Federal Manager's Daily Report

OPM has, somewhat apologetically, told agencies to examine their hiring practices in light of a recent presidential memo concerning those who have been unemployed for a significant time or who have financial troubles.

The January White House memo says that agencies must not make an unfavorable determination with respect to the suitability, fitness, or qualifications of an applicant for employment because that applicant is or was unemployed; or has experienced or is experiencing financial difficulty through no fault of their own, if the applicant has undertaken a good-faith effort to meet his or her financial obligations.

The memo further required agencies to review their recruiting and hiring practices to determine whether they intentionally or inadvertently place such applicants at an undue disadvantage.

OPM has issued implementing guidance saying: “We realize that it may be difficult, in some instances, to distinguish between what practices are acceptable (for example, disqualifying a candidate for lack of relevant experience or finding a candidate unsuitable on the grounds that s/he has failed to undertake an honest effort to discharge financial obligations) and what practices may run afoul of the policy announced in the memorandum (for example, disqualifying a candidate on the basis of unemployment per se or finding a candidate unsuitable simply because s/he has outstanding financial obligations).”

“If you believe your practices are compliant, please disclose that affirmatively, so that OPM will know you have considered the question, as required by the memorandum, and have reached a definitive conclusion,” OPM said.

It said that examples of recruitment and hiring practices that support fair opportunities may include: advertising that neither discourages nor discriminates against individuals who are unemployed; application procedures that neither inadvertently nor intentionally put individuals at a disadvantage based on their unemployment status; and using recruitment practices that cast a broad net and encourage all qualified individuals to apply.

The guidance is here: http://www.chcoc.gov/transmittals/TransmittalDetails.aspx?TransmittalID=6101