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Background

Question: What’s the difference between the Internship Program and the Recent Graduates 

Program?

Answer: The Internship Program is for students currently enrolled in a degree/certificate 

seeking program. The Recent Graduates Program is for individuals who completed the program 

requirements for an associates, bachelors, masters, professional, doctoral or technical/vocational 

degree or certificate. 

Question: How many times can a student be appointed to the Internship Program? 

Answer: There is no limit on the number of times a student may be appointed as long as he/she 

meets the eligibility requirements for the appointment.

Eligibility

Question: What are the eligibility requirements for the Internship Program?

Answer: An individual must be currently enrolled or accepted for enrollment on at least a halftime schedule as a student at an accredited educational institution in a certificate, degree or 

diploma program, and must meet the qualification standards for the Internship position.

Question: What are the eligibility requirements for the Recent Graduates Program?

Answer: An individual must be within 2 years of completion of program requirements for an 

associates, bachelors, masters, professional, doctoral or technical/vocational degree or certificate 

from an accredited educational institution and meet the qualification standards for the position. 

Preference eligible veterans may be eligible for extensions on time to apply. (See Frequently 

Asked Questions)

Pathways Frequently Asked Questions
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Question: May students appointed under the Internship Program remain in the Program once 

they have completed their educational requirements?

Answer: No. Students appointed under the Internship Program who have met all requirements 

of the Program and have satisfactorily completed the requirements for their 

diploma/certificate/degree may no longer remain in the Program, as they are no longer students 

and no longer meet the eligibility requirements for the Program.

Question: May the son or daughter of an agency employee participate in that agency's Internship 

Program?

Answer: Yes. The parent and student must not have a direct reporting relationship and the 

relative cannot advocate the employment, promotion or advancement of the student. See 5 CFR 

362.105(f).

Question: What are the age requirements for students to participate in the Internship Program?

Answer: Age 16 is the minimum age allowed for Federal employment. See OPM's regulations 

on child labor at 5 CFR 551.601.

Question: Is a student pursuing a GED eligible for the Internship Program?

Answer: Yes, a student enrolled in GED courses and pursuing a GED diploma meets the 

definition of “student” provided the student is attending a qualifying educational institution. See 

5 CFR 362.202. 

Question: Are male students required to be registered with the Selective Service before they may 

be appointed under the Pathways Programs?

Answer: In order to be eligible for appointment to a position in an Executive agency, , male 

applicants born after December 31, 1959, who are required to register with the Selective Service 

under section 3 of the Military Selective Service Act, and who are still capable of registering 

(i.e., have not yet reached age 26), must actually be registered. If it is no longer possible for an 

applicant required to register to do so, i.e., if the applicant has reached age 26, the applicant 

must be able to demonstrate that his failure to register was not knowing and willful. See 5 U.S.C. 

3328(a) and 5 CFR part 300, subpart G.

Question: May agencies appoint students who are home-schooled to the Internship Program?

Answer: Yes, provided they are otherwise eligible under 5 CFR 362.203, home-schooled 

students may participate in the Internship Program as long as they are participating in either 1) an 

accredited home-school, or 2) a home-school curriculum approved by their State or local 

governing jurisdiction.
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Applying to the Recent Graduates Program

Question: An individual completes qualifying educational requirements for a degree in May 2012. 

Subsequently, this individual enters the military and is released from active duty in July 2014. 

How much time will this individual have to apply for a Recent Graduates position?

Answer: The 2-year window to apply to the Recent Graduates Program will begin in July 2014 

and end in July 2016 (provided that the individual meets the definition of “veteran” in 5 U.S.C. 

2108). 

Question: What if an individual completes a degree, and then 6 months later is called back to 

active duty for 4 years? How long would this individual be eligible for the Recent Graduates 

Program?

Answer: This individual would be eligible for an additional 18 months after being discharged or 

released from active duty (provided that the individual meets the definition of “veteran” in 5 

U.S.C. 2108). 

Question: What if an individual is in the Reserve Officers Training Corps (ROTC) and has a 4-

year service obligation after graduation; will this individual still be eligible to apply after being 

discharged?

Answer: The 2-year window of eligibility will begin upon completion of the 4-year service 

obligation (provided the individual meets the definition of “veteran” in 5 U.S.C. 2108). 

However, under no circumstances can the eligibility period extend beyond 6 years from the date 

of completing the educational requirements for a degree. 

Question: An individual received a degree in May 2012 while serving on active duty. This 

individual still has 3 more years of service. Will this individual still be eligible for the Recent 

Graduates Program? 

Answer: Yes. This individual will be eligible to apply for positions for 2 years from the date he 

or she is released from active duty (provided the individual meets the definition of “veteran” in 5 

U.S.C. 2108). However, under no circumstances can the eligibility period extend beyond 6 years 

from the date of completing the educational requirements for a degree. 

Question: An individual completed degree requirements in 2011. How long will this individual 

have to apply for positions under the Recent Graduates Program?

Answer: Any individual who completed his or her educational requirements between December 

27, 2010, and the effective date of the final Pathways regulation (July 10, 2012) will have 2 years 

from the effective date of the regulation to apply to the Recent Graduates Program. 
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Benefits

Question: Are Pathways Interns and Recent Graduates eligible for health and life insurance 

benefits?

Answer: Health and life insurance coverage for Federal employees depends on the type of 

appointment an employee has and the expectation of substantial employment during the year. 

Students hired under the Internship Program on a temporary appointment are generally not 

entitled to these benefits. However, once they have been continuously employed for over a year 

without a break in service exceeding 5 days, they may enroll in the Federal Employees Health 

Benefits Program, but they would have to pay 100 percent of the premium (i.e., both the 

employee and Government share). Temporary employees are not eligible for coverage under the 

Federal Employees’ Group Life Insurance Program. 

Students hired under an Internship/Recent Graduate or PMF appointment for a period expected 

to last longer than 1 year are eligible for health and life insurance coverage as long as they are 

expected to be employed under this appointment for over 1 year and are expected to be in a pay 

status for at least one-third of the total period of time from the date of their initial appointment to 

the date of the completion of the Program. The cost of premiums is split between the employee 

and the agency, as it is for all permanent employees. (See 5 CFR 870.202 for life insurance and 5 

CFR 890.102 for health benefits.)

Question: Are Pathways employees eligible for retirement benefits?

Answer: Students hired under the Internship Program are generally ineligible for retirement 

coverage. See 5 CFR 831.201 and 842.105. Recent Graduates are eligible for retirement 

benefits if their appointments are for more than 1 year.

Question: Are Interns/Recent Graduates eligible for annual and sick leave? 

Answer: Yes, employees hired under the Pathways Programs on appointments for 90 days or 

more are eligible to earn annual and sick leave. As provided in 5 U.S.C. 6303(b), employees 

whose appointments are limited to less than 90 days may be eligible for annual leave if they have 

previously served for a continuous period of 90 days under successive appointments.

Tenure, Classification and Pay

Question: What tenure groups are Pathways employees placed in? 

Answer: Interns serving under appointments expected to last more than 1 year are in the 

excepted service Tenure Group II. Interns serving under temporary appointments expected to 

last 1 year or less are in Tenure Group 0, unless they have completed at least 1 year of current 

continuous service, in which case they are in Tenure Group III. Recent Graduates are in the 

excepted service Tenure Group II.
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Question: Are employees appointed under the Pathways Programs eligible for promotion? If so, 

what is the nature of action code (NOAC) and pay setting process?

Answer: Yes. Employees hired under the Pathways Programs are eligible for promotion, except 

for Interns on appointments expected to last less than 1 year. The Nature of Action Code 

(NOAC) can be found in the promotion chapter of the Guide to Processing Personnel Actions. 

A General Schedule (GS) employee is entitled to an increase in pay of at least two steps (about 6 

percent) upon placement in a higher-graded position without a break in service. A Wage Grade 

(WG) employee is entitled to an increase in pay of at least one step (about 4 percent). See 5 CFR 

362.203(e).

Question: What is the appropriate classification series for Interns in the Pathways Program?

Answer: Interns are classified to an appropriate xx99 series for occupational groups in the GS 

(or equivalent) system and xx01 series for occupational groups appropriate for the Federal Wage 

System. See 5 CFR 362.203(f). There are no special requirements for classifying positions 

under the Recent Graduates or PMF Programs.

Conversion to the Competitive Service

Question: May individuals participating in the Internship and Recent Graduates Programs be 

noncompetitively converted to a position that has an established career ladder? 

Answer: Yes. An individual participating in the Internship or Recent Graduates Program who 

otherwise meets the Program requirements for conversion (i.e., work hours, satisfactory 

performance, educational requirements, training completed, etc.) may be converted to a position 

that has an established career ladder. For instance, an Intern GS-0299-04 Human Resources 

Trainee may be noncompetitively converted to a GS-0201-05/7/9/11 Human Resources 

Specialist career ladder position. See 5 CFR 362.106. 

Question: May an Intern work any of the required 640 hours necessary for conversion after 

he/she completes his/her educational requirements? 

Answer: No. The required work experience must be gained prior to, or concurrent with, the 

completion of the student's education.

Question: Does the time spent on an Intern temporary NTE appointment count towards career 

tenure? Time-in-grade? 

Answer: Yes. The time counts towards career tenure (see 5 CFR 315.201). The time spent on 

the temporary Intern NTE appointment would be creditable towards any time-in-grade 

calculation. 
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Question: Does an Intern’s work experience while on an Intern temporary NTE appointment, 

count towards the required 640 hours necessary for noncompetitive conversion to careerconditional employment? 

Answer: Yes. Time spent on an Internship appointment is potentially creditable towards 

conversion in accordance with the provisions of 5 CFR 362.204.

Question: Does a student's work experience, while on the Student Temporary Employment 

Program and prior to conversion to the new Internship Program, count toward the required 640 

hours under the Internship Program? 

Answer: Time spent under a STEP appointment is creditable toward the 640-hour requirement 

when the current STEP employee is transitioned to a temporary NTE appointment and 

subsequently converted to an Internship appointment without a NTE date. 

Question: May an agency waive up to 320 hours for conversion to competitive service for an 

Intern, based on exceptional job performance and outstanding academic achievement?

Answer: Yes. Agencies may waive up to 320 hours under both the SCEP and Pathways 

Internship Program. See 5 CFR 362.204(c).

Question: May an agency waive up to 320 hours of the 640-hour work requirement for an Intern 

with outstanding academic achievement and exceptional job performance if that Intern has not 

worked in the agency long enough to receive a performance appraisal?

Answer: If the Intern meets the criteria for exceptional job performance and outstanding 

academic achievement, the Program allows an agency to evaluate an Intern after 320 hours. 

Agencies may wish to modify their performance plans to allow Intern evaluations after a 

minimum of 320 hours in order to take advantage of this new flexibility. 

Question: May an agency combine the credit provisions of 5 CFR 362.204(c) and the waiver 

provisions of 5 CFR 362.204(d) to credit a student with the entire 640-hour work requirement for 

conversion?

Answer: No. An agency may not grant a credit or waiver (or combination thereof) of more than 

320 hours of the 640 hour service requirement. See 5 CFR 362.204(e). 
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Question: Under the STEP, an employee could be noncompetitively converted to a SCEP 

appointment and the work experience gained while under the STEP could be credited towards the 

640 hour work experience necessary for noncompetitive conversion to a term, career, or careerconditional appointment. Has this changed? 

Answer: No. Interns on temporary NTE appointments can be converted to Intern positions. 

The time spent on the Intern temporary appointment NTE can be credited toward the 640-hour 

work requirement. 

Question: Is the 640 hours of work experience a new requirement? 

Answer: No. The current Student Career Experience Program has the same 640-hour work 

requirement that is in the new Internship Program. 

Question: Do individuals awaiting college acceptance notification meet the definition of 

“student”?

Answer: No. A “student” is defined as an individual who has been accepted for enrollment or 

who is enrolled and seeking a degree (diploma, certificate, etc.) in a qualifying educational 

institution as defined in 5 CFR 362.102. Individuals who have not been accepted do not meet 

the definition of “student.”

Question: If the student has signed an agreement under SCEP, is he or she still required to sign a 

Participant Agreement?

Answer: Yes. Pathways participants must sign a Participant Agreement. 

November 2013