle call for the…to help you get
through the summer, right. So, all of those things. Name requests, like I said, the manager
used to be able, if you knew that Gail Perryman was out there, you could just go to your HR
office, give them my resume and say here get her.
And you can’t do that now. You could still name request, but that individual has to apply
and has to get through the priorities and stuff for you to be able to legitimately reach
them. It’s no different really than how we operate on the competitive side, right. So
we have some questions and comments under this slide, so OK.
Audience Member:  Yes ma’am, can you tell me how targeted recruitment works on the Pathways?
Gail:  No, yeah. All right, so targeted recruitment. So before you used to be able to just go to
let’s say Georgetown, right. And you could go to Georgetown, you could go to a specific
college or university, and you could have your career fair and you could accept applications
and stuff like that. And then you could make job offers right on the spot, whether or not
technically you shouldn’t have done this, but you did, right. You can’t really do that
anymore. You could still target Georgetown, OK, but you would also have to include the
other colleges and universities that belong to the same area as Georgetown. So you can’t
just say Georgetown students only can apply, right. You used to be able to just go to Georgetown.
Now you got to put an announcement out. That announcement has to tell everybody that you
are going to be at Georgetown on such and such a day, etc, etc, OK.
Wherever you hold this targeted event, has to be open, other people have to be able to
get there, OK. And we also advise you to check with your general counselor, you might want
to consider providing opportunity for people who can’t attend that event to apply. Now,
if you choose not to, at the end of the day if it ends up before a third party, your agency
is defending your agency and its actions. Public notice has been defined for the competitive
service for a long, long time. It’s a new concept to the accepted service. The executive
order didn’t define it, so we’re trying to see how it really fits in here. Some of our
thinking has evolved. I can’t say that we changed our mind. Our thinking evolved, sometimes,
with some of this stuff as we see different things happening out there. You just have
to be careful. Now, there is a difference. Recruitment is
one thing, outreach is another. You can conduct your outreach wherever you want. If you only
want to go to Georgetown, go to Georgetown and beat the drum about the Department of
Army intern program and how this is typically when we gear up to hire.
OK, that’s different. You can’t just accept those applications and start making job offers
on the spot because you have veterans’ preference to deal with. You cannot limit by a geographic
area, just for the sake of a geographic area. I know it sounds like I’m talking out of both
sides of my mouth, but there is a difference. It’s a fine difference between targeting colleges
and universities in a particular area versus just limiting it to the Baltimore Metropolitan
Area. Do you see what I’m saying? Wait for the mike please.
Audience Member:  No problem. I just want to make sure I’m clear on this. You’re saying
that you can limit an area of consideration, as we have with other types of announcements,
to say the Baltimore Metropolitan Area? Gail:  No. I said…
Audience Member:  Go ahead. I want clarity. Gail:  His question was that I said you could
geographically limit, for example to Baltimore. No, I said just the opposite. You cannot limit
to Baltimore just because the Cora Engineers is located in Baltimore City. OK? Now, I don’t
know how many, but you could say any students attending any of the colleges and universities
in the Washington, Metropolitan, Baltimore, however you guys define it. You’re telling
all the college students, because remember you’re looking for college students. Think
of it in terms of what would you do if it was public notice that you had to put out
under delegated examining, you cannot limit, correct?
It must be all US citizens all the time. Kind of try and draw a parallel. You’re looking
for students. It’s usually our merit promotion type announcements where we’re looking for
current federal competitive service employees. That’s where you start to see geographic limitations
on the area consideration. Audience Member:  My question is internal.
If we’re going to do an announcement for an internal student with a not to exceed date
and this has come up recently. I have an intern with a not to exceed date, they want to extend
the appointment for another year, but somehow the student was say grade two. Manger says
successfully does grade two, they want to promote him to a three. Can we announce that,
of course, I know things have changed, everything has to be announced on USA Job, can I make
it specific to NPS only and how does the vet preference apply?
Gail:  The question was about if I have an intern not to exceed and they’re a grade two
and management wants to give the intern not to exceed a grade three, what’s the process?
How do I do that? Is that a fair restatement of your question?
Audience Member:  Correct, I know we have to announce it on USA Jobs, but might question
is can I limit it to NPS only? Gail:  OK. What you have to do in order to
do that, so, we have said that we believe it’s defensible when you have intern not to
exceeds and there’s a new opportunity. We believe it’s defensible that you can offer
that new opportunity only to your intern work force. Your intern not to exceed work force.
In that case, you don’t have to go on USA Jobs. That’s an internal. The other thing
is, is remember, too, that temporary employees the world around whether competitive or accepted
they cannot be promoted. The only way to get a temporary employee to a higher grade is
by a conversion to a new appointment at the higher grade level. We’ve said you can offer
that to your current agency interns first, that kind of announcement would be an exception
to USA Jobs. Correct, they don’t have to put that on USA Jobs.
However common it is a new appointment, so any of your agency interns that apply to that
opportunity it is an external action. You are going to treat it and apply preference,
etc. I may not get to promote Mike through that conversioned new appointment because
Karen may have also applied for that opportunity and she is a preference eligible and she’s
every bit as qualified as Mike. Audience Member:  Now, I have a follow up
to that. Is that in the FAQs in the Pathway or is that something that our agencies should
create? Because I have a manager that says they want this in writing. How would I provide
that to them? Gail:  OK. There is stuff, it was in the
implementation guidance. We also, did you receive the Maitresses? The maitresses also
demonstrated some of this, but once again, let me just ask you.
Audience Member:  Yes, ma’am. Gail:  What’s your agency?
Audience Member:  NPS. Gail:  What’s?
Audience Member:  National Park Service. Gail:  So, you’re not the executive agency?
Audience Member:  Oh, DOI. I apologize. Gail:  Right. And see your executive agency
is sitting right across the aisle from you there.
Audience Member:  That’s fine. Gail:  Interior.
Audience Member:  I have the matrix, but the matrix is not clear, so when you give
the matrix… Gail:  Whoa, whoa. OK. What I wanted to caveat,
I just gave you the answer, but that is the flexibility we have provided. You have to
look to interior. Do you see what I’m saying? Because maybe they don’t allow you to do that.
Maybe Interior has said there has been a couple of agencies who have said “all Pathways opportunities
will be posted on USA Jobs period.” If that’s the case and if they haven’t delegated to
your agency authority to do differently, then you can’t. OK? I need to keep emphasizing
that I’m giving an answer that is you’re allowed to do it within the regs, but are you allowed
to do it according to your agency policy? Are you OK? Do you understand?
Audience Member:  I’m OK. She has another question.
Audience Member:  I don’t have a question. I don’t need a mic.
Audience Member:  My agency, and I’m at Department of State, our agency for our Pathway interns
if they don’t have a not to exceed date they can be non competitively promoted. The ones
who have not to exceed dates, they have to apply in order to get a promotion. They’re
considered our ITAPs, which are our old STEPS. Then we have the ones that are IEPs now, that
were the old SKEPS they can be converted if the office has the FTE to convert them, if
not, then we either extend them or we terminate them… That’s how we’re doing our in our
ACN. Another thing is that all of our announcements are posted out of Charleston. Once they review
the application, issue a cert, the cert comes back to me. I give it to the managers. They
review the resumes, do interviews, or what have you. Then just provide selections back
to me, and then I send it back to Charleston. Gail:  Sounds like a simplified process.
Audience Member:  …to Charleston who then posts on USA. They post all of the announcements
and everything? Audience Member:  On USA Jobs? Yeah, and
I would love it. [laughter] Gail:  OK, great. We have one down here Karen.
Audience Member:  Speak through the microphone? Gail:  The question is, can we use KSAs?
Is that politically correct? It’s also the same thing what sills, what kind of knowledge
or skills, competencies, etc. You need to identify what you need that intern, or recent
grad, to do for you? Call it whatever. I’m old and kind of embedded in KSAs a little
bit. For example, has anybody ever seen a vacancy announcement that doesn’t include
this the ability to communicate effectively, both orally and in writing. That’s a KSA from
a hundred years ago. Maybe today they call it a Competency, but we do all have to be
able to communicate. That’s valid for your students. Your students,
there are some students that will demonstrate that better than others for you. They have
to give presentations. They have to write papers, etc., etc. You do have some tools.
Is it maybe just a little bit more? Yeah, but that may be at the end of the day, you
end up more like army where you’ve got an intern that is really interested in doing
your job, and sticking around, and making a career [indecipherable 1:03:09] , which
is part of the purpose to. It’s to encourage Federal careers.
Audience Member:  This is just a question. Gail:  I’m about to cut you off. [laughter]
Audience Member:  But this is a good thing. No, no, no. I just have a, there was a [indecipherable
1:03:33] you’re probably going to have to help me out here. When I first read about
the ad place and everything, it talked about, you have to have the public announcement,
which was fine, I understand that. The public announcement was, there was a cover page that
you would go to a certain page, talk about intern programs, [indecipherable 1:03:47]
programs. You’d click on it and that would take you to the actual website of the organization.
Is that still the case? Because the DOD makes us go with USA Jobs? I understand what DOD
is saying, but is that your policy? Has that changed or is that still the same?
Gail:  No. USA Jobs is actually what the reg says is, you must notify OPM. The way
you notify OPM is through USA Jobs. Audience Member:  Right.
Gail:  In that form of vacancy announcement, right now? There was, don’t get…
Audience Member:  [off mic conversation] Gail:  Right, but do we currently have that
capability? No. In the beginning, we had the morning session, and I went up and looked
at my emails. That’s always a mistake. I actually received an email from somebody who was quoting
the proposed reg. No. We have a final reg. There were some significant adjustments made
between the proposed, and the final. You want to always make sure that you’re looking at
the current stuff. There was a lot of talk about different ways, and we still are pursing
ways of, I believe what they call an ad. That ad would still appear on USA Jobs. The difference
is, that when you post a vacancy announcement on USA Jobs, the applicant can apply directly
via USA Jobs. If you use the ad process, then they have to come in your back door somehow.
They have to go to your system. They don’t actually apply online through USA Jobs.
Audience Member:  Regarding casting of smaller NEFT, if the OPMs qual standard does not a
positive education requirement, what is the appropriate way of indicating that you might
have some preferred academic majors in line for your job? What steps do you take to make
sure that that is defensible? Gail:  The question is, if I’m trying to
recruit for something that doesn’t have a positive education requirement, how can I
say that I want a rocket scientist? I just say it. I say this is preferred. If I’m hiring
Public Affairs, and there are certain academic tracks that would lend themselves to better
preparing that individual, then say so. Say that’s what you want. You can’t disqualify
somebody who doesn’t have it, but when you start to assess your applicants, you can certainly
then start to apply that criteria. It comes down to who’s good, who’s better, and who’s
best. You tell them what you want. The more you
tell them about what you want, the better chance you have of getting the kind of applicants
you want. And not getting a bunch of people who really have no interest in Federal HR,
or Accounting. The accounting is not a good example. Some
of those do have certain educational requirements. You just tell them. The trick is, you don’t
disqualify. Do you see what I’m saying? Quals are quals, but that doesn’t mean that I can’t
say, but this is better. Are we good? I see one more hand, one tentative
hand. Audience Member:  I actually have a couple
of questions, going back to a couple of points that were made about promotions. Is it OK
to go back on this point? Gail:  Yeah. Go ahead.
Audience Member:  One of them actually was for, just say you do an announcement for interns,
not to exceed for just a summer thing, but you actually want to keep some of them on
board after the summer. I think we’ve done this, but I want to make sure it’s right.
We can do a conversion to drop their not to exceed date?
Audience Member:  Is that no, not correct? Gail:  OK. The question is if I hire an intern
not to exceed for the summer, but by the end of the summer I think I’ve got myself a couple
of crackers jacks and I don’t want them to be interned, not to exceeds anymore. I want
them to be an intern. The question is can I just drop the not to exceed date? No, you
cannot. You have got to post that opportunity. Audience Member:  OK, and then my second
one was just say you did hire competitively or through announcement purposes, the intern
without the not to exceed date. The manager has identified that they’re starting to do
higher level work and they’re capable of doing higher level work. Just say they were working
as a GS 4 and the manager thinks they’d be qualified to start doing GS 5 work, how will
we go about promoting that person if at all possible?
Gail:  OK, there’s several things with that and what it is. Her question was if I hire
an intern into just a single grade GS 4, then how do I promote him? There are several answers
and we’re going to get into more detail about that, but why would you hire and intern in
a straight, single graded position? Once again, go back to the purpose of the program. These
people are supposed to on IDP’s, have training plans, these are people you’re supposed to
be developing and growing, hopefully, to be part of your future workforce. Why are you
hiring them at a dead end three or four? Why aren’t you hiring with them some promotion
potential? Then, depending on what you can do, how you
get them to that higher grade, then goes back to some of the requirements for policy. Whether
or not you would be able to just promote that individual or whether at the end of the day,
you would end up having to offer that up to everybody in your workforce. We’ll get to
that, it’s part of our 302 procedure, so… Transcription by CastingWords
p.

Robin Kshlerin

RELATED ARTICLES
LEAVE A COMMENT