AOTA Advocates for Amendments to the Graduate or Higher Level Degree Requirement for Federal Government Employment

In late 2017, it came to AOTA’s attention that the Individual Occupational Requirements for the Occupational Therapy, 0631 Series was precluding occupational therapists without a graduate or higher level degree from being employed at federal agencies, and additionally was acting as a barrier to opportunities for promotion to a supervisory position at federal agencies. This initiated a series of meetings with impacted members regarding how to proceed, and resulted in a direct inquiry to the Office of Personnel Management (OPM), requesting they reconsider or amend certain language in instances that would be more appropriately weighed on a case-by-case basis; for example, during the independent hiring process. The current language provided by Occupational Therapy Series, 0631 provides that, as of September 2017, newly hired employees must meet the basic requirements for federal government employment, which currently state that holders of occupational therapy positions in this series must hold a graduate or higher level degree. Federal government employees hired before September 2017 are considered to have already met the basic requirements for the position occupied, and thus are grandfathered in.

Following AOTA’s initial request, OPM was silent for months despite repeated efforts to obtain a response. When we finally received a response from an OPM representative in May 2018, the OPM’s position remained that contrary to the feedback we had received from members, the Qualification Standards do not preclude agencies from considering the qualifications of individuals with legacy degrees (i.e., bachelor’s degree) and that agencies may consider experience as well as legacy degrees to determine the qualifications of applicants. However, because our members had provided AOTA with documentation reflecting that this was not the case, we had evidence directly contradicting the OPM position. AOTA promptly responded to OPM by letter, providing a variety of member examples showing that some agencies did not, in fact, consider past experience or provide the types of flexibility OPM stated they would. AOTA received an email response from OPM on September 4th, 2018, that suggests new “guidance” has been provided to agencies since our last efforts at contacting them directly. We requested a copy of this guidance and are still waiting for a response from OPM to learn what it includes and in what format it has been disseminated.

We continue to advocate for you! Please stay tuned for updates on this issue as more information becomes available. Email regulatory@aota.org if you have been impacted by this OPM policy and have not already spoken with us.