Shared Applicant Pools for Agency Jobs

By: Keli Wilson and Marcelle Clavette

The Office of Personnel Management (OPM) announced an initiative for federal agencies to pursue pooled hiring with a focus on skills-based selection, evaluating needed skills versus applicants’ education and past employment history. In other words, when one agency goes through the steps to recruit, interview, and select an employee, the list of prospective employees that are deemed qualified for federal employment would then be shared with other agencies hiring for a similar role.

There are clear benefits to using a pooled applicant approach including streamlining resources and capitalizing on the strengths of some agencies’ selection processes to fill similar job vacancies across agencies. This may decrease time to hire and maximize effective selection processes.  

However, these gains cannot shadow the need for continued efforts for equal employment opportunity and implementation of this process leads to some important questions for federal agencies, including: 

• How will each agency meet record keeping requirements for job seekers and qualified applicants?  
• How are agencies advised to monitor adverse impact with multiple agencies having access to the same pool?  
• Which agency is responsible for validating employment tests if statistical and practical indicators for adverse impact are identified through monitoring of selection outcomes?  
• If there is adverse impact, which agency is liable? 
• How will each agency measure the effectiveness of outreach and recruitment towards equal employment opportunities and diversity, equity, and inclusion (DEI) programs? 
• Is research available to agencies to understand how pooled hiring impacts equal employment opportunity and diversity, equity, and inclusion? 
• What recommendations have been provided to agencies to maximize diversity efforts while utilizing pooled hiring practices? 

Of course, the implementation of a new approach to hiring also yields many general questions, including: 

• Do multiple agencies have access to the open pool of qualified candidates at the same time?  
• What happens if more than one agency is interested in the same candidate?  
• Can one agency decline an applicant deemed to be certified for employment? If yes, will that individual be removed from the eligibility pool for use by other agencies? 
• How frequently will the qualified list be updated with newly interested and qualified candidates? 

Considerations for Federal Contractors and Other Private Employers 

To be clear, this initiative only affects federal agencies. However, initiatives for federal agencies can sometimes affect future obligations for federal contractors and other private employers. A pooled approach to hiring would be a sea change for private employers and would undoubtedly result in serious effects on their equal employment opportunity, affirmative action, and DEI programs, effects that regulatory agencies like the Office of Federal Contract Compliance Programs or the Equal Employment Opportunity Commission may not appreciate. 

DCI is monitoring this initiative and will continue to provide updates, as needed.