The regulations guiding the current Student Educational Employment Program are in the Code of Federal Regulations (CFR). The citation is 5 CFR 213.3202. The questions listed here are not meant to be a substitute for reading the regulations, but rather are a compilation of the most frequently asked questions. We hope this information will be helpful to your agency's student employment coordinators, human resources offices and managers who work with the Student Educational Employment Program.
Q. How many times may a student be appointed to the Student Temporary Employment Program? Student Career Experience Program?
A. 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.
Q. Is a student pursuing a GED eligible for the Student Educational Employment Program?
A. Yes, a student enrolled in GED courses and pursuing a GED diploma meets the definition of student. See 5 CFR § 213.3202. Depending on the nature of the student's coursework, the student might not be eligible for the Student Career Experience Program but would be eligible for the Student Temporary Employment Program.
Q. May agencies appoint students who are home-schooled to the Student Educational Employment Program?
A. Providing they are otherwise eligible, home-schooled students may participate in the Student Educational Employment Program as long as they are participating in either 1) an accredited home-school, or 2) a home-school curriculum approved by their State.
Q. What are the age requirements for students to participate in the Student Educational Employment Program?
A. Age 16 is the minimum age allowed for Federal employment. This is described in OPM's regulations on child labor at 5 CFR § 551.601.
Q. May a son or daughter of an agency employee participate in that agency's Student Educational Employment Program?
A. Yes. There is no longer a restriction that would bar a student from working at the same agency as his/her parent. The only requirement is that the parent and student have no direct reporting relationship and that the relative not advocate the employment, promotion or advancement of the student. See 5 CFR 5 CFR § 213.3202(a)(7) and (b)(7).
Q. Must students be U.S. citizens at the time they are appointed?
A. There is no overarching requirement that applicants applying for positions in the excepted service be U.S. citizens. However, the student must have been lawfully admitted to the United States as a permanent resident or otherwise authorized to be employed. Note, some agencies are precluded from hiring non-citizens by a ban in their appropriations act. Agencies should check with their financial officer or general counsel's office when considering a student who is a non-citizen. Students who participate in the Student Career Experience Program may not be converted to career conditional employment in the competitive service unless they are citizens at the time of conversion.
Q. Are students required to be registered with the Selective Service before they may be appointed under the Student Education Employment Program?
A. Male applicants born after 12/31/59 who are required to register with the Selective Service under section 3 of the Military Selective Service Act must be registered (or must have registered at the time that they were required to do so) in order to be eligible for appointment under this program. See 5 U.S.C. § 3328(a) and 5 CFR Part 300, Subpart G.
Q. What is the appointment authority for the Student Career Experience Program?
A. Students are appointed under Schedule B, 5 CFR § 213.3202. This is the appointment authority regardless of the type of academic program.
Q. What is the appointment authority for the Student Temporary Employment Program?
A. Students are appointed under Schedule B, 5 CFR § 213.3202. This is the type of appointment authority regardless of the type of academic program.
Q. May students appointed to one of these programs remain on the appointment once they have completed their educational requirements?
A. Students appointed to the Student Career Experience Program who have met all requirements of the program and have satisfactorily completed the requirements of their diplomas may continue on the appointment for 120 days beyond the date of completing their work and academic requirements. This 120 day period is permitted by Executive Order 12015. At the end of the 120-days, if the graduate has not been converted to a position in the competitive service, he/she must be separated.
Once a student appointed to the Student Temporary Employment Program has completed the requirements for his/her degree/diploma/certificate (as appropriate), he/she is no longer a student as defined by 5 CFR § 213.3202(a)(2), and must be separated, even if the NTE date on their current appointment has not been reached. The reason for the separation is that people in this situation are no longer "students" and therefore no longer meet the basic eligibility for the program. Executive Order 12015 does not permit these graduates to remain on a STEP appointment beyond the date of completing academic requirements. If enrolled or accepted for enrollment in an additional educational program, they may be given a new appointment.
Q. Must applicants for the Student Educational Employment Program be rated and ranked?
A. No. Schedule B positions are exempt from the usual competitive examining procedures (5 CFR § 213.3201) and students appointed under the Schedule B Student Educational Employment Program are also exempt from the rating and ranking requirements under the Excepted Service. See 5 CFR § 302.101.
However, agencies may want to establish a ranking procedure to place themselves in a better position to explain and defend their decisions. For example, based on the qualification standards used for the position, students may be evaluated to determine only eligibility or ineligibility for the position or may be ranked according to more qualitative factors. It is recommended that procedures be documented and applied consistently to avoid any appearance of impropriety.
Q. Does veterans' preference apply in the selection process for students?
A. Pursuant to 5 CFR § 302.101(c)(8)), each agency is required to follow the principle of veterans' preference as far as administratively feasible and, on the request of a qualified and available preference eligible, to furnish him or her with the reasons for his or her non-selection.
Q. Is there a public notice requirement for filling student positions?
A. There are no OPM requirements for public notice. Agencies may establish procedures of their own.
Q. Do students need to take any written tests to apply for the Student Employment Programs?
A. No. These programs are established pursuant to 5 CFR § 213.3201 and 5 CFR § 213.3202 (a) and (b), respectively. Section 213.3202(b), establishing the Student Career Experience Program explicitly states that written tests are waived for students in the Student Career Experience Program. See 5 CFR § 213.3202(b)(15). This includes initial appointment and conversion. Although it is not explicitly stated in subparagraph (b), written tests are also waived for entry into the Student Temporary Employment Program. That program, like the Student Career Experience Program, was created pursuant to 5 CFR § 213.3201. Section 213.3201 establishes that positions filled under this authority are excepted from the usual competitive examining procedures.
Q. What qualification standards does an agency use to appoint students?
A. OPM does not publish qualification standards for positions in the Excepted Service. Therefore agencies have the option of (1) developing their own qualification standards or (2) using OPM competitive service qualification standards. If an agency chooses option (1), it may develop its own standards or adopt or modify the former Schedule B student trainee qualification standard as their own. If an agency chooses option (2), it may use the competitive service qualification standard for the target position, or the competitive service student trainee qualification standards. See 5 CFR § 213.3202(a)(12) and 213.3202(b)(15).
Q. Do time in grade restrictions apply to students in the Student Educational Employment Program?
A. No. Time-in-grade restrictions apply only to competitive service positions. See 5 CFR § 300.603).
Q. What qualification standard does an agency use when it wants to promote a student?
A. An agency must use the same qualification standard it used to appoint the student. See 5 CFR § 213.3202(a)(12) and 213.3202(b)(15).
Q. What qualification standard does an agency use at the time a student (Student Career Experience Program) is being converted to a career-conditional appointment?
A. An agency uses the competitive service qualification standard for the grade level and occupation to which the student is being converted. See 5 CFR 213.3202(b)(11)(D).
Q. May agencies consider financial need in the selection process for their Student Educational Employment Programs?
A. Yes, however, generally there is no requirement for students to meet any specific economic income criteria to be eligible. Agencies may design their Student Educational Employment Programs to include outreach to those students who are most in need of financial assistance. The criteria and documentation to demonstrate financial need must be established by the agency. See 5 CFR § 213.3202(a)(8) and 213.3202(b)(8).
Q. How may agencies determine financial need without OPM issuing the economic guidelines?
A. Determining financial need and the definition of financial need is left up to each agency's discretion. Factors to consider might be the size of the family, local cost of living indicators, household income, medical expenses, educational expenses, etc. Agencies might also wish to consider other types of financial aid that the family is already receiving as indicators of financial need (e.g., food stamps, public assistance, subsidized housing, student financial aid). If the student is attending a post secondary school, information available from the financial aid office might also be considered.
Q. Do local employment service offices still refer students to Federal agencies for Student Employment Programs?
A. Referrals and financial certification for student employment opportunities are no longer required by the Student Educational Employment Program regulations. Agencies may wish to continue to work with local employment service offices to continue to refer students. If financial need is a factor in an agency's program, the criteria and documentation must be developed by the agency.
Q. What tenure groups are students placed in?
A. Students in the Student Temporary Employment Program, provided they have completed one year of current continuous service, are in tenure group 3; Students in the Student Career Experience Program are in tenure group 2. See 5 CFR § 351.502, 5 CFR § 213.3202(a)(14) and 5 CFR § 213.3202(b)(19).
Q. May students in the career experience program be classified using the student trainee, GS-099, series?
A. Yes. Students appointed to positions subject to the General Schedule (GS) are classified as student trainees (099 series) for the appropriate occupational group. (See Qualifications)
Q. How are student employees classified?
A. Students are classified to an appropriate GS or Wage Grade (WG) series and grade and paid according to that classification. See 5 CFR § 213.2302(a)(11).
Q. May students be paid minimum wage?
A. No. Students in the Student Educational Employment Program must be paid according to the criteria set forth in the appropriate general schedule or wage grade classification standard for the job. See 5 CFR § 213.3202(a)(11).
Q. Do students get within-grade increases?
A. Students in the Student Career Experience Program are eligible for within-grade increases. For students in the Student Temporary Employment Program, eligibility for within-grade increases depends on the pay system of the occupation. Temporary WG employees are eligible for within-grade increases; temporary GS employees are not eligible for within-grade increases.
Q. May students be promoted?
A. Yes. Students in both programs are eligible for promotion. However, the Nature of Action Code (NOAC) for students in the Student Temporary Employment Program is actually a conversion to a new appointment (at the higher grade level) while keeping the current NTE date. Even though the actual nature of the action is a conversion to a new appointment, a 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 WG employee is entitled to an increase in pay of at least one step (about 4 percent). See 5 CFR § 213.3202(a)(12) and 213.3202(b)(15).
Q. Are students eligible for annual and sick leave?
A. Yes. Students in both programs earn annual and sick leave. See 5 CFR § 213.3202(a)(13)(i) and 213.3202(b)(16)(i).
Q. Are students eligible for health and life insurance benefits?
A. 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 in the Student Temporary Employment Program are considered temporary employees and are generally not entitled to these benefits. However, once students have been continuously employed for a year without a break in service exceeding 5 days, they may enroll in the Federal Employee Health Benefits Program, but they would have to pay 100 percent of the premium (i.e., both the employee and government share). There is no provision for temporary employees to be eligible for life insurance coverage.
Students in the Student Career Experience Program are eligible for both health and life insurance coverage as long as they are expected to be employed under this appointment authority for at least one 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. Cost of premiums is split between the employee and the agency, as for all permanent employees. (See 5 CFR § 870.202 for life insurance and 5 CFR § 890.102 for health benefits.)
Q. Are students eligible for retirement benefits?
A. Students in the Student Temporary Employment Program are generally ineligible for retirement coverage. See 5 CFR § 831.201, 842.105, 213.3202(a)(13)(i). Students in the Student Career Experience Program with less than 5 years of prior civilian service are generally covered by the Federal Employees Retirement System (FERS). See 5 CFR part 842 and 5 CFR § 213.3202(b)(16)(i).
Q. May students be placed on intermittent schedules?
A. An intermittent schedule is appropriate only when the nature of the work is so sporadic and unpredictable that a regularly scheduled tour of duty cannot be scheduled in advance. In establishing the Student Educational Employment Program, OPM did not intend to have STEP or SCEP students working on intermittent schedules. Students may work full- or part-time schedules, however, as best meets their needs and the needs of the agency.
Q. Must students work or attend school during the summer?
A. . In establishing the Student Educational Employment Program, OPM intended, generally that students always be either attending classes, working at the agency, or both. However, agencies may use their discretion to permit a break in program during which time a student is neither attending classes nor working. The student would be placed on leave without pay (LWOP) during this time.
Q. Are there any "outer limits" on the length of a "break in program" which an agency can approve?
A. No. It is at the discretion of the agency. Agencies should ensure that the student is making reasonable progress towards the attainment of the degree/diploma, etc., and that the needs of the manager are also considered.
Q. May students work less than 16 hours a week?
A. Yes. Although the Federal Employees Part-Time Career Employment Act of 1978 defines part-time as from 16 to 32 hours a week, 5 CFR § 340.202(b) permits agencies to allow employees in tenure group 1 or 2 to perform regularly scheduled work of from 1 to 15 hours per week. Students in the Student Career Experience Program are in tenure group 2. The Act does not cover employees in tenure group 3 so students in the Student Temporary Employment Program (tenure group 3) may work any number of hours acceptable to all parties.
Q. May students still alternate school and work (e.g. work full-time this semester, and next semester go to school full-time, and not work at all)?
A. Yes. The student, school and agency need to work together to accommodate the academic needs of the student and the work related needs of the agency. For students participating in the Student Career Experience Program there must be a written agreement (5 CFR § 213.3202(b)(12)) and a formally arranged schedule of school and work.
Q. Does a student's work experience, while on the student temporary appointment, count towards the required 640 hours necessary for noncompetitive conversion to career-conditional employment?
A. Yes, if the work performed is related to the student's academic studies and career goals. There should be clear documentation showing the relatedness between the work (actual duties/tasks/assignments) performed while on the Student Temporary Employment Program appointment and the Student Career Experience Program appointment. See 5 CFR § 213.3202(a)(15).
Q. Does a student's work experience, while on the former Stay-In-School program and prior to conversion to the new Student Temporary Employment Program, count toward the required 640 hours?
A. Yes. Agencies may consider and count work experience gained under the former Stay-in-School Program toward the 640 hours. However, there should be clear documentation showing the relatedness between the work (actual duties/tasks/assignments) performed under the Stay-in-School appointment and the work being performed under the Student Career Experience Program.
Q. Does the time spent on the Student Temporary Employment Program count towards career tenure? time-in-grade?
A. No. The time does not count towards career tenure because the 3-year period of service required to obtain career tenure must begin and end with non-temporary employment in the competitive service. However, the time spent on the student temporary appointment would be creditable towards any time in grade calculation. (Time spent on the former Stay-In-School appointment would also be credited towards time-in-grade). See 5 CFR § 315.201.
Q. Has the 120-Day conversion period been changed?
A. No. The requirement that noncompetitive conversions must take place within 120 days after completion of educational requirements is in Executive Order 12015 and has not been changed.
Q. When does the 120-Day conversion window begin...upon completion of course requirements or upon "graduation ceremony day?"
A. Upon satisfactory completion of course requirements.
Q. May a student work any of the required 640 hours necessary for conversion, after he/she completes his/her educational requirements?
A. No. The required work experience must be gained prior to, or concurrent with the completion of the student's education. This requirement is stated in the Executive order.
Q. Is a student eligible only for noncompetitive conversion in the agency where the student worked prior to the completion of his/her education?
A. No. A student is eligible to be noncompetitively converted in any Federal agency. Agency student employment coordinators are urged to try and place the graduates with other agencies, if placement in their own agency is not possible. Checking the job listings on the USAJOBS is one way to locate appropriate positions for graduated students.
Q. If an agency wants to hire a graduating career experience student does the agency have to clear the Career Transition Assistance Program (CTAP)?
A. No. See 5 CFR § 330.606(d).
Q. If an agency wants to hire a graduating career experience student who worked, while on the student appointment, with another agency, does the gaining agency have to clear The Interagency Program Career Transition Assistance (ICTAP)?
Q. If an agency wants to hire a graduating career experience student who worked, while on the student appointment, with another agency, does the gaining agency have to clear the Reemployment Priorities List (RPL)?
A. Yes, if the student is from a different agency. However, if the student is going from one location/activity/component to another location/activity/component in the same agency, the agency has discretion on whether to give RPL registrants priority over students. For purposes of the RPL, all DOD agencies are considered the same agency. DOD agencies (e.g., Defense Logistics Agency, Defense Investigative Service) and the Departments of Army, Navy, and Air Force are all considered DOD. See 5 CFR § 330.201(a).
Q. May an individual participating in the Student Career Experience Program be noncompetitively converted to a position that has an established career ladder?
A. Yes. An individual participating in the Student Career Experience Program who otherwise meets the program requirements for conversion (i.e., work hours, satisfactory performance, educational requirements, etc.) may be converted to a position that has an established career ladder. For instance, a SCEP GS-0201-04 Human Resources Trainee may be noncompetitively converted to a GS-0201-05/7/9/11 Human Resources Specialist career ladder position. See 5 CFR § 213.3202(b)(11).
Q. What type of military experience is creditable towards the 640 hours required for conversion?
A. Agencies may credit any type of active duty military service (including active duty for training) performed by a SCEP student as long as the active duty service is related to the SCEP position, as determined by the agency.
Q. What criteria should agencies use to determine if a non-Federal intern program is comparable to the SCEP?
A. Agencies must use the criteria set forth in 5 CFR § 213.3202(b)(11)(ii). The non-Federal intern program must also have been a formally structured program requiring a written agreement between the school, student, and Federal agency. For example, the agreement would have addressed issues such as the nature of work assignments, schedule of work assignment and class attendance, evaluation procedures, and requirements for continuation and successful completion of the program.
Q. May an agency add or combine these flexibilities to credit a student the entire 640 hours required for conversion?
A. No. An agency may credit only up to a total of 320 hours toward the required 640 hours. However, agencies may add or combine these flexibilities to credit a student up to 320 hours for non-SCEP work experience. See 5 CFR § 213.3202(b)(11)(i)(A)
Q. May an agency waive up to 320 hours for exceptional job performance and outstanding academic achievement for time a student spent on a non-Federal internship (i.e., worked in, but not for, a Federal agency)?
A. No. Agencies may consider only exceptional job performance and outstanding academic achievement that was demonstrated under a Student Educational Employment Program appointment (i.e., STEP or SCEP). See 5 CFR § 213.3202(b)(11)(iii)
Q. May an agency waive up to 320 hours for exceptional job performance and outstanding academic achievement for time a student spent on a STEP appointment when that student is subsequently converted to a SCEP appointment?
A. Yes. Agencies are reminded when considering the outstanding academic achievement and exceptional job performance accomplishments from a STEP appointment, the outstanding academic achievement and exceptional job performance must have been related to the student's current SCEP position.
Q. How may an agency waive up to 320 hours of the 640-hour work requirement for a student with outstanding academic achievement and exceptional job performance if that student has not worked in the agency long enough to receive a performance appraisal?
A. Agencies may wish to modify their performance plans to allow student evaluations after a minimum of 320 hours in order to take advantage of this new flexibility. If the student meets the criteria for exceptional job performance and outstanding academic achievement, the program allows an agency to evaluate a SCEP student after 320 hours.
Q. Is an agency required to write performance plans for students and conduct performance evaluations?
A. OPM encourages agencies to establish performance plans and conduct performance evaluations for student employees to: (1) document what the student is expected to do, and (2) advise the student on how well he/she is performing. Student Temporary Employment participants, who are on appointments not-to-exceed (NTE) one year, could be excluded by their employing agency from the requirements for performance appraisal if certain requirements are met and the student agrees to not having his/her performance appraised. (See 5 CFR § 430.202.) Participants in the Student Career Experience Program, who are eligible for noncompetitive conversion to career conditional status, do not fall under any of the exclusions specified in the OPM regulations and, therefore, are required to have written performance plans and be appraised on their performance as specified in the agency's performance appraisal system. Performance appraisals can be used as documentation to support both positive and negative consequences of the student's performance. Further documentation for the Student Career Experience Program students may be included in the written agreement signed by all parties (student/school official/agency) prior to the initial appointment.
Q. If an agency wants to terminate a career experience program student because it is unable to offer him/her a position after graduation (due to funding, downsizing/FTE issues) does the agency need to use RIF procedures?
A. If the student (STEP or SCEP) has not completed his/her education requirements, students are covered by OPM's reduction in force regulations and are placed in excepted service, tenure group 2. If, however, a student in the Student Career Experience Program has completed his/her education requirements, and is within the 120- day conversion period for optional conversion, he or she has no vested right to remain employed and has no mandatory right to be non-competitively converted to a competitive service position. Therefore, the agency may terminate the student without regard to reduction in force regulations.
Q. Are SCEP students who are converted to career or career-conditional appointments subject to the probationary period required by 5 CFR § 315.801?
A. Yes. However, time spent on the SCEP appointment may be credited towards probation provided it meets the requirements of 5 CFR § 315.802.
Q. May an agency credit time spent in a non-Federal internship or active duty military service towards the probationary period?
A. No. 5 CFR § 315.802 only allows for prior Federal service in the same agency and in the same line of work.