GSA's Pathways Programs

Purpose

This Order issues and transmits the General Services Administration’s (GSA) policy governing the use of the Pathways Programs to include the appointment and employment of individuals under the two Pathways Programs (i.e. the Intern Program and the Recent Graduates 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.

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. 

Applicability

This order applies to all GSA Human Resources practitioners and the GSA workforce involved in the hiring and employment of all Pathways Programs’ Interns and Recent Graduates under Schedule D, 5 CFR 213.3402(a) and (b).

1. 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.

Cancellation

This Order cancels and supersedes HRM 9362.1A, GSA’s Pathways Programs, dated June 24, 2024.

Explanation of Changes

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:

1. Removes mention of the Presidential Management Fellows to comply with the Executive Order entitled Commencing the Reduction of the Federal Bureaucracy, dated February 19, 2025 which eliminated the program.
2. Removes references to “diversity, equity, and inclusion (DEI)” to align with the Executive Order Ending Radical and Wasteful Government DEI Programs and Preferencing, dated January 20, 2025.
3. Removes mention of the Luevano Consent Decree which was terminated by the Department of Justice in August 2025.
4. Removes outdated telework language and links to the updated GSA Order HRM 6040.1A Telework Policy.
5. Duty titles were updated to align with the Office of Human Resources Management (OHRM) 2025 reorganization.
6. Adds guidance allowing agencies to apply OPM’s “Rule of Many,” as described in OPM’s final rule on Reinvigorating Merit-Based Hiring Through Candidate Ranking (90 FR 43135).
7. Added “indefinite” intern distinction – Updated the Intern definition in Section 3 to include the new designation.
8. Updated Intern promotion language under Section 26 – Added time-in-grade provisions to clarify that interns may be promoted on conversion without regard to time-in-grade restrictions.
9. Added language to Section 27, Conversion to the Competitive Service – Clarified that while conversion of NTE interns should be rare, it is possible when all academic and program requirements are met and the JOA included the possibility of conversion.
10. Updates performance information to match the revisions of the recently revised GSA Order HRM 9430.2A. Under Section 11 and Appendix C, 120 days is now changed to 90 days.