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Yes, OPM approval is required when using tests to determine basic eligibility or as the sole basis for ranking applicants for inservice placement (reference Part E.9[d] of the Operating Manual on Qualification Standards for General Schedule Positions (http://www.opm.gov/policy-data-oversight/classification-qualifications/general-schedule-qualification-policies/#url=app). For occupations not requiring an OPM test, agencies may develop and implement their own tests for inservice placement without OPM approval as long as such tests are used as part of a comprehensive set of assessment procedures.
However, for delegated competitive examining, OPM approval is not required as long as the assessment procedure is consistent with the technical standards of the Uniform Guidelines on Employee Selection Procedures (http://uniformguidelines.com/). Specifically, the Uniform Guidelines require that the method of test use (e.g., as a screening device with a passing score, for grouping or ranking, combined with other assessments) be supported by findings of a job analysis and test validation study. For example, if the test is to be used for ranking, the agency should have evidence showing that higher scores on the test are related to better job performance.
When a test is used as a "screen out," it becomes part of the minimum requirements for the position and is subject to the same job-relatedness requirements as any other selective placement factor (see the guidance in the Delegated Examining Operations Handbook on the use of selective factors in Chapter 5, Section B, http://www.opm.gov/policy-data-oversight/hiring-authorities/competitive-hiring/deo_handbook.pdf).
An assessment accommodation is defined as a change in how an assessment is presented or how the applicant is asked to respond. Accommodations may include changes in the presentation format, response format, assessment setting, timing, or scheduling. The purpose of an assessment accommodation is to provide equal access to the examination process for applicants with disabilities. Accommodations are intended to lessen the impact of the applicant's functional limitation on the assessment process without:
While providing accommodations will presumably enable applicants to better demonstrate their mastery of job-related competencies or knowledge, skills, and abilities (KSAs), assessment accommodations are not a guarantee of improved performance, test completion, or a passing score.
Specific guidance is provided in Appendix O (Assessing Applicants with Disabilities) of the Delegated Examining Operations Handbook: http://www.opm.gov/policy-data-oversight/hiring-authorities/competitive-hiring/deo_handbook.pdf
The Freedom of Information Act (FOIA, http://www.foia.gov/) can be employed to protect agency examining materials regardless of the basis for filing a disclosure request. 5 U.S.C. § 552a (k)(6) (http://www.justice.gov/opcl/1974tenexemp.htm) protects agencies from mandatory disclosure of "testing or examination material used solely to determine individual qualifications for appointment or promotion in the Federal service the disclosure of which would compromise the objectivity or fairness of the testing or examination process."
Courts have ruled that "agency testing or employee rating materials" are covered by Exemption 2 (DOJ's FOIA Guide contains a summary of Exemption 2 case law, available at: http://www.justice.gov/oip/foia_guide09.htm). The Delegated Examining Operations Handbook, (Chapter 7, Section B - Freedom of Information and Privacy Acts) contains general policy and guidance as well: http://www.opm.gov/policy-data-oversight/hiring-authorities/competitive-hiring/deo_handbook.pdf
Also, please check with your agency as how to handle FOIA requests when the examining material at issue is in litigation.
In short, OPM does not offer specific guidance to agencies on administering additional assessments after a certificate is issued. Please check your agency's policies on administering post-certification assessments because policies may vary by agency.
To be placed on a Certificate of Eligibles, applicants must have already been screened for minimum qualifications and been assessed for critical competencies established for the position. Once a certificate is issued, the selecting official may select from any of the candidates in the highest quality category, with the exception that a non-veteran may not be selected over a veteran without an approved pass over.
However, one "post-cert" option for selecting officials is to conduct a "selecting official's interview," which may be used to verify candidates' qualifications for a job after they have been rated using other assessment methods, but prior to making a hiring decision (refer to the introduction of OPM's Structured Interview Guide, http://www.opm.gov/policy-data-oversight/assessment-and-selection/structured-interviews/guide.pdf). In a selecting official's interview, candidates' responses are not typically scored.
OPM encourages agencies to consider the use of structured interviews. When designed appropriately and used correctly, they have the ability to predict the future job performance of applicants with relatively low adverse impact on minority groups compared to other assessment tools. The structured interview is among the most valid assessment tools available.
For more information regarding structured interviews, please visit the Structured Interviews page of OPM's Assessment and Selection website (http://www.opm.gov/policy-data-oversight/assessment-and-selection/structured-interviews/) and the Structured Interview Guide (http://www.opm.gov/policy-data-oversight/assessment-and-selection/structured-interviews/guide.pdf).
Another good source for more information on structured interviews is the U.S. Merit Systems Protection Board report, "The Federal Selection Interview: Unrealized Potential," (http://www.mspb.gov/netsearch/viewdocs.aspx?docnumber=253635&version=253922&application=ACROBAT).
Response distortion (whether high or low) has long been a challenge with self-report occupational questionnaires. Employing the following suggestions may help:
Research has shown that warning applicants in advance that their responses are subject to verification can be a powerful incentive to answer honestly.
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