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Recruitment Policy Studio

Federal Section
Planning for Recruiting - Pathways
Pathways for students and recent graduates to federal careers


Must candidates be U.S. citizens or Nationals at the time they are appointed to the Internship, Recent Graduates, or PMF Program? (READ MORE)
It depends. There is no overarching requirement that applicants for positions in the excepted service be U.S. citizens. Many agencies, however, are subject to restrictions from paying non-citizens in their annual appropriations legislation or other agency-specific enabling and 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 permanent Federal employment in the competitive service.

Must applicants have actually completed their educational degree requirements to be eligible to apply to the Recent Graduates Program? (READ MORE)
No. Students who have not completed their educational degree requirements 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 part 362.302 in order to be appointed as a Recent Graduate under the Pathways Program.

In addition, agencies can choose to accept applications from individuals who will complete education by a certain cutoff; e.g., announcement closing, date certificate issued, appointment date. Any such conditions must be established in the agencies’ Pathways MOU and in the agencies’ application procedures under 5 CFR part 302.301.

What constitutes a valid certificate program for purposes of eligibility under the Pathways Programs? (READ MORE)
The Pathways Programs regulation (see 5 CFR 362.103) defines certificate program as “post-secondary education, in a qualifying educational institution, equivalent to at least one academic year of full-time study that is part of an accredited college-level, technical, trade, vocational, or business school curriculum.”

Since the early days of the Cooperative Education Program (more recently called the Student Career Experience Program), a predecessor program to the Pathways Internship Program, certificate programs were included in the educational requirements to accommodate technical, trade, and vocational schools where individuals learn a trade that does not necessarily require a 2- or 4-year degree from a college or university. Generally, these occupational fields require licensure for an individual to practice his or her trade or craft. OPM did not intend the use of certificate programs to allow agencies to appoint individuals enrolled in short term “certificate programs” that are not required for the position or which lacked sufficient academic rigor.

May an agency use an educational requirement such as the completion of specific coursework as eligibility criteria for a Pathways Intern position? (READ MORE)
For positions that have positive education requirements, agencies may impose educational requirements as they would relate to the OPM qualifications standard for the target position if stated as eligibility requirements, rather than minimum qualification requirements. For example, if an agency is filling a Petroleum Engineering Intern position, which upon conversion would require that the Intern had completed specific courses in engineering, then the agency may indicate that only students who have completed or are currently taking some or all those required courses will be eligible for the Petroleum Engineering Intern position.

For positions that do not have positive education requirements, agencies may not impose education degree requirements or require that specific courses have been, or will be, taken as an eligibility requirement. The agency may indicate in the Pathways job opportunity announcement that they seek or prefer candidates who are pursuing specific degree paths or courses. However, agencies must follow the selection procedures in 5 CFR part 302, before making a selection.

For the Pathways Internship Program, may an agency use requirements such as the ability to work a specified number of hours each week or be in good academic standing (e.g., require maintenance of a minimum grade point average (GPA)) as an eligibility criteria? (READ MORE)
Yes. Agencies may use requirements such as the ability to work a specified number of hours per week or be in good academic standing as eligibility criteria. However, the hiring agency must ensure that all such criteria are stated in the agency’s Pathways MOU with OPM, the job opportunity announcement, and the participant agreement.

If a student is hired as an Intern with a not-to-exceed date (NTE), does the work performed need to be related to the student’s academic area of study? (READ MORE)
No. Intern NTE positions are used to complete temporary projects, to perform labor-intensive tasks not requiring subject-matter expertise, or to fill traditional summer jobs. This work is not required to be related to the student’s area of study.

When filling a position under the Pathways Internship Program, must the Internship position be related to the student’s academic field of study? (READ MORE)
No. The Internship position either must be related either to the student's academic field of study or the student’s career interests.

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? (READ MORE)
No. The Schedule A hiring authority cannot be used to fill Pathways Programs positions. 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 program by following the instructions found in the job opportunity announcement on 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.