The Clean Air Act. The Clean Water Act. The National Environmental Policy Act. These and most of our nation’s other foundational environmental laws were passed decades ago – and they have started to show their age. The Clean Air Act, for instance, was written to cut air pollution, not to drive the whole-of-economy response that the climate crisis now warrants. The Energy Policy and Conservation Act of 1975 was designed to make cars more efficient in a pre-electric vehicle era, and now puts the Department of Transportation in the awkward position of setting fuel economy standards in an era when more and more cars don’t burn gas.

Trying to manage today’s problems with yesterday’s laws results in government by kludge. Legacy regulatory architecture has foundered under a patchwork of legislative amendments and administrative procedures designed to bridge the gap between past needs and present realities. Meanwhile, Congressional dysfunction has made purpose-built updates exceptionally difficult to land. The Inflation Reduction Act, for example, was mostly designed to move money rather than rethink foundational statutes or regulatory processes – because those rethinks couldn’t make it past the filibuster.

As the efficacy of environmental laws has waned, so has their durability. What was once a broadly shared goal – protecting Americans from environmental harm – is now a political football, with rules that whipsaw back and forth depending on who’s in charge. 

The second Trump Administration launched the biggest environmental deregulatory campaign in history against this backdrop. But that campaign, coupled with massive reductions in the federal civil service and a suite of landmark court decisions (including Loper Bright) about how federal agencies regulate, risks pushing U.S. regulatory architecture past the point of sensible and much-needed reform and into a state of complete disrepair.

Dismantling old systems has proven surprisingly easy. Building what comes next will be harder. And the work must begin now. 

It is time to articulate a long-term vision for a government that can actually deliver in an ever-more complex society. The Federation of American Scientists (FAS) is meeting this moment by launching an ambitious new project to reimagine the U.S. environmental regulatory state, drawing ideas from across ideological lines.

The Beginning of a New Era

Fear of the risks of systemic change often prevent people from entertaining change in earnest. Think of the years of U.S. squabbles over how or whether to reform permitting and environmental review, while other countries simply raced ahead to build clean energy projects and establish dominance in the new world economy. Systemic stagnation, however, comes with its own consequences. 

The Inflation Reduction Act (IRA) and the Infrastructure Investment and Jobs Act (IIJA) are a case in point when it comes to climate and the environment. Together, these two pieces of legislation represented the largest global investment in the promise of a healthier, more sustainable, and, yes, cheaper future. Unfortunately, as proponents of the “abundance” paradigm and others have observed, rollout was hampered by inefficient processes and outdated laws. Implementing the IRA and the IIJA via old systems, in short, was like trying to funnel an ocean through a garden hose – and as a result, most Americans experienced only a trickle of real-world impact.

Similar barriers are constraining state progress. For example, the way we govern and pay for electricity has not kept pace with a rapidly changing energy landscape – meaning that the United States risks ceding leadership on energy technologies critical to national security, economic competitiveness, and combating climate change.

But we are perhaps now entering a new era. The United States appears to be on the edge of real political realignments, with transpartisan stakes around the core role of government in economic development that do not match up neatly to current coalitions. This realignment presents a crucial opportunity to catalyze a new era of climate, environmental, and democratic progress.

FAS will leverage this opportunity by providing a forum for debate and engagement on different facets of climate and environmental governance, a platform to amplify insights, and the capacity to drive forward solutions. Examples of topics ripe for exploration include:

• Balancing agility and accountability. As observed, regulatory approaches of the past have struggled to address the interconnected, quickly evolving nature of climate and environmental challenges. At the same time, mechanisms for ensuring accountability have been disrupted by an evolving legal landscape and increasingly muscular executive. There is a need to imagine and test new systems designed to move quickly but responsibly on climate and environmental issues. 
• Complementing traditional regulation through novel strategies. There is growing interest in using novel financial, contractual, and other strategies as a complement to regulation for driving climate and environmental progress. There is considerable room to go deeper in this space, identifying both the power of these strategies and their limits. 
• Rethinking stakeholder engagement. The effectiveness of regulation depends on its ability to serve diverse stakeholder needs while advancing environmental goals. Public comment and other pipelines for engaging stakeholders and integrating external perspectives and expertise into regulations have been disrupted by technologies such as AI, while the relationship between regulated entities and their regulators has become increasingly adversarial. There is a need to examine synergies and tradeoffs between centering stakeholders and centering outcomes in regulatory processes, as well as examine how stakeholder engagement could be improved to better ensure regulations that are informed, feasible, durable, and distributively fair. 

In working through topics like these, FAS seeks to lay out a positive vision of regulatory reconstruction that is substantively superior to either haphazard destruction or incremental change. Our vision is nothing less than to usher in a new paradigm of climate and environmental governance: one that secures a livable world while reinforcing democratic stability, through systems that truly deliver for America. 

We will center our focus on the federal government given its important role in climate and environmental issues. However, states and localities do a lot of the work of a federated government day-to-day. We recognize that federal cures are unlikely to fully alleviate the symptoms that Americans are experiencing every day, from decaying infrastructure to housing shortages. We are committed to ensuring that solutions are appropriately matched to the root cause of state capacity problems and that federal climate and environmental regulatory regimes are designed to support successful cooperation with local governments and implementation partners. 

FAS is no stranger to ambitious endeavors like these. Since our founding in 1945, we have been committed to tackling the major science policy issues that reverberate through American life. This new FAS workstream will be embedded across our Climate and Environment, Clean Energy, and Government Capacity portfolios. We have already begun engaging and activating the diverse community of scholars, experts, and leaders laying the intellectual groundwork to develop compelling answers to urgent questions surrounding the climate regulatory state, against the backdrop of a broader state capacity movement. True to our nonpartisan commitment, we will build this work on a foundation of cross-ideological curiosity and play on the tension points in existing coalitions that strike us all as most productive.

We invite you to join us in conversation and collaboration. If you want to get involved, contact Zoë Brouns (zbrouns@fas.org).

Decision to Sunset IRS’ Direct File Previews Worse Taxpayer Experience in 2026

Yesterday, tens of thousands of taxpayers filed their returns using IRS Direct File, the agency’s new free, public, online tax filing service now in its second filing season. They joined hundreds of thousands who have used the service, and who have been nearly-unanimously thrilled to fulfill their tax obligations easily and directly. It seems we have finally done the impossible: make Tax Day anything but the most dreaded day of the year. At least we did.

Today, the Associated Press reported that the Treasury Department will discontinue the program. “Cutting costs and saving money for families were just empty campaign promises,” says Adam Ruben, a vice president at the Economic Security Project of the administration’s decision to end the program.

I was an original architect of Direct File from 2021 until just a few months ago, and got to see its impact on government and on taxpayers directly. Make no mistake: Direct File is a shining example of government capacity and government efficiency. By providing a critical government service for free, and helping taxpayers file more timely and more accurate returns, it is projected to eventually generate $11 billion in net savings for taxpayers every year. 

The dismantling of the program is not, at all, a step toward government efficiency. This is a move that will degrade our government services, incurring massive costs for people trying to file their taxes, further damaging the capacity of the nation’s revenue-collection agency, and making our institutions less robust and less capable.

It’s no secret: Americans do not love tax season.

The Direct File story started for me, personally, when I moved back to the U.S. after living in London for 9 years. I had already spent years working in digital services: I had built the first in-house digital team at the brand-new Consumer Financial Protection Bureau in 2010, and then worked on multiple projects in London, culminating in helping the London Borough of Camden digitally transform its entire operations practically overnight during the pandemic. I moved back to the States and joined the US Digital Service to help rebuild after Covid, bringing the lessons I had learned from the UK. My first project at USDS was leading our efforts on Child Tax Credit expansion — ensuring that families across the country could access the enormous new child benefit that was created in the March 2021 American Rescue Plan.

But there was a problem: families naturally had to file a tax return to claim their tax credit. And I was pretty surprised to learn that our government still did not, in 2021, offer a free, online way to file your taxes directly with the government. Around the world, tax collection is seen as an inherent government function and, as such, tax filing is a service that the government offers free of charge. I thought we should too, especially if we were going to make such critical social supports contingent on it during a crisis. 

Instead, in the U.S., we relied on a confusing — and sometimes costly — mishmash of private offerings and support from non-profits designed to ensure most people could maybe, sort of, file a return for free if they needed to. It made the barrier to entry high, both in terms of trying to navigate how to simply file a return, nevermind to do so without cost. Tax filing, I thought, is a core function of government, and making it free and easy to use would cut through this waste and deliver for the American people.

I wasn’t the only one who thought this way. By 2021, a free public filing service was already the “white whale” of civic tech; everyone knew this was the critical government function to bring into a modern digital product, and yet it was too big, too daunting, too much of a change. Honestly, never in a million years did I think we would pull it off, either. The IRS, for all its genuine accomplishments in the face of constantly shrinking budgets and aging technology, had no real experience launching an enormous, high-stakes tech product designed to simplify the mind-numbing complexities of an American tax return. This was government capacity we would have to create.

But, we did. Since Direct File launched as a pilot in March 2023, hundreds of thousands of people have now filed their returns with it, to stunning results. In its pilot year, 86% of users said that Direct File increased their trust in the IRS. In its second year, it is winning awards and killing it with users, with a Net Promoter Score in the +80s, up from +74 last year (Apple’s, which is considered astronomically high, is +72). Direct File is a wildly successful government startup. Not only that, but the IRS now has its own in-house capacity to continue building awesome digital experiences — capacity that could have gone toward cost savings and experience improvements in all matter of IRS operations. This is all capacity, needless to say, that has gone away, all in the name of “efficiency.”

The impact for taxpayers from Direct File alone are, and would have been, enormous. In the U.S., the IRS estimates that it takes the average person over 9 hours and costs $160 to file your taxes each year. We even heard anecdotally from Direct File users who had paid thousands of dollars to do what Direct File does for free. There also remain millions of households who, every year, don’t file their returns at all, leaving sizable refunds on the table, because they can’t navigate the confusing tax filing “offers” advertising tax filing services. These households would have stood to finally access billions of dollars they leave unclaimed every year.

Not only are taxpayers saving these hundreds of dollars, they also feel newly empowered to interact with their government and take control of their tax situations. For decades, Americans have been told that they are not smart enough to do your own taxes; only highly-paid specialists that you have to pay for, can do it for you. Direct File stripped away the noise and showed taxpayers that filing can be simple and easy. The valuable trust this creates in government and public institutions is impossible to quantify.

Finally, there is the issue of data privacy and security. Taxpayers filing via private services must expose their most sensitive personal and financial information to third parties that monetize their data, sometimes illegally and without taxpayers’ consent. Without a public filing option, taxpayers are more or less required to sacrifice their privacy and the security of their data just to fulfill their filing obligations. Direct File gives taxpayers the option to protect their data and provide it straight to the tax agency, without a middleman.

All this — the in-house capacity to modernize the IRS, billions of dollars in cost savings, an empowered public — is what is cancelled today. But they have it exactly backwards. It’s a functional, high-quality government that’s efficient. The chaos they are sowing is anything but.

Federal Advisory Committees (FACs) are the single point of entry for the American public to provide consensus-based advice and recommendations to the federal government. These Advisory Committees are composed of experts from various fields who serve as Special Government Employees (SGEs), attending committee meetings, writing reports, and voting on potential government actions.

Advisory Committees are needed for the federal decision-making process because they provide additional expertise and in-depth knowledge for the Agency on complex topics, aid the government in gathering information from the public, and allow the public the opportunity to participate in meetings about the Agency’s activities. As currently organized, FACs are not equipped to provide the best evidence-based advice. This is because FACs do not meet transparency requirements set forth by GAO: making pertinent decisions during public meetings, reporting inaccurate cost data, providing  official meeting documents publicly available online, and more. FACs have also experienced difficulty with recruiting and retaining top talent to assist with decision making. For these reasons, it is critical that FACs are reformed and equipped with the necessary tools to continue providing the government with the best evidence-based advice. Specifically, advice as it relates to issues such as 1) decreasing the burden of hiring special government employees 2) simplifying the financial disclosure process 3) increasing understanding of reporting requirements and conflict of interest processes 4) expanding training for Advisory Committee members 5) broadening  the roles of Committee chairs and designated federal officials 6) increasing public awareness of Advisory Committee roles 7) engaging the public outside of official meetings 8) standardizing representation from Committee representatives 9) ensuring that Advisory Committees are meeting per their charters and 10) bolstering Agency budgets for critical Advisory Committee issues. 

Challenge and Opportunity

Protecting the health and safety of the American public and ensuring that the public has the opportunity to participate in the federal decision-making process is crucial. We must evaluate the operations and activities of federal agencies that require the government to solicit evidence-based advice and feedback from various experts through the use of federal Advisory Committees (FACs). These Committees are instrumental in facilitating transparent and collaborative deliberation between the federal government, the advisory body, and the American public and cannot be done through the use of any other mechanism. Advisory Committee recommendations are integral to strengthening public trust and reinforcing the credibility of federal agencies. Nonetheless, public trust in government has been waning and efforts should be made to increase public trust. Public trust is known as the pillar of democracy and fosters trust between parties, particularly when one party is external to the federal government. Therefore, the use of Advisory Committees, when appropriately used, can assist with increasing public trust and ensuring compliance with the law. 

There have also been many success stories demonstrating the benefits of Advisory Committees. When Advisory Committees are appropriately staffed based on their charge, they can decrease the workload of federal employees, assist with developing policies for some of our most challenging issues, involve the public in the decision-making process, and more. However, the state of Advisory Committees and the need for reform have been under question, and even more so as we transition to a new administration. Advisory Committees have contributed to the improvement in the quality of life for some Americans through scientific advice, as well as the monitoring of cybersecurity. For example, an FDA Advisory Committee reviewed data and saw promising results for the treatment of sickle cell disease (SCD) which has been a debilitating disease with limited treatment for years. The Committee voted in favor of gene therapy drugs Casgevy and Lyfgenia which were the first to be approved by the FDA for SCD. 

Under the first Trump administration, Executive Order (EO) 13875 resulted in a significant decrease in the number of federal advisory meetings. This  limited agencies’ ability to convene external advisors. Federal science advisory committees met less during this administration than any prior administration, met less than what was required from their charter, disbanded long standing Advisory Committees, and scientists receiving agency grants were barred from serving on Advisory Committees. Federal Advisory Committee membership also decreased by 14%, demonstrating the issue of recruiting and retaining top talent. The disbandment of Advisory Committees, exclusion of key scientific external experts from Advisory Committees, and burdensome procedures can potentially trigger  severe consequences that affect the health and safety of Americans. 

Going into a second Trump administration, it is imperative that Advisory Committees have the opportunity to assist federal agencies with the evidence-based advice needed to make critical decisions that affect the American public. The suggested reforms that follow can work to improve the overall operations of Advisory Committees while still providing the government with necessary evidence-based advice. With successful implementation of the following recommendations, the federal government will be able to reduce administrative burden on staff through the recruitment, onboarding, and conflict of interest processes. 

The U.S. Open Government Initiative encourages the promotion and participation of public and community engagement in  governmental affairs. However, individual Agencies can and should do more to engage the public. This policy memo identifies several areas of potential reform for Advisory Committees and aims to provide recommendations for improving the overall process without compromising Agency or Advisory Committee membership integrity. 

Plan of Action

The proposed plan of action identifies several policy recommendations to reform the federal Advisory Committee (Advisory Committee) process, improving both operations and efficiency. Successful implementation of these policies will  1) improve the Advisory Committee member experience, 2) increase transparency in federal government decision-making, and 3) bolster trust between the federal government, its Advisory Committees, and the public. 

Streamline Joining Advisory Committees

Recommendation 1. Decrease the burden of hiring special government employees in an effort to (1) reduce the administrative burden for the Agency and (2) encourage Advisory Committee members, who are also known as special government employees (SGEs), to continue providing the best evidence-based advice to the federal government through reduced onerous procedures

The Ethics in Government Act of 1978 and Executive Order 12674 lists OGE-450 reporting as the required public financial disclosure for all executive branch and special government employees. This Act provides the Office of Government Ethics (OGE) the authority to implement and regulate a financial disclosure system for executive branch and special government employees whose duties have “heightened risk of potential or actual conflicts of interest”. Nonetheless, the reporting process becomes onerous when Advisory Committee members have to complete the OGE-450 before every meeting even if their information remains unchanged. This presents a challenge for Advisory Committee members who wish to continue serving, but are burdened by time constraints. The process also burdens federal staff who manage the financial disclosure system. 

Policy Pathway 1. Increase funding for enhanced federal staffing capacity to undertake excessive administrative duties for financial reporting.

Policy Pathway 2. All federal agencies that deploy Advisory Committees can conduct a review of the current OGC-450 process, budget support for this process, and work to develop an electronic process that will eliminate the use of forms and allow participants to select dropdown options indicating if their financial interests have changed.  

Recommendation 2. Create and use public platforms such as OpenPayments by CMS to (1) aid in simplifying the financial disclosure reporting process and (2) increase transparency for disclosure procedures

Federal agencies should create a financial disclosure platform that streamlines the process and allows Advisory Committee members to submit their disclosures and easily make updates. This system should also be created to monitor and compare financial conflicts. In addition, agencies that utilize the expertise of Advisory Committees for drugs and devices should identify additional ways in which they can promote financial transparency. These agencies can use Open Payments, a system operated by Centers for Medicare & Medicaid Services (CMS), to “promote a more financially transparent and accountable healthcare system”. The Open Payments system makes payments from medical and drug device companies to individuals, healthcare providers, and teaching hospitals accessible to the public. If for any reason financial disclosure forms are called into question, the Open Payments platform can act as a check and balance in identifying any potential financial interests of Advisory Committee members. Further steps that can be taken to simplify the financial disclosure process would be to utilize conflict of interest software such as Ethico which is a comprehensive tool that allows for customizable disclosure forms, disclosure analytics for comparisons, and process automation.   

Policy Pathway. The Office of Government Ethics should require all federal agencies that operate Advisory Committees to develop their own financial disclosure system and include a second step in the financial disclosure reporting process as due diligence, which includes reviewing the Open Payments by CMS system for potential financial conflicts or deploying conflict of interest monitoring software to streamline the process.

Streamline Participation in an Advisory Committee

Recommendation 3. Increase understanding of annual reporting requirements for conflict of interest (COI)

Agencies should develop guidance that explicitly states the roles of Ethics Officers, also known as Designated Agency Ethics Officials (DAEO), within the federal government. Understanding the roles and responsibilities of Advisory Committee members and the public will help reduce the spread of misinformation regarding the purpose of Advisory Committees. In addition, agencies should be encouraged by the Office of Government Ethics to develop guidance that indicates the criteria for inclusion or exclusion of participation in Committee meetings. Currently, there is no public guidance that states what types of conflicts of interests are granted waivers for participation. Full disclosure of selection and approval criteria will improve transparency with the public and draw clear delineations between how Agencies determine who is eligible to participate. 

Policy Pathway. Develop conflict of interest (COI) and financial disclosure guidance specifically for SGEs that states under what circumstances SGEs are allowed to receive waivers for participation in Advisory Committee meetings.

Recommendation 4. Expand training for Advisory Committee members to include (1) ethics and (2) criteria for making good recommendations to policymakers

Training should be expanded for all federal Advisory Committee members to include ethics training which details the role of Designated Agency Ethics Officials, rules and regulations for financial interest disclosures, and criteria for making evidence-based recommendations to policymakers. Training for incoming Advisory Committee members ensures that all members have the same knowledge base and can effectively contribute to the evidence-based recommendations process.

Policy Pathway. Agencies should collaborate with the OGE and Agency Heads to develop comprehensive training programs for all incoming Advisory Committee members to ensure an understanding of ethics as contributing members, best practices for providing evidence-based recommendations, and other pertinent areas that are deemed essential to the Advisory Committee process.

Leverage Advisory Committee Membership

Recommendation 5. Uplifting roles of the Committee Chairs and Designated Federal Officials

Expanding the roles of Committee Chairs and Designated Federal Officers (DFOs) may assist federal Agencies with recruiting and retaining top talent and maximizing the Committee’s ability to stay abreast of critical public concerns. Considering the fact that the General Services Administration has to be consulted for the formation of new Committees, renewal, or alteration of Committees, they can be instrumental in this change.

Policy Pathway. The General Services Administration (GSA) should encourage federal Agencies to collaborate with Committee Chairs and DFOs to recruit permanent and ad hoc Committee members who may have broad network reach and community ties that will bolster trust amongst Committees and the public. 

Recommendation 6. Clarify intended roles for Advisory Committee members and the public

There are misconceptions among the public and Advisory Committee members about Advisory Committee roles and responsibilities. There is also ambiguity regarding the types of Advisory Committee roles such as ad hoc members, consulting, providing feedback for policies, or making recommendations. 

Policy Pathway. GSA should encourage federal Agencies to develop guidance that delineates the differences between permanent and temporary Advisory Committee members, as well as their roles and responsibilities depending on if they’re providing feedback for policies or providing recommendations for policy decision-making.

Recommendation 7. Utilize and engage expertise and the public outside of public meetings

In an effort to continue receiving the best evidence-based advice, federal Agencies should develop alternate ways to receive advice outside of public Committee meetings. Allowing additional opportunities for engagement and feedback from Committee experts or the public will allow Agencies to expand their knowledge base and gather information from communities who their decisions will affect.

Policy Pathway. The General Services Administration should encourage federal Agencies to create opportunities outside of scheduled Advisory Committee meetings to engage Committee members and the public on areas of concern and interest as one form of engagement. 

Recommendation 8. Standardize representation from Committee representatives (i.e., industry), as well as representation limits

The Federal Advisory Committee Act (FACA) does not specify the types of expertise that should be represented on all federal Advisory Committees, but allows for many types of expertise. Incorporating various sets of expertise that are representative of the American public will ensure the government is receiving the most accurate, innovative, and evidence-based recommendations for issues and products that affect Americans. 

Policy Pathway. Congress should include standardized language in the FACA that states all federal Advisory Committees should include various sets of expertise depending on their charge. This change should then be enforced by the GSA.

Support a Vibrant and Functioning Advisory Committee System

Recommendation 9. Decrease the burden to creating an Advisory Committee and make sure Advisory Committees are meeting per their charters

The process to establish an Advisory Committee should be simplified in an effort to curtail the amount of onerous processes that lead to a delay in the government receiving evidence based advice.

Advisory Committee charters state the purpose of Advisory Committees, their duties, and all aspirational aspects. These charters are developed by agency staff or DFOs with consultation from their agency Committee Management Office. Charters are needed to forge the path for all FACs.

Policy Pathway. Designated Federal Officers (DFOs) within federal agencies should work with their Agency head to review and modify steps to establishing FACs. Eliminate the requirement for FACs to require consultation and/or approval from GSA for the formation, renewal, or alteration of Advisory Committees.

Recommendation 10. Bolster agency budgets to support FACs on critical issues where regular engagement and trust building with the public is essential for good policy

Federal Advisory Committees are an essential component to receive evidence-based recommendations that will help guide decisions at all stages of the policy process. These Advisory Committees are oftentimes the single entry point external experts and the public have to comment and participate in the decision-making process. However, FACs take considerable resources to operate depending on the frequency of meetings, the number of Advisory Committee members, and supporting FDA staff. Without proper appropriations, they have a diminished ability to recruit and retain top talent for Advisory Committees. The Government Accountability Office (GAO) reported that in 2019, approximately $373 million dollars was spent to operate a total of 960 federal Advisory Committees. Some Agencies have experienced a decrease in the number of Advisory Committee convenings. Individual Agency heads should conduct a budget review of average operating and projected costs and develop proposals for increased funding to submit to the Appropriations Committee.  

Policy Pathway. Congress should consider increasing appropriations to support FACs so they can continue to enhance federal decision-making, improve public policy, boost public credibility, and Agency morale. 

Conclusion

Advisory Committees are necessary to the federal evidence-based decision-making ecosystem. Enlisting the advice and recommendations of experts, while also including input from the American public, allows the government to continue making decisions that will truly benefit its constituents. Nonetheless, there are areas of FACs that can be improved to ensure it continues to be a participatory, evidence-based process. Additional funding is needed to compensate the appropriate Agency staff for Committee support, provide potential incentives for experts who are volunteering their time, and finance other expenditures.

Frequently Asked Questions

How will Federal Advisory Committees (Advisory Committees) increase government efficiency?

With reform of Advisory Committees, the process for receiving evidence-based advice will be streamlined, allowing the government to receive this advice in a faster and less burdensome manner. Reform will be implemented by reducing the administrative burden for federal employees through the streamlining of recruitment, financial disclosure, and reporting processes.

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The administration should create a federal center of excellence for state and local artificial intelligence (AI) procurement and use—a hub for expertise and resources on public sector AI procurement and use at the state, local, tribal, and territorial (SLTT) government levels. The center could be created by expanding the General Services Administration’s (GSA) existing Artificial Intelligence Center of Excellence (AI CoE). As new waves of AI technologies enter the market, shifting both practice and policy, such a center of excellence would help bridge the gap between existing federal resources on responsible AI and the specific, grounded challenges that individual agencies face. In the decades ahead, new AI technologies will touch an expanding breadth of government services—including public health, child welfare, and housing—vital to the wellbeing of the American people. An AI CoE federal center would equip public sector agencies with sustainable expertise and set a consistent standard for practicing responsible AI procurement and use. This resource ensures that AI truly enhances services, protects the public interest, and builds public trust in AI-integrated state and local government services. 

Challenge and Opportunity 

State, local, tribal, and territorial (SLTT) governments provide services that are critical to the welfare of our society. Among these: providing housing, child support, healthcare, credit lending, and teaching. SLTT governments are increasingly interested in using AI to assist with providing these services. However, they face immense challenges in responsibly procuring and using new AI technologies. While grappling with limited technical expertise and budget constraints, SLTT government agencies considering or deploying AI must navigate data privacy concerns, anticipate and mitigate biased model outputs, ensure model outputs are interpretable to workers, and comply with sector-specific regulatory requirements, among other responsibilities. 

The emergence of foundation models (large AI systems adaptable to many different tasks) for public sector use exacerbates these existing challenges. Technology companies are now rapidly developing new generative AI services tailored towards public sector organizations. For example, earlier this year, Microsoft announced that Azure OpenAI Service would be newly added to Azure Government—a set of AI services that target government customers. These types of services are not specifically created for public sector applications and use contexts, but instead are meant to serve as a foundation for developing specific applications. 

For SLTT government agencies, these generative AI services blur the line between procurement and development: Beyond procuring specific AI services, we anticipate that agencies will increasingly be tasked with the responsible use of general AI services to develop specific AI applications. Moreover, recent AI regulations suggest that responsibility and liability for the use and impacts of procured AI technologies will be shared by the public sector agency that deploys them, rather than just resting with the vendor supplying them.

SLTT agencies must be well-equipped with responsible procurement practices and accountability mechanisms pivotal to moving forward given the shifts across products, practice, and policy. Federal agencies have started to provide guidelines for responsible AI procurement (e.g., Executive Order 13960, OMB-M-21-06, NIST RMF). But research shows that SLTT governments need additional support to apply these resources.: Whereas existing federal resources provide high-level, general guidance, SLTT government agencies must navigate a host of challenges that are context-specific (e.g., specific to regional laws, agency practices, etc.). SLTT government agency leaders have voiced a need for individualized support in accounting for these context-specific considerations when navigating procurement decisions. 

Today, private companies are promising state and local government agencies that using their AI services can transform the public sector. They describe diverse potential applications, from supporting complex decision-making to automating administrative tasks. However, there is minimal evidence that these new AI technologies can improve the quality and efficiency of public services. There is evidence, on the other hand, that AI in public services can have unintended consequences, and when these technologies go wrong, they often worsen the problems they are aimed at solving. For example, by increasing disparities in decision-making when attempting to reduce them. 

Challenges to responsible technology procurement follow a historical trend: Government technology has frequently been critiqued for failures in the past decades. Because public services such as healthcare, social work, and credit lending have such high stakes, failures in these areas can have far-reaching consequences. They also entail significant financial costs, with millions of dollars wasted on technologies that ultimately get abandoned. Even when subpar solutions remain in use, agency staff may be forced to work with them for extended periods despite their poor performance.

The new administration is presented with a critical opportunity to redirect these trends. Training each relevant individual within SLTT government agencies, or hiring new experts within each agency, is not cost- or resource-effective. Without appropriate training and support from the federal government, AI adoption is likely to be concentrated in well-resourced SLTT agencies, leaving others with fewer resources (and potentially more low income communities) behind. This could lead to disparate AI adoption and practices among SLTT agencies, further exacerbating existing inequalities. The administration urgently needs a plan that supports SLTT agencies in learning how to handle responsible AI procurement and use–to develop sustainable knowledge about how to navigate these processes over time—without requiring that each relevant individual in the public sector is trained. This plan also needs to ensure that, over time, the public sector workforce is transformed in their ability to navigate complicated AI procurement processes and relationships—without requiring constant retraining of new waves of workforces. 

In the context of federal and SLTT governments, a federal center of excellence for state and local AI procurement would accomplish these goals through a “hub and spoke” model. This center of excellence would serve as the “hub” that houses a small number of selected experts from academia, non-profit organizations, and government. These experts would then train “spokes”—existing state and local public sector agency workers—in navigating responsible procurement practices. To support public sector agencies in learning from each others’ practices and challenges, this federal center of excellence could additionally create communication channels for information- and resource-sharing across the state and local agencies. 

Procured AI technologies in government will serve as the backbone of local public services for decades to come. Upskilling government agencies to make smart decisions about which AI technologies to procure (and which are best avoided) would not only protect the public from harmful AI systems but would also save the government money by decreasing the likelihood of adopting expensive AI technologies that end up getting dropped. 

Plan of Action 

A federal center of excellence for state and local AI procurement would ensure that procured AI technologies are responsibly selected and used to serve as a strong and reliable backbone for public sector services. This federal center of excellence can support both intra-agency and inter-agency capacity-building and learning about AI procurement and use—that is, mechanisms to support expertise development within a given public sector agency and between multiple public sector agencies. This federal center of excellence would not be deliberative (i.e., SLTT governments would receive guidance and support but would not have to seek approval on their practices). Rather, the goal would be to upskill SLTT agencies so they are better equipped to navigate their own AI procurement and use endeavors. 

To upskill SLTT agencies through inter-agency capacity-building, the federal center of excellence would house experts in relevant domain areas (e.g., responsible AI, public interest technology, and related topics). Fellows would work with cohorts of public sector agencies to provide training and consultation services. These fellows, who would come from government, academia, and civil society, would build on their existing expertise and experiences with responsible AI procurement, integrating new considerations proposed by federal standards for responsible AI (e.g., Executive Order 13960, OMB-M-21-06, NIST RMF). The fellows would serve as advisors to help operationalize these guidelines into practical steps and strategies, helping to set a consistent bar for responsible AI procurement and use practices along the way. 

Cohorts of SLTT government agency workers, including existing agency leaders, data officers, and procurement experts, would work together with an assigned advisor to receive consultation and training support on specific tasks that their agency is currently facing. For example, for agencies or programs with low AI maturity or familiarity (e.g., departments that are beginning to explore the adoption of new AI tools), the center of excellence can help navigate the procurement decision-making process, help them understand their agency-specific technology needs, draft procurement contracts, select amongst proposals, and negotiate plans for maintenance. For agencies and programs with high AI maturity or familiarity, the advisor can train the programs about unexpected AI behaviors and mitigation strategies, when this arises. These communication pathways would allow federal agencies to better understand the challenges state and local governments face in AI procurement and maintenance, which can help seed ideas for improving existing resources and create new resources for AI procurement support.

To scaffold intra-agency capacity-building, the center of excellence can build the foundations for cross-agency knowledge-sharing. In particular, it would include a communication platform and an online hub of procurement resources, both shared amongst agencies. The communication platform would allow state and local government agency leaders who are navigating AI procurement to share challenges, learned lessons, and tacit knowledge to support each other. The online hub of resources can be collected by the center of excellence and SLTT government agencies. Through the online hub, agencies can upload and learn about new responsible AI resources and toolkits (e.g., such as those created by government and the research community), as well as examples of procurement contracts that agencies themselves used. 

To implement this vision, the new administration should expand the U.S. General Services Administration’s (GSA) existing Artificial Intelligence Center of Excellence (AI CoE), which provides resources and infrastructural support for AI adoption across the federal government. We propose expanding this existing AI CoE to include the components of our proposed center of excellence for state and local AI procurement and use. This would direct support towards SLTT government agencies—which are currently unaccounted for in the existing AI CoE—specifically via our proposed capacity-building model.

Over the next 12 months, the goals of expanding the AI CoE would be three-fold:

1. Develop the core components of our proposed center of excellence within the AI CoE. 

• Recruit a core set of fellows with expertise in responsible AI, public interest technology, and related topics from government, academia, and civil society for a 1-2 year placement; 
• Develop a centralized onboarding and training program for the fellows to set standards for responsible AI procurement and use guidelines and goals; 
• Create a research strategy to streamline documentation of SLTT agencies’ on-the-ground practices and challenges for procuring new AI technologies, which could help prepare future fellows. 

2. Launch collaborations for the first sample of SLTT government agencies. Focus on building a path for successful collaborations: 

• Identify a small set of state and local government agencies who desire federal support in navigating AI procurement and use (e.g., deciding which AI use cases to adopt, how to effectively evaluate AI deployments through time, what organizational policies to create to help govern AI use); 
• Ensure there is a clear communication pathway between the agency and their assigned fellow; 
• Have each fellow and agency pair create a customized plan of action to ensure the agency is upskilled in their ability to independently navigate AI procurement and use with time. 

3. Build a path for our proposed center of excellence to grow and gain experience. If the first few collaborations show strong reviews, design a scaling strategy that will: 

• Incorporate the center of excellence’s core budget into future budget planning;
• Identify additional fellows for the program; 
• Roll out the program to additional state and local government agencies. 

Conclusion

Expanding the existing AI CoE to include our proposed federal center of excellence for AI procurement and use can help ensure that SLTT governments are equipped to make informed, responsible decisions about integrating AI technologies into public services. This body would provide necessary guidance and training, helping to bridge the gap between high-level federal resources and the context-specific needs of SLTT agencies. By fostering both intra-agency and inter-agency capacity-building for responsible AI procurement and use, this approach builds sustainable expertise, promotes equitable AI adoption, and protects public interest. This ensures that AI enhances—rather than harms—the efficiency and quality of public services. As new waves of AI technologies continue to enter the public sector, touching a breadth of services critical to the welfare of the American people, this center of excellence will help maintain high standards for responsible public sector AI for decades to come.

This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.

PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.

Frequently Asked Questions

What is existing guidance for responsible SLTT procurement and use of AI technologies?

Federal agencies have published numerous resources to support responsible AI procurement, including the Executive Order 13960, OMB-M-21-06, NIST RMF. Some of these resources provide guidance on responsible AI development in organizations broadly, across the public, private, and non-profit sectors. For example, the NIST RMF provides organizations with guidelines to identify, assess, and manage risks in AI systems to promote the deployment of more trustworthy and fair AI systems. Others focus on public sector AI applications. For instance, the OMB Memorandum published by the Office of Management and Budget describes strategies for federal agencies to follow responsible AI procurement and use practices.

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Why a federal center? Can’t SLTT governments do this on their own?

Research describes how these forms of resources often require additional skills and knowledge that make it challenging for agencies to effectively use on their own. A federal center of excellence for state and local AI procurement could help agencies learn to use these resources. Adapting these guidelines to specific SLTT agency contexts necessitates a careful task of interpretation which may, in turn, require specialized expertise or resources. The creation of this federal center of excellence to guide responsible SLTT procurement on-the-ground can help bridge this critical gap. Fellows in the center of excellence and SLTT procurement agencies can build on this existing pool of guidance to build a strong theoretical foundation to guide their practices.

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How has this “hub and spoke” model been used before?

The hub and spoke model has been used across a range of applications to support efficient management of resources and services. For instance, in healthcare, providers have used the hub and spoke model to organize their network of services; specialized, intensive services would be located in “hub” healthcare establishments whereas secondary services would be provided in “spoke” establishments, allowing for more efficient and accessible healthcare services. Similar organizational networks have been followed in transportation, retail, and cybersecurity. Microsoft follows a hub and spoke model to govern responsible AI practices and disseminate relevant resources. Microsoft has a single centralized “hub” within the company that houses responsible AI experts—those with expertise on the implementation of the company’s responsible AI goals. These responsible AI experts then train “spokes”—workers residing in product and sales teams across the company, who learn about best practices and support their team in implementing them.

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Who would be the experts selected as fellows by the center of excellence? What kind of training would they receive?

During the training, experts would form a stronger foundation for (1) on-the-ground challenges and practices that public sector agencies grapple with when developing, procuring, and using AI technologies and (2) existing AI procurement and use guidelines provided by federal agencies. The content of the training would be taken from syntheses of prior research on public sector AI procurement and use challenges, as well as existing federal resources available to guide responsible AI development. For example, prior research has explored public sector challenges to supporting algorithmic fairness and accountability and responsible AI design and adoption decisions, amongst other topics.

The experts who would serve as fellows for the federal center of excellence would be individuals with expertise and experience studying the impacts of AI technologies and designing interventions to support more responsible AI development, procurement, and use. Given the interdisciplinary nature of the expertise required for the role, individuals should have an applied, socio-technical background on responsible AI practices, ideally (but not necessarily) for the public sector. The individual would be expected to have the skills needed to share emerging responsible AI practices, strategies, and tacit knowledge with public sector employees developing or procuring AI technologies. This covers a broad range of potential backgrounds.

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What are some examples of the skills or competencies fellows might bring to the Center?

For example, a professor in academia who studies how to develop public sector AI systems that are more fair and aligned with community needs may be a good fit. A socio-technical researcher in civil society with direct experience studying or developing new tools to support more responsible AI development, who has intuition over which tools and practices may be more or less effective, may also be a good candidate. A data officer in a state government agency who has direct experience procuring and governing AI technologies in their department, with an ability to readily anticipate AI-related challenges other agencies may face, may also be a good fit. The cohort of fellows should include a balanced mix of individuals coming from government, academia, and civil society.

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The United States faces urgent challenges related to aging infrastructure, vulnerable energy systems, and economic competitiveness. Improving American competitiveness, security, and prosperity depends on private and public stakeholders’ ability to responsibly site, build, and deploy critical energy and infrastructure. Unfortunately, these projects face one common bottleneck: permitting. 

Permits and authorizations are required for the use of land and other resources under a series of laws, such as the National Environmental Policy Act (NEPA), the Endangered Species Act (ESA), and National Historic Preservation Act of 1966. However, recent court rulings and the Trump Administration’s executive actions have brought uncertainty and promise major disruption to the status quo. The Executive Order (EO) on Unleashing American Energy mandates guidance to agencies on permitting processes be expedited and simplified within 30 days, requires agencies prioritize efficiency and certainty over any other objectives, and revokes the Council of Environmental Quality’s (CEQ) authority to issue binding NEPA regulations. While these changes aim to advance the speed, efficiency, and certainty of permitting, the impact will ultimately depend on implementation by the permitting workforce.

Unfortunately, the permitting workforce is unprepared to swiftly implement changes following shifts in environmental policy and regulations. Teams responsible for permitting have historically been understaffed, overworked, and unable to complete their project backlogs, while demands for permits have increased significantly in recent years. Building workforce capacity is critical for efficient and effective federal permitting. 

Project Overview

Our team at the Federation of American Scientists (FAS) has spent 18 months studying and working to build government capacity for permitting talent. The Inflation Reduction Act (IRA) provided resources to expand the federal permitting workforce, and we partnered with the Permitting Council, which serves as a central body to improve the transparency, predictability, and accountability of the federal environmental review and authorization process, to gain a cross-agency understanding of the hiring challenges experienced in permitting agencies and prioritize key challenges to address. Through two co-hosted webinars for hiring managers, HR specialists, HR leaders, and program leaders within permitting agencies, we shared tactical solutions to improve the hiring process.

We complemented this understanding with voices from agencies (i.e., hiring managers, HR specialists, HR teams, and leaders) by conducting interviews to identify new issues, best practices, and successful strategies for building talent capacity. With this understanding, we developed long-term solutions to build a sustainable, federal permitting workforce for the future. While many of our recommendations are focused on permitting talent specifically, our work naturally uncovered challenges within the broader federal talent ecosystem. As such, we’ve included recommendations to advance federal talent systems and improve federal hiring.

Problem

Building permitting talent capacity across the federal government is not an easy endeavor. There are many stakeholders involved across different agencies with varying levels of influence who need to play a role: the Permitting Council staff, the Permitting Council members-represented by Deputy Secretaries (Deputy Secretaries) of permitting agencies, the Chief Environmental Review and Permitting Officers (CERPOs) in each agency, the Office of Personnel and Management (OPM), the Chief Human Capital Officer (CHCO) in each permitting agency, agency HR teams, agency permitting teams, hiring managers, and HR specialists. Permitting teams and roles are widely dispersed across agencies, regions, states, and programs. The role each agency plays in permitting varies based on their mission and responsibilities, and there are many silos within the broader ecosystem. Few have a holistic view of permitting activities and the permitting workforce across the federal government.

With this complex network of actors, one challenge that arises is a lack of standardization and consistency in both roles and teams across agencies. If agencies are looking to fill specialized roles unique to one permitting need, it means that there will be less opportunity for collaboration and for building efficiencies across the ecosystem. The federal hiring process is challenging, and there are many known bottlenecks that cause delays. If agencies don’t leverage opportunities to work together, these bottlenecks will multiply, impacting staff who need to hire and especially permitting and/or HR teams who are understaffed, which is not uncommon. Additionally, building applicant pools to have access to highly qualified candidates is time consuming and not scalable without more consistency.

Tracking workforce metrics and hiring progress is critical to informing these talent decisions. Yet, the tools available today are insufficient for understanding and identifying gaps in the federal permitting workforce. The uncertainty of long-term, sustainable funding for permitting talent only adds more complexity into these talent decisions. While there are many challenges, we have identified solutions that stakeholders within this ecosystem can take to build the permitting workforce for the future.

There are six key recommendations for addressing permitting workforce capacity outlined in the table below. Each is described in detail with corresponding actions in the Solutions section that follows. Our recommendations are for the Permitting Council staff, Deputy Secretaries, CERPOs, OPM, CHCOs, OMB, and Congress.

High-level Recommendations

Enhance the Permitting Council’s Authority to Improve Processes and Workforce Collaboration	Congress needs to give the Permitting Council staff greater authority to standardize permitting practices, direct better permitting outcomes, and serve as a central authority for mandating permitting performance.
Build Efficient Permitting Teams and Standardize Roles	The Permitting Council staff, Deputy Secretaries, CERPOs, OMB, and the CHCO Council should improve the performance and consistency of permitting processes by establishing standards in permitting team roles and configurations to support cross-agency collaboration and drive continuous improvements.
Improve Workforce Strategy, Planning, and Decisions through Quality Workforce Metrics	OPM, OMB, the CHCO Council, and Permitting Council staff need to accurately gather and report on hiring metrics for talent surges and workforce metrics by domain.
Invest in Professional Development and Early Career Pathways	The Permitting Council staff, Deputy Secretaries, and CERPOs should create more development opportunities and early career pathways for civil servants.
Improve and Invest in Pooled Hiring for Common Positions	OPM, CHCOs, OMB, Permitting Council staff, Deputy Secretaries, and CERPOs should improve and make joint announcements, shared position descriptions, assessments, and certificates of eligibles for common positions a standard practice.
Improve Human Resources Support for Hiring Managers	The CHCO Council, OPM, CERPOs, and the Permitting Council staff need to test new HR resourcing models to implement hiring best practices and offer additional support to hiring managers.

Solutions

The six solutions described below include an explanation of the problem and key actions our signal stakeholders (Permitting Council staff, Deputy Secretaries, CERPOs, OPM, CHCOs, OMB, and Congress) can take to build permitting workforce capacity. The table in the appendix specifies the stakeholders responsible for each recommendation.

Enhance the Permitting Council’s Authority to Improve Permitting Processes and Workforce Collaboration 

Permitting process, performance, and talent management cut across agencies and their bureaus—but their work is often disaggregated by agency and sub-agency, leading to inefficient and unnecessarily discrete practices. While the Permitting Council plays a critical coordinating role, it lacks the authority and accountability to direct and guide better permitting outcomes and staffing. There is no central authority for influencing and mandating permitting performance. Agency-level CERPOs vary widely in their authority, whereas the Permitting Council is uniquely positioned for this role. Choosing to overlook this entity will lead to another interagency workaround. Congress needs to give the Permitting Council staff greater authority to improve permitting processes and workforce collaboration. 

1. Enhance Permitting Council Authority for Improved Performance: Enhance provisions in FAST-41 and IRA by passing legislation that empowers the Permitting Council staff to create and enforce consistent performance criteria for permitting outcomes, permitting process metrics, permitting talent acquisition, talent management, and permitting teams KPIs.
2. Enhance Permitting Council Authority for Interagency Coordination: Empower the Permitting Council staff to manage interagency coordination and collaboration for defining permitting best practices, establishing frameworks for permitting, and reinforcing those frameworks across agencies. Clarify the roles and responsibilities between Permitting Council staff, Deputy Secretaries, CERPOs, and the Council on Environmental Quality (CEQ).
3. Assign Responsibility for Tracking Changes and Providing Guidance for Permitting Practices: Assign the Permitting Council staff in coordination with OMB responsibility for tracking changes and providing guidance on permitting practices in response to recent and ongoing court rulings that change how permitting outcomes are determined (e.g., Loper Bright/Chevron Deference, CEQ policies, etc.).
4. Provide Permitting Council staff with Consistent Funding: Either renew components of IRA and/or IIJA funding that enables the Council to invest in agency technologies, hiring, and workforce development, or provide consistent appropriations for this.
5. Enhance CERPO Authority and Position CERPOs for Agency-Wide and Cross-Agency Permitting Actions: Expand CERPO authority beyond the FAST-41 Act to include all permitting work within their agency. Through legislation, policy, and agency-level reporting relationships (e.g., CERPO roles assigned to the Secretary’s office), provide CERPOs with clear authority and accountability for permitting performance. 

Build Efficient Permitting Teams and Standardize Roles

In our research, we interviewed one program manager who restructured their team to drive efficiency and support continuous improvement. However, this is not common. Rather, there is a lack of standardization in roles engaged in permitting teams within and across agencies, which hinders collaboration and prevents efficiencies. This is likely driven by the different roles played by agencies in permitting processes. These variances are in opposition to shared certifications and standardized job descriptions, complicate workforce planning, hinder staff training and development, and impact report consistency. The Permitting Council staff, Deputy Secretaries, CERPOs, OMB, and the CHCO Council should improve the performance and consistency of permitting processes by establishing standards in permitting team roles and configurations to support cross-agency collaboration and drive continuous improvements.

1. Characterize Types of Permitting Processes: Permitting Council staff should work with Deputy Secretaries, CERPOs, and Permitting Program Team leaders to categorize types of permitting processes based on project “footprint”, complexity, regulatory reach (i.e., regulations activated), populations affected and other criteria. Identify the range of team configurations in use for the categories of processes.  
2. Map Agency Permitting Roles: Permitting Council staff should map and clarify the roles played by each agency in permitting processes (e.g., sponsoring agency, contributing agency) to provide a foundation for understanding the types of teams employed to execute permitting processes.
3. Research and Analyze Agency Permitting Staffing: Permitting Council staff should collaborate with OMB to conduct or refine a data call on permitting staffing. Analyze the data to compare the roles and team structures that exist between and across agencies. Conduct focus groups with cross agency teams to identify consistent talent needs, team functions, and opportunities for standardization.
4. Develop Permitting Team Case Studies: Permitting Council staff should conduct research to develop a series of case studies that highlight efficient and high performing permitting team structures and processes.
5. Develop Permitting Team Models: In collaboration with Deputy Secretaries and CERPOs, Permitting Council staff should develop team models for different agency roles (i.e., sponsor, lead agency, coordinating agency) that focus on driving efficiencies through process improvements and technology, and develop guidelines for forming new permitting teams.
6. Create Permitting Job Personas: In collaboration with Deputy Secretaries and CERPOs, Permitting Council staff should develop personas to showcase the roles needed on each type of permitting team and roles, recognizing that some variance will always remain, and the type of hiring authority that should be used to acquire those roles (e.g., IPA for highly specialized needs). This should also include new roles focused on process improvements; technology and data acquisition, use, and development; and product management for efficiency, improved customer experience, and effectiveness.
7. Define Standardized Permitting Roles and Job Analyses: With the support of Deputy Secretaries and CERPOs, Permitting Council staff should identify roles that can be standardized across agencies based on the personas, and collaborate with permitting agencies to develop standard job descriptions and job analyses.
8. Develop Permitting Practice Guide: In collaboration with Deputy Secretaries and CERPOs, Permitting Council staff should develop a primer on federal permitting practices that explains how to efficiently and effectively complete permitting activities.
9. Place Organizational Strategy Fellows: Permitting Council staff should hire at least one fellow to their staff to lead this effort and coordinate/liaise between permitting teams at different agencies.
10. Mandate Permitting Hiring Forecasts: Permitting Council staff should collaborate with the CHCO Council to mandate permitting hiring forecasts annually with quarterly updates.
11. Revise Permitting Funding Requirements: Permitting Council staff should include requirements for the adoption of new team models and roles in the resources and coordination provided to permitting agencies to drive process efficiencies.

Improve Workforce Strategy, Planning, and Decisions through Quality Workforce Metrics

Agency permitting leaders and those working across agencies do not have the information to make informed workforce decisions on hiring, deployment, or workload sharing. Attempts to access accurate permitting workforce data highlighted inefficient methods for collecting, tracking, and reporting on workforce metrics across agencies. This results in a lack of transparency into the permitting workforce, data quality issues, and an opaque hiring progress. With these unknowns, it becomes difficult to prioritize agency needs and support. Permitting provided a purview into this challenge, but it is not unique to the permitting domain. OPM, OMB, the CHCO Council, and Permitting Council staff need to accurately gather and report on hiring metrics for talent surges and workforce metrics by domain.

1. Establish Permitting Workforce Data Standards: OPM should create minimum data standards for hiring and expand existing data standards to include permitting roles in employee records, starting with the Request for Personnel Action that initiates hiring (SF52). Permitting Council staff should be consulted in defining standards for the permitting workforce.
2. Mandate Agency Data Sharing: OPM and OMB should require agencies share personnel action data; this should be done automatically through APIs or a weekly data pull between existing HR systems. To enable this sharing, agencies must centralize and standardize their personnel action data from their components.
3. Create Workforce Dashboards: OPM should create domain-specific workforce dashboards based on most recent agency data and make it accessible to the relevant agencies. This should be done for the permitting workforce.
4. Mandate Permitting Hiring Forecasts: The CHCO Council should mandate permitting hiring forecasts annually with quarterly updates. This data should feed into existing agency talent management/acquisition systems to track workforce needs and support adaptive decision making.

Invest in Professional Development and Early Career Pathways

There are few early career pathways and development opportunities for personnel who engage in permitting activities. This limits agencies’ workforce capacity and extends learning curves for new staff. This results in limited applicant pools for hiring, understaffed permitting teams, and limited access to expertise. More recently, many of the roles permitting teams hired for were higher level GS positions. With a greater focus on early career pathways and development, future openings could be filled with more internal personnel. In our research, one hiring manager shared how they established an apprenticeship program for early career staff, which has led 12 interns to continue into permanent federal service positions. The Permitting Council staff, Deputy Secretaries, and CERPOs should create more development opportunities and early career pathways for civil servants.

1. Invest in Training to Upskill and Reskill Staff: The Permitting Council staff should continue investing in training and development programs (i.e., Permitting University) to upskill and reskill federal employees in critical permitting skills and knowledge. Leveraging the knowledge gained through creating standard permitting team roles and collaborating with permitting leaders, the Permitting Council staff should define critical knowledge and skills needed for permitting and offer additional training to support existing staff in building their expertise and new employees in shortening their learning curve.
2. Allocate Permitting Staff Across Offices and Regions: CERPOs and Deputy Secretaries should implement a flexible staffing model to reallocate staff to projects in different offices and regions to build their experience and skill set in key areas, where permitting work is anticipated to grow. This can also help alleviate capacity constraints on projects or in specific locations.
3. Invest in Flexible Hiring Opportunities: CERPOs and Deputy Secretaries should invest in a range of flexible hiring options, including 10-year STEM term appointments and other temporary positions, to provide staffing flexibility depending on budget and program needs. Additionally, OPM needs to redefine STEM to include technology positions that do not require a degree (e.g., Environmental Protection Specialists).
4. Establish a Permitting Apprenticeship: The Permitting Council staff should establish a 1-year apprenticeship program for early career professionals to gain on-the-job experience and learn about permitting activities. The apprenticeship should focus on common roles shared across agencies and place talent into agency positions. A rotational component could benefit participants in experiencing different types of work.

Improve and Invest in Pooled Hiring for Common Positions

Outdated and inaccurate job descriptions slow down and delay the hiring process. Further delays are often caused by the use of non-skills-based assessments, often self-assessments, which reduce the quality of the certificate list, or the list of eligible candidates given to the hiring manager. HR leaders confront barriers in the authority they have to share job announcements, position descriptions (PDs), classification determinations, and certificate lists of eligible candidates (Certs). Coupled with the above ideas on creating consistency in permitting teams and roles and better workforce data, OPM, CHCOs, OMB, Permitting Council staff, Deputy Secretaries, and CERPOs should improve and make joint announcements, shared position descriptions, assessments, and certificates of eligibles for common positions a standard practice.

1. Provide CHCOs the Delegated Authority to Share Announcements, PDs, Assessments, and Certs: OPM and OMB should lower the barriers for agencies to share key hiring elements and jointly act on common permitting positions by delegating the authority for CHCOs to work together within and across their agencies, including with the Permitting Council staff.
2. Revise Shared Certificate Policies: OPM and OMB should revise shared certificate policies to allow agencies to share certificates regardless of locations designated in the original announcement and the type of hire (temporary or permanent). They should require skills-based assessments in all pooled hiring. Additionally, OPM should streamline and clarify the process for sharing certificates across agencies. Agencies need to understand and agree to the process for selecting candidates off the certificate list.
3. Create a Government-wide Platform for Permitting Hiring Collaboration: OPM should create a platform to gather and disseminate permitting job announcements, PDs, classification determinations, job/competency evaluations, and cert. lists to support the development of consistent permitting teams and roles.
4. Pilot Sharing of Announcements, PDs, Assessments, and Certs for Common Permitting Positions: OPM and the CHCO Council should collaborate with the Permitting Council staff to select most common and consistent permitting team roles (e.g., Environmental Protection Specialist) to pilot sharing within and across agencies.
5. Track Permitting Hiring and Workforce Performance through Data Sharing and Dashboards: Permitting Council staff, Deputy Secretaries, and CERPOs should leverage the metrics (see Improve Workforce Decisions Through Quality Workforce Metrics) and data actions above to track progress and make adjustments for sharing permitting hiring actions.
6. Incorporate Shared Certificates into Performance: OPM and the CHCO Council should incorporate the use of shared certificates into the performance evaluations of HR teams within agencies.

Improve Human Resources Support for Hiring Managers

Hiring managers lack sufficient support in navigating the hiring and recruiting process due to capacity constraints. This causes delays in the hiring process, restricts the agency’s recruiting capabilities, limits the size of the applicant pools, produces low quality candidate assessments, and leads to offer declinations. The CHCO Council, OPM, CERPOs, and the Permitting Council staff need to test new HR resourcing models to implement hiring best practices and offer additional support to hiring managers.

1. Develop HR Best Practice Case Studies: OPM should conduct research to develop a series of case studies that highlight HR best practices for recruitment, performance management, hiring, and training to share with CHCOs and provide guidance for implementation.
2. Document Surge Hiring Capabilities: In collaboration, the Permitting Council staff and CERPOs should document successful surge hiring structures (e.g., strike teams), including how they are formed, how they operate, what funding is required, and where they sit within an organization, and plan to replicate them for future surge hiring.
3. Create Hiring Manager Community of Practice: In collaboration, the Permitting Council staff and Permitting Agency HR Teams with support from the CHCO Council should convene a permitting hiring manager community of practice  to share best practices, lessons learned, and opportunities for collaboration across agencies. Participants should include those who engage in hiring, specifically permitting hiring managers, HR specialists, and HR leaders.
4. Develop Permitting Talent Training for HR: OPM should collaborate with CERPOs to create a centralized training for HR professionals to learn how to hire permitting staff. This training could be embedded in the Federal HR Institute.
5. Contract HR Support for Permitting: The Permitting Council staff should create an omnibus contract for HR support across permitting agencies and coordinate with OPM to ensure the resources are allocated based on capacity needs.
6. Establish HR Strike Teams: OPM should create a strike team of HR personnel that can be detailed to agencies to support surge hiring and provide supplemental support to hiring managers.
7. Place a Permitting Council HR Fellow: The Permitting Council should place an HR professional fellow on their staff to assist permitting agencies in shared certifications and build out talent pipelines for the key roles needed in permitting teams.
8. Establish Talent Centers of Excellence: The CHCO Council should mandate the formation of a Talent Center of Excellence in each agency, which is responsible for providing training, support, and tools to hiring managers across the agency. This could include training on hiring, hiring authorities, and hiring incentives; recruitment network development; career fair support; and the development of a system to track potential candidates.

Next Steps

These recommendations aim to address talent challenges within the federal permitting ecosystem. As you can see, these issues cannot be addressed by one stakeholder, or even one agency, rather it requires effort from stakeholders across government. Collaboration between these stakeholder groups will be key to realizing sustainable permitting workforce capacity.

Federal hiring ebbs and flows with changes in administrations, legislative mandates, attrition, hiring freezes, and talent surges. The lessons and practices in this blog post series explore the earlier stages of the hiring process. Though anchored in our permitting talent research, the lessons are universal in their application, regardless of the hiring environment. They can be used to accelerate and improve hiring for a single or multiple open positions, and they can be kept in reserve during hiring downturns.

Assessing, Selecting, and Onboarding the Successful Candidate

Previously we described the end-to-end hiring process, the importance of getting hiring right from the start, and how sharing resources speeds hiring. This post focuses on the last two phases of the process: Assessment and Offer. While these phases include eight steps, we’ve narrowed down our discussion to five key steps:

1. Close Job Opportunity Announcement and Evaluate Applicants
2. Review Certificate of Eligibles, Conduct Interviews, and Make Selection
3. Make Tentative Job Offer and Receive Acceptance
4. Initiate Investigation at the Appropriate Level (Security Check)
5. Make Official Offer and Enter on Duty (Onboard New Hire)

Our insights shared in this post are based on extensive interviews with hiring managers, program leaders, staffing specialists, workforce planners, and budget professionals as well as on-the-job experience. These recommendations for improvement focus on process and do not require policy or regulatory changes. They do require adoption of these practices more broadly throughout HR, program, and permitting managers, and staff. These recommendations are not unique to permitting; they apply broadly to federal government hiring. These insights should be considered both for streamlining efforts related to environmental permitting, as well as improving federal hiring.

Breaking Down the Steps

For each step, we provide a description, explain what can go wrong, share what can go right, and provide some examples from our research, where applicable.

Close Job Opportunity Announcement and Evaluate Applicants 

Once the announcement period has ended, job announcements close, and HR begins reviewing the applications in the competitive hiring process. HR reviews the applications, materials provided by the applicants, and the completed assessments, which vary depending on the assessment strategy. This selection process is governed by policies in competitive examination and will be determined by whether the agency is following category rating, rule of many, or other acceptable evaluation methods.

If the agency is using a different hiring authority or flexibility, this step will change. For example, if the agency has Direct Hire Authority (DHA), they may not need to provide a rigorous assessment and may be able to proceed to selection after a review of resumes. Most agencies will still engage in some assessment process for these types of positions. After the applicants are evaluated, HR issues a Certificate of Eligibles (or “cert list”) with the ranking of the applicants from which the hiring manager can select, including the implementation of Veterans preference. 

What Can Go Wrong

• Most applicant assessments rely on the resume review and candidate self-assessment. Applicants who understand the process rate themselves as highly qualified on all aspects of the job, resulting in a certificate list with unqualified applicants at the top. Agencies are now required by law to use skills-based assessments in the Chance to Compete Act and previous Executive Order guidance to prevent this, but the adoption process will be slow.
• HR staffing resources are frequently strained to immediately review applications and resumes causing delays. This causes applicant and hiring manager dissatisfaction and possibly a loss of attractive, qualified applicants. Within permitting, hiring managers have been struggling to find talent with the required expertise, especially specialized or niche expertise, and this loss is a critical setback.
• Frequently HR specialists do not consult with the program managers to gain a deep understanding of what they’re looking for in a resume or application and rely solely on their interpretation of the qualifications listed in the position description. This can result in poor quality applicants referred to the hiring manager. 

What Can Go Right

• If the recruiters and hiring manager have engaged in effective recruiting, applicant quality is likely to be quite high. This eases the HR’s job of finding strong applicants.
• With a strong applicant pool, HR specialist can limit the number of applicants they consider and/or limit how long the job announcement is open. This will expedite the process, as the assessment will be faster. Rigorous assessments reduce the likelihood of unqualified applicants making it to the certificate list. A hiring manager who insists on a skills-based assessment will likely move forward with a successful hire. Using subject-matter experts in a Subject Matter Expert Qualifications Assessment (SME-QA) or similar assessment process can result in a strong list of applicants, and it has the added benefit of building familiarity by engaging the employee’s future peers in the process.

Review Certificate of Eligibles, Conduct Interviews, and Make Selection 

HR sends a Certificate of Eligibles (certificate list) to the hiring manager that ranks the applicants who passed the assessment(s). Under competitive hiring rules (as opposed to some of the other hiring authorities), hiring managers are obligated to select from the top of the Certificate of Eligibles list, or those considered to be most qualified. 

The Veterans preference rules also require that qualified Veterans move to the top of the list and must be considered first. Outside of competitive hiring and under other hiring authorities, the hiring manager may have more flexibility in the selection of candidates. For example, direct hire authority allows the hiring manager to make a selection decision based on their own review of resumes and applications. 

If determined as part of the assessment process beforehand, the hiring manager may choose to conduct final interviews with the top candidates. In this case, the manager then informs HR of their selection decision. 

What Can Go Wrong

• If the hiring manager cannot find an applicant they deem qualified on the certificate list, they inform HR, restart the hiring action, and/or re-post the position, further delaying the process. This happens frequently when the assessment tools default to a self-evaluation, or self-assessment. One Hiring Manager we met needed to request a second certificate list, and this extended the hiring process to nine months.
• Lack of resources in HR or the hiring manager’s program often results in evaluation and selection delays. Top applicants in high demand may take other jobs if the process takes longer than anticipated. This was a concern voiced by hiring managers during our interviews.
• In rare circumstances, agency funding could be uncertain and the budget function could rescind the approval to hire at this stage, frustrating hiring managers, applicants, and HR specialists.

What Can Go Right

• Strong recruiting early and throughout the process results in a strong certificate list with excellent candidates. One permitting agency, following best practice, kept a pipeline of potential candidates, including prior applicants to boost the quality of the applicant pool.
• An effective assessment process weeds out unqualified or unsuitable candidates and culls the list of applicants to only those who can do the job.
• A deep partnership between the HR staffing specialist and the hiring manager in which they discuss the skills and “fit” of the top candidates increases the hiring manager’s confidence in the selection.

Make Tentative Job Offer and Receive Acceptance

HR reaches out to the applicant to make a tentative job offer (i.e., tentative based on the applicant’s suitability determination, outlined below) and asks for a decision from the applicant within an acceptable time frame, which is normally a couple of days to a week. The HR staffing specialist will keep in close contact with the hiring manager and HR officials regarding the status of the candidate accepting the position.

What Can Go Wrong

• The applicant rejects the offer due to a misunderstanding of the job. This could be the location, remote work, or telework availability. In our interviews, we learned that some applicants declined offers because they believed the position was full time or a temporary position that could convert to a full time role, but that was not the case.
• The applicant rejects the offer due to a competing offer at a higher salary or as a result of other financial factors (e.g., relocation expenses). Some participants shared that financial factors had been the reason for some of their declinations.
• The applicant rejects the offer because of how they have been treated throughout the process or delays, which have led them to remain in their current role or accept another position.

What Can Go Right

• The HR specialist and others involved in the hiring process maintain regular communications with the candidate regarding their offer, listens to any concerns they may have about accepting their offer, and works with the hiring manager to correct any misperceptions about the job requirements.
• The HR specialist and the hiring manager understand the financial incentives they can use to negotiate salary, relocation expenses, signing bonuses, and other benefits to negotiate with the candidate. These options are usually agency-, function-, or job-specific.

Initiate Investigation at the Appropriate Level (Security Check)

Different federal occupations require different levels of suitability determinations or security clearances – from simple background checks to make sure the information an applicant provided on their application is accurate to a Top Secret clearance that enables the employee to access sensitive information. Each type of suitability determination has a different time frame needed for a security officer to evaluate the candidate. (Some positions require the security officer to not only interview the candidate, but also interview their friends, relatives, and neighbors.) This takes time during a part of the hiring process when both the candidate with the tentative offer and the hiring manager are anxious to move forward.

Once the candidate selection is made, the HR specialist works with the agency suitability professionals to initiate the background check and clearance process. Agency suitability experts work with the Defense Counterintelligence Security Agency (DCSA) to conduct the determination of the applicant. 

What Can Go Wrong

• Applicants who have never applied for a federal job may be unfamiliar with their responsibilities during the suitability determination. If they do not fill out the forms properly, this causes delays, especially when the applicant is slow to respond.
• If the candidate does not know how long the suitability determination will take or what is involved in the process, the lack of transparency may create uncertainty and/or frustration among the applicant. Furthermore, if the candidate is not kept informed on where they are in the process or what to expect next, they may get discouraged and decline the tentative offer.
• Delays in scheduling fingerprinting appointments or access to fingerprinting facilities can also lengthen the time for the suitability determination.

What Can Go Right

• The hiring manager, HR specialist, and suitability experts work together to ensure the candidate knows where they are in the process and what is expected of them through frequent check-ins and progress tracking.
• Offering applicants a range of options for fingerprinting, including the opportunity to go to a third party vendor for prints. This can enable fast digital uploads within 24 hours (applicant may have to pay for third-party services).
• Hiring managers and HR specialists leverage the DCSA resources and tools, including the PDT Tool to determine the level of background check needed for their role.
• The Suitability manager uses a case management system to track and maintain all suitability requests. This will help ensure nothing is lost, and system notifications can help keep the process on track by requesting applicants, hiring managers, and HR specialists complete their tasks in a timely manner. One interview participant highlighted this as critical to the timeliness of the suitability process.

Make Official Offer and Enter on Duty (Onboard New Hire)

The last step in the hiring process is administering the final offer of employment, identifying and Entry on Duty date, and onboarding the new employee. HR staff usually shepherd the new employee through this step. The hiring manager, administrator, or a peer mentor frequently assists the new employee in making sure the employee understands what they need to do to begin contributing to the agency.

What Can Go Wrong

• The candidate declines the final offer of employment due to delays or dissatisfaction with their experience during the hiring process.
• Frequently, onboarding consists of filling out online forms, paperwork to register the new employee in the various agency systems, and required compliance training. Minimal attention is spent on their work and how it connects to the agency mission.
• All too often, the new employee does not receive their computer equipment, phone, or other resources necessary for them to do their jobs in a timely manner. These delays degrade the initial employee experience.

What Can Go Right

• HR and hiring manager program staff stay in constant connection with the candidate as they accept the job and start the onboarding process, ensuring that the early employee experience is positive. This includes not only the administrative activities but also introductions to the agency and the work they will be doing.
• Program managers and administrative staff can work with IT functions and other departments to make sure the new employee has the equipment and resources needed to start their job successfully.
• The hiring manager establishes their relationship with the new employee during onboarding, creating a positive atmosphere for the employee by clearly articulating expectations.

Conclusion

Hiring success depends heavily on the broader hiring ecosystem. There are many stakeholders (e.g., leadership, budget, program, HR, suitability, applicant) who play a crucial role; collaboration and communication is important for both a timely and successful hire. Adoption of best practices across the ecosystem will help to improve hiring outcomes, reduce process delays, and enhance the overall hiring experience for all parties involved. The best practices outlined in our blog post series provide a guide to better navigate the hiring process. 

The overall intent of hiring is to improve the performance of the federal program or function. New employees expand the organization’s workforce capacity and bring capabilities needed to achieve the mission. A skilled, prepared, and engaged federal employee can have an outsized impact on a program’s success.

In the machinery of national security decision-making, innovation is the first casualty of consensus. At the heart of this process lies the National Security Council’s multi-layered committee structure to develop policy recommendations for the President. While this process ensures broad interagency coordination, it also means that agencies can effectively veto options that challenge their interests. The result is that the President often only sees consensus recommendations that preserve institutional status quo, rather than the full range of viable policy options that might better serve national interests. The new National Security Advisor, Congressman Mike Waltz, should reshape the NSC process to provide better foreign policy advice for the President.

The Current Process: Design vs. Reality

The NSC’s decision-making process follows a carefully structured path. At the working level, Interagency Policy Committees (IPCs) bring together Assistant Secretary-level officials and subject matter experts to develop initial policy options. These recommendations then move to the Deputies Committee, composed of deputy heads of relevant agencies, for refinement and further analysis. The Principals Committee, consisting of Cabinet-level officials, then reviews and shapes final recommendations before they reach the President through the National Security Advisor.

In theory, this layered approach should ensure thorough vetting while preserving diverse viewpoints. In practice, however, the system often produces the opposite effect. Each level of review tends to narrow options rather than expand them, as agencies work to protect their institutional interests and avoid conflict with other departments.

The Consensus Trap

The emphasis on interagency consensus, while well-intentioned, has become a structural impediment to bold or innovative policy options. Former National Security Advisor H.R. McMaster warned about this in his book Battlegrounds stating, “Presenting a single option designed to either tell the President what he or she wants to hear, or to present the consensus position of the cabinet is doing him or her a disservice.” He argued that it is “important to provide the President with multiple options.”

When every agency effectively holds veto power over proposals, the path of least resistance becomes maintaining existing approaches with minor modifications. This dynamic is particularly problematic in rapidly evolving security situations where status quo responses may be inadequate.

Consider, for example, how options that might gore the ox of the Defense Department’s budget are quietly culled, or how proposals that ruffle the diplomatic feathers of the State Department rarely survive the process. While both of the Department’s perspectives may have merit, the current system often leads to their mutual neutralization, rather than producing either a creative outcome or an advancement of an option with dissents.

The Cost of Lost Alternatives

The consequences of this consensus-driven approach are significant. The President is often presented with artificially limited choices, typically framed as minor variations on existing policy rather than genuinely distinct alternatives. This narrowing of options can be particularly problematic in crisis situations where innovative approaches might be most needed. 

More concerning is what the President doesn’t see: options that challenge conventional wisdom, propose significant departures from existing policy, or require substantial institutional compromise or change. These alternatives, while potentially valuable, often don’t survive the gauntlet of interagency review.

Potential Reforms

During the Obama NSC we identified several reforms that could help address these structural limitations. Some of these ideas included:

1. Mandate a presentation of competing options: Require that multiple, genuinely distinct policy alternatives reach the President’s desk, even if they don’t have unanimous agency support.
2. Create independent analysis channels: Borrow the Intelligence Community’s Red Cell process and establish mechanisms for policy options to reach senior decision-makers without requiring consensus at every level.
3. Strengthen the NSC staff’s role: Empower NSC staff to develop independent options that might challenge agency preferences.
4. Reform the Deputies Committee process: Modify procedures to focus on developing multiple viable options rather than driving toward consensus.

The NSC’s current decision-making process, while sophisticated in design, often fails to provide the President with the full range of policy options needed for effective decision-making. The system’s emphasis on consensus, while valuable for implementation, has become an impediment to innovative policy development.

Reform is possible without dismantling the valuable coordination functions of the current system. By modifying procedures to ensure that diverse options reach senior decision-makers, the NSC can better fulfill its core mission: providing the President with the best possible range of choices for addressing national security challenges.

The goal isn’t to eliminate interagency coordination but to prevent it from unduly constraining presidential options. In an increasingly complex security environment, the President needs access to the fullest possible range of policy alternatives, not just those that survive the consensus-building process.

Jim Thompson is the Director of Government Capacity at the Federation of American Scientists. He served as a Director on both President Obama’s and President Biden’s National Security Councils.

“There really are fewer unicorn positions out there than we all imagined” – Bob Leavitt, HHS CHCO on shared PDs and certificates for common positions

Creating a job announcement that attracts high quality applicants is critical to the hiring process. For hiring managers, finding a balance between identifying the unique details of the position and managing the time and resources required is a challenge. When defining a position, there are many potential “off-ramps.” While these diversions are sometimes necessary, they often result in significant time delays and demand scarce resources from both hiring managers and HR staff. Improvements over the past few years offer hiring managers opportunities to accelerate the process while improving applicant quality, primarily done through collaboration within and across agencies that requires a level of standardization.

In our previous blog posts, we outlined the hiring process and dove into the first phase – Getting Hiring Right from the Start. This post discusses the second phase of the process: planning for and announcing the job. This phase includes four steps:

1. Review Position Description and Confirm Job Analysis 
2. Classify or Reclassify the Position
3. Confirm Job Analysis and Assessment Strategy
4. Create and Post the Job Opportunity Announcement (JOA)

Our insights shared in this post are based on extensive interviews with hiring managers, program leaders, staffing specialists, workforce planners, and budget professionals as well as on-the-job experience. These recommendations for improvement focus on process and  do not require policy or regulatory changes. They do require adoption of these practices more broadly throughout HR, program, and permitting managers, and staff. Additionally, our insights here are not unique to permitting, rather they apply broadly to federal government hiring. These insights should be considered both for streamlining efforts related to environmental permitting, as well as improving federal hiring.

Breaking Down the Steps

For each step in this phase, we provide a description, explain what can go wrong, share what can go right, and provide some examples from our research, where applicable. 

Review Position Description and Confirm Job Analysis

The Position Description (PD) is core to the hiring process. It describes the occupation, grade level, job duties, qualifications, and any special skills needed for the job and agency. In hiring, it is used to develop the job announcement, review the position’s classification, and establish a  foundation for assessing candidates. Outside of hiring, it is used in performance management, position management, probation period evaluation, and serves as a reference for disciplinary action. 

At this step, a hiring manager reviews the position description to make sure it is an accurate, current depiction of the job requirements, which may require a review of the past job analysis, or the evaluation of the knowledge, skills, abilities, behaviors, and experience needed for the positions (i.e., the competencies). The PD can be inaccurate due to dynamic changes in the job: core duties, technologies used, process changes, and supervisory responsibilities. These updates can range from simple wording changes to major changes that require additional work. 

In our interviews, we heard from hiring managers and HR specialists that updating position descriptions had been a challenge and bottleneck in their hiring process. One hiring manager shared that they chose to not change their positions even if they wanted a different role because of the anticipated time delays. Other participants shared that they have begun moving towards standardized PDs within their agency to reduce redundancies and enable more collaboration.

What Can Go Wrong

• Based on hiring manager feedback to the HR specialist, a significantly out-of-date PD can result in major revisions that require a job analysis and/or reclassification of the position. This can delay the hiring process by weeks, or even months. If the grade level or other key aspects of the position need to be changed, the position requisition (SF-52 form) needs to be revised, adding even more time. 
• Overzealous staffing specialists or classifiers may perceive major job changes where they do not exist in practice, causing delays for additional reviews and revisions.
• Too much specificity in job task descriptions will require additional job analyses, causing further delays. Whereas not enough specificity provides insufficient guidance for developing the assessment strategy, JOA, and other management actions dependent on the PD (e.g., performance management, development plans, or disciplinary action).

What Can Go Right

• With permission from their Chief Human Capital Office (CHCO) office, a hiring manager can use a current PD from elsewhere in the agency that accurately describes the job. A number of agencies have created PD libraries that bring together common PDs from across the organization. One HR Leader we interviewed described having a library of available positions that hiring managers are encouraged to look through when creating a new position. Hiring managers can even include specialized skills in an existing PD to augment the fundamental job duties, avoiding reclassification.
• Hiring managers can offer flexibility in location, where possible. Based on our interviews, agencies are seeing greater success attracting strong applicants with flexible locations, remote work, or telework options.
• The HR staffing specialist can search for and find a shared certificate of eligibles (i.e., a list of eligible candidates) for their PD already available through their own agency HR talent systems or through the USAJOBS Agency Talent Portals. As long as the job and grade match, the hiring manager can bypass much of the hiring process and move quickly to identifying applicants. 
• Many agencies require managers to review and if needed, revise position description every year during the performance management process. This can make sure the PD is ready to go for the hiring process. In our interviews, we heard that this is required, but may not be regularly completed.

Classify/Reclassify the Position

Position classification is a structured process in every Cabinet agency in which an expert assesses the requirements of the job by evaluating factors such as knowledge, skills, abilities, complexity, and supervisory controls/responsibilities. The process is initiated when a PD is deemed inaccurate due to changes in the role. The HR staffing specialist will ask a classification expert to assess the role. This is done by reviewing the PD, existing job analyses, past classifications, and classification audits. They will also gather and review data from the hiring manager and others working in similar roles. Based on their assessment, the classifier can recommend changes to the grade level and/or the occupational series. These changes could be simple revisions or a more extensive reclassification. This process can take days or weeks to complete and can delay the hiring process significantly.

What Can Go Wrong

• HR staff and classifiers sometimes do not explain the need for classification and its benefits. This makes the process opaque and leaves the hiring manager wondering how long it will take to complete.

• HR staffing specialists and classifiers vary widely in how they apply the classification standards. Some seek greater specificity, and therefore insist on a full classification review when it may not be needed.
• Agency HR functions frequently lack workforce capacity for classification and job analyses. As a result, they have to prioritize requests, which can cause further delays.

What Can Go Right

• Collaboration and transparency between hiring managers, staffing specialists, and classifiers can lead to rapid approval of a PD and classification review. If there cannot be a quick approval, this close engagement leads to clearer expectations and realistic timelines.
• If the same position, at the same grade level, has recently completed a classification audit in a different part of the agency, the hiring team can use it. This can also be done across agencies with CHCO approval.
• Hiring managers who invest time to understand the position well and articulate the roles, duties, relationships, and complexity to the classifier can improve the outcomes and make the process more efficient. 
• Agencies that lack classification resources frequently engage with outside contractors or retired annuitants to provide more capacity for the classification and job analysis work. 

Develop Assessment Strategy

A critical, but sometimes overlooked step in hiring is developing the assessment strategy for the position. This determines how the HR staff and hiring manager will evaluate applicants and identify candidates for the certificate list, or the list of eligible applicants. The strategy needs to assess candidates based on the defined job duties and position criteria, and it plays a major role in determining the quality of candidates.The assessment strategy consists of three parts:

1. How job applications and resumes are reviewed
2. How the applicants demonstrate the required skills and abilities
3. How the hiring manager makes the final selection

Recently, agencies have moved toward evaluating applicants by assessing their skills, spurred on by the Executive Order and guidance on skills-based assessments and now reinforced by the Chance to Compete Act. This shift aims to move away from relying on education and/or self-assessments. Skills-based assessments can include online tests, skills-based simulation exercises, simulated job tryouts, as well as the Subject Matter Expert Qualifications Assessment (SME-QA) process developed by OPM and USDS/OMB. This improves the quality of assessments and aims to ensure the candidates on the certificate list are qualified for the job.

What Can Go Wrong

• If a hiring manager and HR staffing specialist bypass this step, this frequently results in a certificate list with unqualified candidates. Without a strategy, many default to using a resume review and self-assessments. Unfortunately, our research indicated that many agencies are still using self-assessments.
• Most of the time, resume screening is left solely to the HR staff. Lack of alignment between HR specialists and hiring managers on essential qualifications results in an inaccurate screening, leading unqualified candidates to make the cut. Too often, HR staff will only screen applications for the exact phrases that appear in the job announcement. Applicants know this and revise their documents accordingly.
• When a skills-based assessment does not exist for the position and specific grade level, it needs to be created. This takes time and expert resources, thus delaying the hiring process.
• Inaccurate resume screenings and self-assessments frequently lead to a high number of unqualified Veterans making the top of the certificate list due to Veterans preference. Unfortunately, this leads to a negative perception of Veterans preference. 

What Can Go Right

• Working with HR staffing specialists to find existing assessments can save time and improve candidate selection quality. In addition, USA Hire, Monster, and other HR talent acquisition platforms are offering compendiums of assessment strategies and tools that can be accessed, usually for free. 
• Deep engagement between hiring managers, staffing specialists, and assessment professionals in developing an assessment strategy and selecting tools pays off. This can lead to enhanced resume and application screening, stronger alignment between candidate and position needs, and higher quality certificate lists of eligible candidates.
• Engagement with staffing specialists and assessment experts can also help the hiring manager understand and make tradeoff decisions related to the speed and ease of administration. For example, an online test may be easier to utilize, while embedding Subject Matter Experts into the selection process may increase the efficacy.

Create and Post Job Opportunity Announcement

Though creating and posting the JOA is relatively straightforward, lack of attention to this step can reduce the number of attractive candidates. The HR staffing specialist usually creates the JOA in consultation with the hiring manager to ensure that it not only accurately reflects the job duties, but also sells the job to potential applicants. The JOA is an opportunity to showcase the importance of the role and its contribution to the agency’s mission. 

The JOA outlines applicant eligibility, job duties, job requirements (e.g., conditions of employment, qualifications, etc.), education (if needed), assessment strategy, and application requirements. It also lists the occupation, grade level, location, and other details. See USAJOBS for examples.

What Can Go Wrong

• Some hiring managers and staffing specialists are under the misapprehension that the JOA needs to contain the exact language from the PD in both the title and description. This can include jargon and terms that are unfamiliar to those not within the organization. 
• Unintentionally, a hiring manager may lock the job location in a specific city or metropolitan area when the job could be remote or in multiple locations. To correct this, the JOA will need to be taken down and re-posted if no suitable applicants can be found.

What Can Go Right

• JOAs need to be tailored to the target applicants, and working with those currently in the job or in a related-discipline can help in crafting an attractive JOA.
• Using plain language in the job title and description instead of jargon will attract more candidates. OPM has published plain language guidance to help hiring managers and staffing specialists do this effectively.
• Earlier in the hiring process, successful hiring managers and staffing specialists define recruiting and sourcing strategies to attract candidates. This can include posting the job on alternative sites (e.g., agency websites, LinkedIn, Handshake, Indeed, etc.) in addition to USAJOBS to reach a broader audience. One agency’s HR team described leveraging multiple platforms for outreach and was able to successfully recruit many qualified candidates for their open roles. Strategies can also include asking hiring managers, peers, agency leaders, and recruiters to message highly qualified candidates to expand the applicant pool and bring in more qualified applicants. 

Conclusion

Throughout this phase of work, there are many actions hiring managers and staffing specialists can take to streamline the process and improve the quality of eligible candidates. Most importantly, hiring managers and staffing specialists can collaborate within and across agencies to expedite and simplify the process. Using an existing PD from another part of the agency, finding an assessment tool for the job and grade level, pooling resources on a common job announcement with a peer, and using shared certificates to move straight to a job offer are all ways you can find a well-qualified hire faster. More tips and techniques to improve hiring can be found in OPM’s Workforce of the Future Playbook.

Changes that can be made to improve efficiency and promote collaboration. These center on moving to standardized PDs, where appropriate, leveraging shared certifications with those standardized PDs, and investing in skills-based assessments, which are now required by law in the Chance to Compete Act. 

Making these actions common practice is one of the key challenges to improving hiring. The Executive Order on skills-based hiring states “in light of today’s booming labor market, the Federal government must position itself to compete with other sectors for top talent.” It is critical we take advantage of these collaboration tools that can improve the hiring experience for all those involved.

Government, like all institutions, runs on people. We need more people with the right skills and expertise for the many critical roles that public agencies are hiring for today. Yet hiring talent in the federal government is a longstanding challenge. The next Administration should unpack hiring strategy from headquarters and launch a series of large scale, cross-agency recruitment and hiring surges throughout the country, reflecting the reality that 85% of federal employees are outside the Beltway. With a collaborative, cross-agency lens and a commitment to engaging jobseekers where they live, the government can enhance its ability to attract talent while underscoring to Americans that the federal government is not a distant authority but rather a stakeholder in their communities that offers credible opportunities to serve. 

Challenge and Opportunity

The Federal Government’s hiring needs—already severe across many mission-critical occupations—are likely to remain acute as federal retirements continue, the labor market remains tight, and mission needs continue to grow. Unfortunately, federal hiring is misaligned with how most people approach job seeking. Most Americans search for employment in a geographically bounded way, a trend which has accelerated following the labor market disruptions of the COVID-19 pandemic. In contrast, federal agencies tend to engage with jobseekers in a manner siloed to a single agency and across a wide variety of professions. 

The result is that the federal government tends to hire agency by agency while casting a wide geographic net, which limits its ability to build deep and direct relationships with talent providers, while also duplicating searches for similar roles across agencies. Instead, the next Administration should align with jobseekers’ expectations by recruiting across agencies within each geography. 

By embracing a new approach, the government can begin to develop a more coordinated cross-agency employer profile within regions with significant federal presence, while still leveraging its scale by aggregating hiring needs across agencies. This approach would build upon the important hiring reforms advanced under the Biden-Harris Administration, including cross-agency pooled hiring, renewed attention to hiring experience for jobseekers, and new investments to unlock the federal government’s regional presence through elevation of the Federal Executive Board (FEB) program. FEBs are cross-agency councils of senior appointees and civil servants in regions of significant federal presence across the country. They are empowered to identify areas for cross-agency cooperation and are singularly positioned to collaborate to pool talent needs and represent the federal government in communities across the country.

Plan of Action

The next Administration should embrace a cross-agency, regionally-focused recruitment strategy and bring federal career opportunities closer to Americans through a series of 2-3 large scale, cross-agency recruitment and hiring pilots in geographies outside of Washington, DC. To be effective, this effort will need both sponsorship from senior leaders at the center of government, as well as ownership from frontline leaders who can build relationships on the ground. 

Recommendation 1. Provide Strategic Direction from the Center of Government 

The Office of Personnel Management (OPM) and the Office of Management and Budget (OMB) should launch a small team, composed of leaders in recruitment, personnel policy and workforce data, to identify promising localities for coordinated regional hiring surges. They should leverage centralized workforce data or data from Human Capital Operating Plan workforce plans to identify prospective hiring needs by government-wide and agency-specific mission-critical occupations (MCOs) by FEB region, while ensuring that agency and sub-agency workforce plans consistently specify where hiring will occur in the future. They might also consider seasonal or cyclical cross-agency hiring needs for inclusion in the pilot to facilitate year-to-year experimentation and analysis. With this information, they should engage the FEB Center of Operations and jointly select 2-3 FEB regions outside of the capital where there are significant overlapping needs in MCOs. 

As this pilot moves forward, it is imperative that OMB and OPM empower on-the-ground federal leaders to drive surge hiring and equip them with flexible hiring authorities where needed. 

Recommendation 2. Empower Frontline Leadership from the FEBs

FEB field staff are well positioned to play a coordinating role to help drive surges, starting by convening agency leadership in their regions to validate hiring needs and make amendments as necessary. Together, they should set a reasonable, measurable goal for surge hiring in the coming year that reflects both total need and headline MCOs (e.g., “in the next 12 months, federal agencies in greater Columbus will hire 750 new employees, including 75 HR Specialists, 45 Data Scientists, and 110 Engineers”). 

To begin to develop a regional talent strategy, the FEB should form a small task force drawn from standout hiring managers and HR professionals, and then begin to develop a stakeholder map of key educational institutions and civic partners with access to talent pools in the region, sharing existing relationships and building new ones. The FEB should bring these external partners together to socialize shared needs and listen to their impressions of federal career opportunities in the region.

With these insights, the project team should announce publicly the number and types of roles needed and prepare sharp public-facing collateral that foregrounds headline MCOs and raises the profile of local federal agencies. In support, OPM should launch regional USAJOBS skins (e.g., “Columbus.USAJOBS.gov”) to make it easy to explore available positions. The team should make sustained, targeted outreach at local educational institutions aligned with hiring needs, so all federal agencies are on graduates’ and administrators’ radar. 

These activities should build toward one or more signature large, in-person, cross-agency recruitment and hiring fairs, perhaps headlined by a high profile Administration leader. Candidates should be able to come to an event, learn what it means to hold a job in their discipline in federal service, and apply live for roles at multiple agencies, all while exploring what else the federal government has to offer and building tangible relationships with federal recruiters. Ahead of the event, the project team should work with agencies to align their hiring cycles so the maximum number of jobs are open at the time of the event, potentially launching a pooled hiring action to coincide. The project team should capture all interested jobseekers from the event to seed the new Talent Campaigns function in USAStaffing that enables agencies to bucket tranches of qualified jobseekers for future sourcing. 

Recommendation 3. Replicate and Celebrate

Following each regional surge, the center of government and frontline teams should collaborate to distill key learnings and conclude the sprint engagement by developing a playbook for regional recruitment surges. Especially successful surges will also present an opportunity to spotlight excellence in recruitment and hiring, which is rarely celebrated. 

The center of government team should also identify geographies with effective relationships between agencies and talent providers for key roles and leverage the growing use of remote work and location negotiable positions to site certain roles in “friendly” labor markets. 

Conclusion

Regional, cross-agency hiring surges are an opportunity for federal agencies to fill high-need roles across the country in a manner that is proactive and collaborative, rather than responsive and competitive. They would aim to facilitate a new level of information sharing between the frontline and the center of government, and inform agency strategic planning efforts, allowing headquarters to better understand the realities of recruitment and hiring on the ground. They would enable OPM and OMB to reach, engage, and empower frontline HR specialists and hiring managers who are sufficiently numerous and fragmented that they are difficult to reach in the present course of business. 

Finally, engaging regionally will emphasize that most of the federal workforce resides outside of Washington, D.C., and build understanding and respect for the work of federal public servants in communities across the nation.

This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.

PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.

Across the United States, thousands of communities, particularly rural ones, don’t have the capacity to identify, apply for, and manage federal grants. And more than half of Americans don’t feel that the federal government adequately takes their interests into account. These factors make it difficult to build climate resilience in our most vulnerable populations. AmeriCorps can tackle this challenge by providing the human power needed to help communities overcome significant structural obstacles in accessing federal resources. Specifically, federal agencies that are part of the Thriving Communities Network can partner with the philanthropic sector to place AmeriCorps members in Community Disaster Resilience Zones (CDRZs) as part of a new Resilient Communities Corps. Through this initiative, AmeriCorps would provide technical assistance to vulnerable communities in accessing deeply needed resources. 

There is precedent for this type of effort. AmeriCorps programming, like AmeriCorps VISTA, has a long history of aiding communities and organizations by directly helping secure grant monies and by empowering communities and organizations to self-support in the future. The AmeriCorps Energy Communities is a public-private partnership that targets service investment to support low-capacity and highly vulnerable communities in capitalizing on emerging energy opportunities. And the Environmental Justice Climate Corps, a partnership between the Environmental Protection Agency (EPA) and AmeriCorps, will place AmeriCorps VISTA members in historically marginalized communities to work on environmental justice projects. 

A new initiative targeting service investment to build resilience in low-capacity communities, particularly rural communities, would help build capacity at the local level, train a new generation of service-oriented individuals in grant writing and resilience work, and ensure that federal funding gets to the communities that need it most.

Challenge and Opportunity  

A significant barrier to getting federal funding to those who need it the most is the capacity of those communities to search and apply for grants. Many such communities lack both sufficient staff bandwidth to apply and search for grants and the internal expertise to put forward a successful application. Indeed, the Midwest and Interior West have seen under 20% of their communities receive competitive federal grants since the year 2000. Low-capacity rural communities account for only 3% of grants from the Federal Emergency Management Agency (FEMA)’s flagship program for building community resilience. Even communities that receive grants often lack the capacity for strong grant management, which can mean losing monies that go unspent within the grant period.

This is problematic because low-capacity communities are particularly vulnerable to natural disasters from flooding to wildfires. Out of the nearly 8,000 most at-risk communities with limited capacity to advocate for resources, 46% are at risk for flooding, 36% are at risk for wildfires, and 19% are at risk for both.

Ensuring communities can access federal grants to help them become more climate resilient is crucial to achieving an equitable and efficient distribution of federal monies, and to building a stronger nation from the ground up. These objectives are especially salient given that there is still a lot of federal money available through the Inflation Reduction Act (IRA) and the Infrastructure Investment and Jobs Act (IIJA) that low-capacity communities can tap into for climate resilience work. As of April 2024, only $60 billion out of the $145 billion in the IRA for energy and climate programs had been spent. For the IIJA, only half of the nearly $650 billion in direct formula funding had been spent. 

The Biden-Harris Administration has tried to address the mismatch between federal resilience funding and community capacity in a variety of ways. The Administration has deployed resources for low-capacity communities, agencies tasked with allocating funds from the IRA and IIJA have held information sessions, and the IRA and IIJA contain over a hundred technical assistance programs. Yet there still is not enough support in the form of human capacity at the local level to access grants and other resources and assistance provided by federal agencies. AmeriCorps members can support communities in making informed decisions, applying for federal support, and managing federal financial assistance. Indeed, state programs like the Maine Climate Corps, include aiding communities with both resilience planning and emergency management assistance as part of their focus. Evening the playing field by expanding deployment of human capital will yield a more equitable distribution of federal monies to the communities that need it the most. 

AmeriCorps’ Energy Communities initiative serves as a model for a public-private partnership to support low-capacity communities in meeting their climate resilience goals. Over a three-year period, the program will invest over $7.8 million from federal agencies and philanthropic dollars to help communities designated by the Interagency Working Group on Coal & Power Plant Communities & Economic Revitalization on issues revolving around energy opportunity, environmental cleanup, and economic development to help communities capitalize on emerging energy opportunities. 

There is an opportunity to replicate this model towards resilience. Specifically, the next Administration can leverage the Federal Emergency Management Agency (FEMA’s) Community Disaster Resilience Zone (CDRZ) designations to target AmeriCorps support to the communities that need it most. Doing so will not only build community resilience, but will help restore trust in the federal government and its programs (see FAQ).

Plan of Action

The next administration can support vulnerable communities in building climate resilience by launching a new Resilient Communities Corps through AmeriCorps. The initiative can be launched through a three-part Plan of Action: (1) find a philanthropic partner to fund AmeriCorps placements in CDRZs, (2) engage federal agencies that are part of the Thriving Communities Network to provide resilience training and support to Corps members, and (3) use the CDRZ designations to help guide where AmeriCorps members should be placed.  

Recommendation 1. Secure philanthropic funding 

American service programs have a history of utilizing philanthropic monies to fund programming. The AmeriCorps Energy Communities is funded with philanthropic monies from Bloomberg Philanthropies. California Volunteers Fund (CVF), the Waverly Street Foundation, and individual philanthropists helped fund the state Climate Corps. CVF has also provided assistance and insights for state Climate Corps officials as they develop their programs. 

A new Resilient Communities Corps under the AmeriCorps umbrella could be funded through one or several major philanthropic donors, and/or through grassroots donations. Widespread public support for AmeriCorps’ ACC that transcends generational and party lines presents the opportunity for new grassroots donations to supplement federal monies allocated to the program along with tapping the existing network of foundations, individuals, companies, and organizations that have provided past donations. The Partnership for the Civilian Climate Corps (PCCC), which has had a history of collaborating with the ACC’s federal partners, would be well suited to help spearhead this grassroots effort. 

America’s Service Commissions (ASC), which represents state service commissions, can also help coordinate with state service commissions to find local philanthropic monies to fund AmeriCorps work in CDRZs. There is precedent for this type of fundraising. Maine’s state service commission was able to secure private monies for one Maine Service Fellow. The fellow has since worked with low-capacity communities in Maine on climate resilience. ASC can also work with state service commissions to identify current state, private, and federally funded service programming that could be tapped to work in CDRZs or are currently working in CDRZs. This will help tie in existing local service infrastructure.  

Recommendation 2. Engage federal agencies participating in the Thriving Communities Network and the American Climate Corps (ACC) interagency working group. 

Philanthropic funding will be helpful but not sufficient in launching the Resilient Communities Corps. The next administration should also engage federal agencies to provide AmeriCorps members participating in the initiative with training on climate resilience, orientations and points of contact for major federal resilience programs, and, where available, additional financial support for the program. The ACC’s interagency working group has centered AmeriCorps as a multiagency initiative that has directed resources and provides collaboration in implementing AmeriCorps programming. The Resilient Communities Corps will be able to tap into this cross-agency collaboration in ways that align with the resilience work already being done by partnership members. 

There are currently four ACC programs that are funded through cooperation with other federal agencies. These are the Working Lands Climate Corps with the U.S. Department of Agriculture (USDA)’s Natural Resources and Conservation Service, AmeriCorps NCCC Forest Corps with the USDA Forest Service, Energy Communities AmeriCorps with the Department of Interior and the Department of Commerce, and the Environmental Justice Corps, which was announced in September 2024 and will launch in 2025, with the EPA. The Resilient Communities Corps could be established as a formal partnership with one or more federal agencies as funding partners.

In addition, the Resilient Communities Corps can and should leverage existing work that federal agencies are doing to build community capacity and enhance community climate resilience. For instance, USDA’s Rural Partners Network helps rural communities access federal funding while the EPA’s Environmental Justice Thriving Communities Technical Assistance Centers Program provides training and assistance for communities to build the capacity to navigate, develop proposals, and manage federal grants. The Thriving Communities Network provides a forum for federal agencies to provide technical assistance to communities trying to access federal monies. Corps members, through the network, can help federal agencies provide communities they are working with building capacity to access this technical assistance. 

Recommendation 3. Use CDRZ designations and engage with state service commissions to guide Resilient Communities Corps placements

FEMA, through its National Risk Index, has identified communities across the country that are most vulnerable to the climate crisis and need targeted federal support for climate resilience projects. CDRZs provide an opportunity for AmeriCorps to identify low-capacity communities that need their assistance in accessing this federal support. With assistance from partner agencies and philanthropic dollars, the AmeriCorps can fund Corps members to work in these designated zones to help drive resources into them. As part of this effort, the ACC interagency working group should be broadened to include the Department of Homeland Security (which already sponsors FEMA Corps).

In 2024, the Biden-Harris Administration announced Federal-State partnerships between state service commissions and the ACC. This partnership with state service commissions will help AmeriCorps and partner agencies identify what is currently being done in CDRZs, what is needed from communities, and any existing service programming that could be built up with federal and philanthropic monies. State service commissions understand the communities they work with and what existing programming is currently in place. This knowledge and coordination will prove invaluable for the Resilient Communities Corps and AmeriCorps more broadly as they determine where to allocate members and what existing service programming could receive Resilient Communities Corps designation. This will be helpful in deciding where to focus initial/pilot Resilient Communities Corps placements.

Conclusion

A Resilient Communities Corps presents an incredible opportunity for the next administration to support low-capacity communities in accessing competitive grants in CDRZ-designated areas. It will improve the federal government’s impact and efficiency of dispersing grant monies by making grants more accessible and ensure that our most vulnerable communities are better prepared and more resilient in the face of the climate crisis, introduce a new generation of young people to grant writing and public service, and help restore trust in federal government programs from communities that often feel overlooked.

This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.

PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.

Frequently Asked Questions

How much would a Resilient Communities initiative cost?

Funding for one AmeriCorps member in each of FEMA’s 483 designated Community Disaster Resilience Zones would cost around $14,500,000 per year. This is with an estimate of $30,000 per member. However, this figure will be subject to change due to overhead and living adjustment costs.

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Why focus on CDRZ communities? Aren’t there lots of other communities that could also benefit from support?

There are many communities that could benefit from additional support when it comes to building resilience. Headwater Economics, a research institute in Montana, has flagged that the CDRZ does not account for all low-capacity communities hampered in their efforts to become more climate resilient. But the CDRZ designation does provide a federal framework that can serve as a jumping-off point for AmeriCorps to begin to fill capacity gaps. These designations, identified through the National Risk Index, provide a clear picture for where federal, public and private monies are needed the most. These communities are some of the most vulnerable to climate change, lack the resources for resilience work, and need the human capacity to access them. Because of these reasons, the CDRZ communities provide the ideal and most appropriate area for the Resilient Communities Corps to first serve in.

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How would the Resilient Communities initiative help restore local trust in federal government?

Funding for national service programming, particularly for the ACC, has bipartisan support. 53% of likely voters say that national service programming can help communities face climate-related issues.

On the other hand, 53% of Americans also feel that the federal government doesn’t take into account “the interests of people like them.” ACC programming, like what Maine’s Climate Corps is doing in rural areas, can help reach communities and build support among Americans for government programs that can be at times met with hostility.

For example, in Maine, the small and politically conservative town of Dover-Foxcroft applied for and was approved to host a Maine Service Fellow (part of the Maine Climate Corps network) to help the local climate action committee to obtain funding for and implement energy efficiency programs. The fellow, a recent graduate from a local college, helped Dover-Foxcroft’s new warming/cooling emergency shelter create policies, organized events on conversations about climate change, wrote a report about how the county will be affected by climate change, and recruited locals at the Black Fly Festival to participate in energy efficiency programs.

Like the Maine Service Fellows, Resilient Communities Corps members will be integral members of the communities in which they serve. They will gather essential information about their communities and provide feedback from the ground on what is working and what areas need improvement or are not being adequately addressed. This information can be passed up to the interagency working groups that can then be relayed to colleagues administering the grants, improving information flow, and creating feedback channels to better craft and implement policy. It also presents the opportunity for representatives of those agencies to directly reach out to those communities to let them know they have been heard and proactively alert residents to any changes they plan on making.

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Have you ever asked a civil servant in the federal government what it was like to hire new staff? It’s quite common to hear how challenging it is to navigate the hiring process and how long it takes to get someone through the door. At FAS, we know it’s hard. We’ve seen how it works, and we’ve heard stories from civil servants in government.

Following the wave of legislation aimed at addressing infrastructure, environment, and economic vulnerabilities (i.e., the Bipartisan Infrastructure Law (BIL), the Inflation Reduction Act (IRA), and the CHIPS and Science Act (CHIPS)), we knew that the federal government’s hiring needs were going to soar. As we previously stated, permitting is a common bottleneck that would hinder the implementation of BIL, IRA, and CHIPS. The increase in work following this legislation came in conjunction with a push for faster permits, which in turn significantly increased agency workload. Many agencies did not have the capacity to clear the existing backlogs of permitting projects they already had in their pipeline, which would not even begin to address the new demand that would result from these laws. As such, talent capacity, or having staff with the knowledge and skills needed to meet the work demands, presented a major bottleneck. 

We also knew that surge hiring is not a strength of the government, and there are a number of reasons for that; some we highlighted in our recent blog post. It’s a difficult task to coordinate, manage, and support the hiring process for a variety of roles across many agencies. And agencies that are responsible for permitting activities, like environmental reviews and authorizations, do not have standardized roles and team structures to make it easier to hire. Furthermore, permitting responsibility and roles are disaggregated within and across agencies – some roles are permanent, others are temporary. Sometimes responsibility for permitting is core to the job. In other cases, the responsibility is part of other program or regional/state needs. This makes it hard to take concerted and sustained action across government to improve hiring. 

While this sounds like a challenge, FAS saw an opportunity to apply our talent expertise to permitting hiring with the aim of reducing the time to hire and improving the hiring experience for both hiring managers and HR specialists. Our ultimate goal was to enable the implementation of this new legislation. We also knew that focusing on hiring for permitting would offer a lens to better understand and solve for systemic talent challenges across government. 

As part of this work, we had the opportunity to connect and collaborate with the Permitting Council, which serves as a central body to improve the transparency, predictability, and accountability of the federal environmental review and authorization process, to gain a broad understanding of the hiring difficulties experienced across permitting agencies. This helped us identify some of the biggest challenges preventing progress, which enabled us to co-host two webinars for hiring managers, HR specialists, HR leaders, and program leaders within permitting agencies, focused on showcasing tactical solutions that could be applied today to improve hiring processes.

Our team wanted to complement this understanding of the core challenges with voices from agencies – hiring managers, HR specialists, HR teams, and leaders – who have all been involved in the process. We hoped to validate the challenges we heard and identify new issues, as well as capture best practices and talent capacity strategies that had been successfully employed. The intention of this blog is to capture the lessons from our discussions that could support civil servants in building talent capacity for permitting-related activities and beyond, as many solutions identified are broadly applicable across the federal government.

Approach

Our team at FAS reached out to over 55 civil servants who work across six agencies and 17 different offices identified through our hiring webinars to see if they’d be willing to share about their experiences trying to hire for permitting-related roles in the implementation of IRA, BIL, and CHIPS. Through this outreach, we facilitated 14 interviews and connected with 18 civil servants from six different organizations within the Environmental Protection Agency, Department of Defense, Department of Interior, U.S. Department of Agriculture, and the Department of Commerce. The roles of the participants varied; it included Hiring Managers, HR Specialists, HR Leaders, Chief Environmental Review and Permitting Officers, and Chief Human Capital Officers.

In our conversations, we focused on identifying their hiring needs to support permitting-related activities within their respective organization, the challenges they experience in trying to hire for those new positions, what practices were successful in their hiring efforts, and any recommendations they had for other agencies. We synthesized the data we gathered through these discussions and identified common challenges in hiring, successful hiring practices, talent capacity strategies, and additional tips for civil servants to consider.

Challenges to Hiring

We identified many challenges hindering agencies from quickly bringing on new staff to fill their open roles. From the start, many teams responsible for permitting were already very understaffed. One interviewee explained that they had serious backlogs requiring complex analysis, but were only able to triage and take on what was feasible. Another shared that they initially were only processing 60% of their workload annually. A third interviewee explained that some of their staff had previously been working on 4-5 Environment Impact Statements (EIS) at one time, which is very high and not common for the field. Their team had a longstanding complaint about high workload that led to a high attrition rate, which only increased the need for more hires. In addition to the permitting teams being under resourced, many HR counterpart teams were also understaffed. This created an environment where teams needed to hire a significant number of new staff, but did not necessarily have the HR support necessary to execute. 

The budget was the next issue many agencies faced. The budget constraints resulting from the time-bound funding of IRA and BIL raised a number of important questions for the agencies. BIL funds expire at the end of FY2026 and IRA funds expire anywhere between 2-10 years from the legislation passing in 2022. For example, the funds allocated to the Permitting Council in the IRA expire at the end of FY2031, and some of these funds have been given to agencies to bolster workforce capacity for supporting timely permitting reviews. Ultimately, agencies needed to decide if they wanted to hire temporary or full time employees. This decision cannot be made without additional information and analysis of retirement rates, attrition rates, and other funding sources. 

In addition to managing the budgetary constraints, agencies needed to determine how they would allocate the funds provided to their bureaus and programs. This required negotiations, justifications, and many discussions. The ability of Program Leaders to negotiate and justify their allocation is dependent upon their ability to accurately conduct workforce planning, which was a challenge identified through interviews. Specifically, some managers were challenged to accurately plan in an environment that is demand-driven and continuously evolving. Additionally, managing staff who have a variety of responsibilities and may only work on permitting projects for a portion of their time only increases the complexity of the planning process. 

A number of challenges we heard were common pain points in the federal government’s hiring process, as noted in Many Chutes and Few Ladders in the Federal Hiring Process. These include:

• Assessments: Inadequate assessments have led to issues with the certificate lists of eligible candidates provided from the HR Specialist to the hiring manager. Some hiring managers have received lists with too many candidates to choose from, while others have been disappointed to not see qualified candidates on the list. This is largely a result of assessments that do not effectively screen qualified applicants. Self-assessments are an example of this, where applicants score their own abilities in response to a series of multiple choice questions. From our conversations, self-assessments are still a commonly used practice, and skills-based assessments have not been widely adopted.
• Job Descriptions: Both creating new and updating job descriptions has caused delays in the hiring process. Some agencies have started moving towards standardized job descriptions with the goal of making the process more efficient, but this has not been an easy task and has required a lot of time for collaboration across a variety of stakeholders.
• Background Checks: Delays in background checks have slowed the process. These delays often result from mistakes in or incomplete Electronic Questionnaires for Investigations Processing (e-QIP) forms, delays in scheduling fingerprint appointments, a lack of infrastructure for sharing and tracking information between key stakeholders (e.g., selected applicant, suitability manager, hiring manager), and delayed responses to notifications in the process.
• Candidate Declinations: Candidates declining a job offer have set a number of agencies back, especially those lacking deep applicant pools. The reasons provided have varied. Some applicants believed that the temporary positions were negotiable or did not realize they had applied to a term position, and they were no longer interested. In some cases, agency hiring managers did not know they had hiring flexibilities or incentives to offer that may have bridged the gap for the candidate. Others were unable to accept the offer for the specific location, citing the increased cost of living and housing prices as a barrier.

Lastly, recruiting was noted as a challenge by a number of participants. Recruiting for a qualified applicant pool has been difficult, especially for those looking to hire very specialized roles. One participant explained their need for someone with experience working in a specific region of the country and the limitations that came with not being able to offer a relocation bonus. Another participant described the difficulty in finding qualified candidates at the right grade level because the pay scale was very limiting for the expertise required. These challenges are exacerbated in agencies that lack recruiting infrastructure and dedicated resources to support recruitment.

These challenges manifested as bottlenecks in the hiring process and present opportunities for improvement. Apart from the new, uncertain funding, these challenges are not novel. Rather, these are issues agencies have been facing for many years. The new legislation has drawn broader attention back to these problems and presents an opportunity for action. 

Successful Hiring Practices

Despite these bottlenecks, participants shared a number of practices they employed to improve the hiring process and successfully bring new staff onboard. We wanted to share seven (7) practices that could be adopted by civil servants today.

Establish Hiring Priority and Gain Leadership Support

One agency leveraged the Biden-Harris Permitting Action Plan to establish and elevate their hiring needs. Following the guidance shared by OMB, CEQ, and the Permitting Council, this agency set out to develop an action plan that would function as a strategic document over the next few years. They employed a collaborative approach to develop their plan. The Chief Environmental Review and Permitting Officer (CERPO) and Deputy CERPO, the roles responsible for overseeing environmental review and permitting projects within their agencies and under their jurisdiction, brought together a team of NEPA Specialists and other staff engaged in environmental reviews and permitting across their organizations with equities. This group collectively brainstormed what they could do to strengthen and streamline permitting and environmental reviews at their agency. From this list, they prioritized five key focus areas for the first phase of their plan. This included hiring as the highest priority because it had been identified as a critical issue. Given their positioning within the organization and the Administration’s mandate, they were able to gain the support of the Secretary, and as a result, escalate their hiring needs to fill over 30 open positions over the course of FY24.

Collaborate and Share Across the Organization

Sharing and collaborating across the agency helped many expedite the hiring process. Here are examples that highlight the importance of this for success.
(1) One agency described how they share position descriptions across the enterprise. They have a system that allows any hiring manager to search for a similar position that they could use themselves or refine for their specific role. This reduces the time spent by hiring managers recreating positions.

(2) Another agency explained how they created an open tracking tool of positions they were interested in hiring across the organization. This tool allowed hiring managers across the agency to share the positions they wanted to hire. The initial list included 300 potential positions; it allowed them to prioritize and identify opportunities for collaboration. By leveraging shared certificates, they were able to reduce duplication. This tool evolved into an open repository of positions the organization was looking to recruit and a timeline for when they would be recruiting for those roles. Once announcements were closed, they would share the certificate lists widely to hiring managers.

(3) In another example, the participant explained how they facilitated ongoing collaboration between the CERPO, CHCO, HQ, and both HR and Program Leads from each relevant bureau to drive forward the hiring process. They initially worked with the Program Leads from the key bureaus impacted to identify their hiring needs and discuss the challenges they were facing. Then they reached out to the CHCO to engage them and share their priority hiring needs and worked to bring in each bureau’s respective HR teams to provide technical assistance. With everyone engaged, they set up a regular check-in to discuss progress, and the group collaborated to develop and classify position descriptions for the open positions. Later once candidates had been selected, they collaborated with operations to prioritize their hires in suitability. This ultimately saved time and streamlined the process.

Improve Hiring Processes

Participants described improving hiring processes within their organization through a variety of approaches. One method that we heard numerous times is standardizing job descriptions across the enterprise to reduce duplicative job revision and classification efforts and support the use of shared certifications. One agency approached this by facilitating focus groups with key stakeholders to define the non-negotiable and “nice to have” duties for the role. These sessions included classifiers, domain specialists, leadership, and data analysts. They found that when the group started discussing the knowledge and skills that really mattered, they were able to understand why combining efforts would help them achieve their goals more quickly. They realized that some of the minute details (e.g., expertise in Atlantic Salmon) did not need to be in the position description and rather could be deduced through the interview process. While this took a great deal of buy in and leadership support, they were successful in standardizing some position descriptions.

Other methods for improving hiring processes included standardizing the process for establishing pay to reduce competition across the agency, setting a 30-day time limit for making selections, setting applicant limits for closing job announcements, and using data to drive improvements. In one interview with an agency’s HR team, we learned about their role in collecting and analyzing data in each step of the hiring process (e.g., overall hiring time, time at each step, etc.). They use this information to monitor progress, track performance, understand which incentives are being employed, and identify opportunities for improvement in the overall process. This data helps inform their decisions and allows them to identify where they need to provide more support.

Leverage Position and Recruiting Incentives

Multiple participants described using incentives to make a position more attractive to a candidate and encourage the acceptance of a job offer. Multiple agencies offered remote and hybrid positions where possible, which they cited as generating more interest in the role. One HR team shared how they employ a series of OPM approved recruiting incentives to make positions more compelling. These included starting bonuses, student loan repayment, credit for industry work, advanced leave, higher step options, relocation bonuses, and additional leave time. They find these incentives to be particularly helpful when the location requires a far move (e.g., Alaska, Hawaii) or is difficult to hire into for whatever reason. 

Leverage Hiring Flexibilities

Multiple agencies cited using different hiring flexibilities to hire for their open positions and remove some of the barriers embedded in the competitive service hiring process. The flexibilities included, Direct Hire Authority, Schedule A, Pathways Programs, retired annuitants, internship conversions, internal detailees, Presidential Innovation Fellows via GSA, Digital Service Fellows Program, as well as contract staff to support IT development. Many agencies also hired for term or temporary positions that ranged from three to 10 years, depending on the additional funding sources that could be found. Employing these authorities helped to streamline the hiring process.

Seek HR Recruiting Support

One agency described how their HR office supported and collaborated with hiring managers throughout the hiring process, especially in bolstering their recruitment efforts. One HR team helped lead recruitment outreach, sharing their open positions on a variety of media in coordination with their communications team (i.e., their website, facebook, instagram). They also developed standard language for hiring managers to share with their networks that highlighted information about the role and mistakes to avoid when applying. This helped relieve the pressure on the hiring manager to lead the recruiting effort.

Invest in Dedicated HR Staff to Manage and Support Permitting Hiring

Multiple agencies shared how they hired a dedicated resource to oversee the hiring process for their organization. One agency hired a retired annuitant (i.e., someone who retired from working in the federal government and is rehired) to help manage the organization’s hiring process after they realized that they were making minimal progress against their hiring needs. This individual returned to the government workforce and brought a deep understanding of government hiring. They collaborated with the HR Specialists and hiring managers to develop position descriptions, organize procurement packages, schedule interviews, and support the applicant selection process. They said, “we would not have been able to do any of the 40 hires without this person.”

Another agency described how they detailed someone to manage BIL and IRA hiring requests across their organization. This person was situated outside of HR, and they were responsible for tracking the end-to-end hiring and recruitment efforts. They maintained a repository of the positions each office needed to recruit and generated weekly reports on BIL and IRA hiring efforts that highlighted how many positions are open, how many are closed, and where certificate lists are available. This allowed the broader team to identify how they could drive progress.

While there were a number of challenges, many participants described successfully hiring 15-30+ new employees over the last year alone. One agency in particular described hiring over 2,000 people in 2024 for the IRA, which was an all time high for their organization. These seven practices have enabled agencies to be successful in filling new positions to support permitting-related activities, and they can be applied to other hiring needs as well. Any future talent surge in the federal government could benefit from adopting these hiring practices.

Solutions to Build Talent Capacity

While the majority of the interviews focused on hiring due to concerns of understaffed teams and the new funding availability, there are many other ways to build talent capacity in government. Some of the participants we interviewed shared other strategies they employed to address high workload demands, which present opportunities for other agencies to consider, especially as we move into the new administration. Here are six (6) strategies for building workforce capacity.

Establish Strike Teams

During our conversations, two different agencies described creating a strike team, or making an investment in additional, flexible staff, to provide supplemental capacity where there is insufficient staff for the current demand. One organization accomplished this by hiring project managers with NEPA expertise into their CERPO Office. These Project Managers could then be detailed out to specific bureaus to fill capacity gaps and provide management for high priority, multi-agency projects. This helped fill immediate capacity gaps, as teams were continuing to hire.

Another agency piloted a relief brigade, or a pool of Headquarters (HQ) staff who could be detailed to support regional staffing needs on large projects, consultations, and backlogs with temporary funding. This team was formed from a national perspective and aimed to reduce the pressure on each region and center. Based on this organization’s needs, the team was composed of natural resource management and biological science generalists. Participants shared that some efficiencies have been gained, but there was a substantial learning curve that required training and learning on the job. One hiring manager stated, the “relief brigade is the permanent embodiment of what we need more of.” These types of teams can help address dynamic capacity needs and provide more flexibility to the organization more broadly.

Conduct Bottom Up Workforce Analysis

One Program Manager shared their experience joining a new team and conducting workforce analysis to quantify their staffing needs and inform strategic decisions for their organizational structure. In their initial discussions with staff, they learned that many employees were feeling overworked and capacity was a major concern. To understand the need, they conducted a bottom up workforce analysis to estimate the office’s workload and identify gaps. This involved gathering project data from the past two years, identifying the average time frame by activity type and NEPA category, the staff hours needed to accomplish the work, and the delta between existing and needed staff hours. This data provided evidence of capacity gaps, which they were able to bring to their senior leadership to advocate and secure approval for a team expansion. This analysis enabled them to make data informed decisions about hiring that would reduce the overall workload of staff and ultimately increase staff morale and improve retention rates, which had been a concern. This approach can serve as a model for other agencies who have had difficulty in workforce planning.

Reorganize Team to Drive Efficiencies

The Program Manager who conducted bottom-up workforce analysis applied this new understanding of the work and the demands to reorganize their team to drive efficiencies and share the workload. They established three branches in their team and added four supervisory roles. The branches included one NEPA Branch, one Archeological Branch, and a Program and Policy Branch, and a supervisor was established for each. An additional leadership Deputy role was created to focus on overseeing their programs and coordinating on integration points with relevant agencies.

With this shift, they created new processes and roles to support continuous improvements and fill outstanding duties. Specifically, the Program and Policy Branch is designed to be more proactive, support throughput, and build programmatic and tribal agreements. They added an environmental trainer who is responsible for educating both internal staff and external stakeholders. Two Environmental Protection Specialists now oversee project intake, collaborate with applicants to ensure the applications are complete, manage applicant communications, and then distribute the projects to the assigned owner. A GIS Program Manager was added to the team to support data and analytics. Their role is to identify process delays and their causes, analyze points of failure, and create a geological database to understand where there are project overlaps to expedite and streamline processes. In addition to these internal changes, the Program Manager has also brought on additional contractors to provide greater capacity.

These changes have significantly increased their team’s capacity and has over doubled the number of projects they are able to complete in a year, from 400 projects two years ago to over 900+ projects this year.

Reallocate Work Across Offices and Regions

Numerous participants described work reallocation as a solution to addressing some of their capacity gaps. For example, when one agency was struggling to hire people in a particular location due to the high cost of living, they redistributed the work to another region in the country, where the cost of living was lower. This made it easier to hire into the position. Another HR Leader described supporting their overcapacity teams by redistributing hiring efforts from one office to another in the same region. The original office had minimal bandwidth, while the other had capacity, so they were able to help post the job announcement for the region. They explained the importance of encouraging local offices to help one another deliver, when appropriate.

Others described the reallocation of staff and projects to different regions. This not only allows the organization to match staff with demand, but it also allows for staff to gain experience and knowledge working on a new topic or in a new region. For example, most offshore wind projects are located in the greater Atlantic region, but these projects are gaining traction in the Pacific, so they assigned staff to work in the Atlantic region with the goal of building experience and gaining lessons learned to apply to future Pacific projects. One of these participants emphasized the value and efficiencies that could be derived from developing staff to have more interagency and interservice experience. These examples highlight how leaders can be creative in addressing workload gaps by strategically reallocating work to pair capacity and demand.

Invest in Recruiting Networks

One agency stood out as being an exemplar for their recruiting efforts, which have the potential to be replicated across agencies. They have spent significant time and effort investing in building out their recruitment networks and engaging in career fairs to hire talent. Their organization has been building a repository of potential candidates that is maintained in a system to capture candidate information, educational background, contact information, locations of interest, areas of interest, and remote and relocation preferences. This has been used to generate a list of potential candidates for hiring managers. 

They have made connections through affinity groups, communities of practice, and social media. They’ve also built many partnerships with schools and organizations and have a calendar of events (e.g., career fairs) that they attend over the course of the year. At some events, they’ll have their HR team facilitate breakout sessions to discuss the benefits of working at their organization. To make sure they’re getting diverse candidates, they are continuously reaching out to new sources and potential candidate pools.

In addition to engaging in others’ events, they have hosted their own career fair, where they hired about 200 people. Prior to the event, they reviewed and vetted resumes to know who might be a qualified candidate for a position. With Direct Hire Authority for some of their positions, this allowed hiring managers to interview candidates at the fair and immediately make temporary job offers to attendees. HR staff also worked with the hiring managers at the career fair. This infrastructure sets hiring managers up for success and enables them to easily tap into a variety of networks to find qualified candidates.

Invest in Hiring Manager Training

One agency’s training and support for hiring managers can serve as a model for other HR teams to learn from. This agency offers a robust toolkit for supporting hiring managers through the hiring process. While the Supervisor is ultimately responsible for the hiring, the HR team ensures that they have the tools needed to execute and are equipped to be successful. These tools include:

• Handouts on HR highlights to ensure key information is simple and clear;
• Videos on Recruitment, Relocation, and Retention Incentives and Direct Hire Authority, which are posted on their website for all employees to access; 
• Annual talent acquisition workshops in-person and virtually to hear from speakers and discuss recruitment and marketing strategies; and 
• A Train-the-Trainer program on how to have recruitment conversations.

In addition to these tools and training, HR Specialists work with hiring managers to coach them on how to determine the duties for their open position, especially if they need to re-announce a position multiple times. They are also developing a new marketing strategy centered on everyone being a recruiter. This strategy will result in a new resource to support all staff in recruiting and retaining staff based on their needs.

Another participant identified this as a key opportunity. “Agencies need to educate hiring managers on those processes and what’s out there and available to them… [hiring managers need to] utilize those tools and work with HR to get the best candidates.” This agency’s approach empowers hiring managers to navigate the process, leverage incentives, and successfully recruit.

Establish Apprenticeship Programs

One participant highlighted the need for apprenticeship programs in their permitting work. Short-term or summer internship programs present difficulties with early career staff because there is not enough time for the interns to learn. They explained that it takes about six months for a new employee to become independent. Given this need, they have invested in a 1-year internship program through GeoCorps America. This duration provides interns with the time needed to learn on-the-job through practice, understand the laws and regulations, and gain exposure to the work (e.g., problem solving and stakeholder communication). This program has been successful in creating a pipeline of early career talent; 12 of their interns have moved into permanent federal service positions at different agencies (i.e., DOI, USFS, USGS, and BLM). This type of apprenticeship program could serve as a model for developing early career talent that can be trained on the job and build expertise to take on more complex projects as they grow.

These strategies offer a few examples for how agencies could build workforce capacity. These strategies do not necessarily require bringing on new talent, but rather finding opportunities to improve their internal processes to drive efficiencies and build a more dynamic, flexible workforce to respond to new demand.

Other Considerations

At the end of our interviews, we asked participants if they had any tips or recommendations that they’d want to share with others looking to hire in the government. Here are a few things we heard that we have not already captured in our best practices or talent capacity strategies.

1. Always Be Recruiting: Everyone is a recruiter, and you should always be building relationships and connections, being present at events even if you do not have any active job announcements.
2. Maintain Communication with Candidates: Stay in touch with potential candidates before there is a job open, while recruiting, and throughout the entire hiring process. This can keep them engaged and help you ultimately receive a job acceptance.
3. Invest in Suitability Case Management: Invest in a case management system that sends automatic notifications to each user (i.e., hiring manager, HR specialist, applicant, suitability team) when an action is required. This will streamline the process and ensure that no cases slip through the cracks.
4. Cast a Wide Net: Invest in a wide distribution for your job announcements, interview as many qualified people as you can, and identify multiple candidates that you would like to hire, in case someone declines. Also, leave the announcement open for longer, and if you have large offices with continuous turnover, consider keeping a job open on USAJobs, where you can always accept resumes.
5. Keep Certificate Lists Open: Keep certificate lists open for a long time, so if a candidate declines, you can return to the list of potential candidates. If it is a shared certificate, then this can also assist your colleagues in quickly finding qualified candidates to interview and hire.
6. Regularly Update Position Descriptions: Update your position descriptions to accurately capture the duties of the role and to align with any updated technology. Many agencies have policies for how regularly position descriptions need to be updated, but many question how well these guidelines are followed.
7. Listen to Your Staff’s Plans: Engage with your staff on a regular basis and pay attention to who says they may retire or leave in the next year. This will allow you to more proactively plan and predict your future staffing needs.

Hiring into the federal government is not easy – you will very likely experience challenges even if you follow the practices and strategies highlighted here. However, there are things you can do to set yourself up for success in the future and strategies you can use to address workload demands even if you are not currently hiring. This permitting hiring surge has offered an opportunity to learn how you can effectively hire people into the federal workforce, which can serve as an example for future talent surges. Within the permitting space itself, these strategies have proven successful in supporting more timely and efficient reviews. Bolstering workforce capacity has enabled more effective mission execution.

The United States Agency for International Development (USAID) currently uses Cost-Plus-Fixed-Fee (CPFF) as its de facto default funding and contracting model. Unfortunately, this model prioritizes administrative compliance over performance, hindering USAID’s development goals and U.S. efforts to counter renewed Great Power competition with Russia, the People’s Republic of China (PRC), and other competitors. The U.S. foreign aid system is losing strategic influence as developing nations turn to faster and more flexible (albeit riskier) options offered by geopolitical competitors like the PRC. 

To respond and maintain U.S. global leadership, USAID should transition to heavily favor a Fixed-Price model – tying payments to specific, measurable objectives rather than incurred costs – to enhance the United States’ ability to compete globally and deliver impact at scale. Moreover, USAID should require written justifications for not choosing a Fixed-Price model, shifting the burden of proof. (We will use “Fixed-Price” to refer to both Firm Fixed Price Contracts and Fixed Amount Award Grants, wherein payments are linked to results or deliverables.) 

This shock to the system would encourage broader adoption of Fixed-Price models, reducing administrative burdens, incentivizing implementers (of contracts, cooperative agreements, and grants) to focus on outcomes, and streamlining outdated and inefficient procurement processes. The USAID Bureau for Management’s Office of Acquisition and Assistance (OAA) should lead this transition by developing a framework for greater use of Firm Fixed Price (FFP) contracts and Fixed Amount Award (FAA) grants, establishing criteria for defining milestones and outcomes, retraining staff, and providing continuous support. With strong support from USAID leadership, this shift will reduce administrative burdens within USAID and improve competitiveness by expanding USAID’s partner base and making it easier for smaller organizations to collaborate. 

Challenge and Opportunity

Challenge

The U.S. remains the largest donor of foreign assistance around the world, accounting for 29% of total official development assistance from major donor governments in 2023. Its foreign aid programs have paid dividends over the years in American jobs and economic growth, as well as an unprecedented and unrivaled network of alliances and trading partners. Today, however, USAID has become mired once again in procurement inefficiencies, reversing previous trends and efforts at reform and blocking – for years – sensible initiatives such as third country national (TCN) warrants, thereby reducing the impact of foreign aid for those it intends to help and impeding the U.S. Government’s (USG) ability to respond to growing Great Power Competition.

Foreign aid serves as a critical instrument of foreign policy influence, shaping geopolitical landscapes and advancing national interests on the global stage. No actor has demonstrated this more clearly than the PRC, whose rise as a major player in global development adds pressure on the U.S. to maintain its leadership. Notably, China has increased its spending of foreign assistance for economic development by 525% in the last 15 years. Through the Belt & Road Initiative, its Digital Silk Road, alternative development banks, and increasingly sophisticated methods of wielding its soft power, the PRC has built a compelling and attractive foreign assistance model which offers quick, low-cost solutions without the governance “strings” attached to U.S. aid. While it seems to fulfill countries’ needs efficiently, hidden costs include long-term debt, high lifecycle expenses, and potential Chinese ownership upon default. 

By contrast, USAID’s Cost-Plus-Fixed-Fee (CPFF) foreign assistance model – in which implementers are guaranteed to recover their costs and earn a profit – mainly prioritizes tracking receipts over achieving results and therefore often fails to achieve intended outcomes, with billions spent on programs that lack measurable impact or fail to meet goals. Implementers are paid for budget compliance, regardless of results, placing all performance risk on the government. 

The USG invented CPFF to establish fair prices where no markets existed. However, its use has now extended far beyond this purpose – including for products and services with well-established commercial markets. The compliance infrastructure necessary to administer USAID awards and adhere to the documentation/reporting requirements favors entrenched contractors – as noted by USAID Administrator Samantha Power – stifles innovation, and keeps prices high, thereby encumbering America’s ability to agilely work with local partners and respond to changing conditions. (Note: USAID typically uses “award” to refer to contracts, cooperative agreements, and grants. We use “award” in this same manner to refer to all three procurement mechanisms. We use “Fixed-Price Awards” to refer to fixed-price grants and contracts. “Fixed Amount Awards,” however, specifically refers to a fixed-price grant.)

In light of the growing Great Power Competition with China and Russia – and threats by those who wish to undermine the US-led liberal international order – as well as the possibility of further global shocks like COVID-19 or the war in Ukraine, USAID must consider whether its current toolset can maintain a position of strategic strength in global development. Furthermore, amid declining Official Development Assistance (ODA) – 2% year-over-year – and a global failure to meet the UN Sustainable Development Goals (SDGs), it is critical for USAID to reconcile the gap between its funding and lack of results. Without change, USAID funding will largely continue to fall short of objectives. The time is now for USAID to act.

Opportunity

While USAID cannot have a de jure default procurement mechanism, CPFF has become the de facto default procurement mechanism, but it does not have to be. USAID has other mechanisms to deploy funding at its disposal. In fact, at least two alternative award and contract pricing models exist:

1. Time and materials (T&M): The implementer proposes a set of fully loaded (i.e., inclusive of salary, benefits, overhead, plus profit) hourly rates for different labor categories and the USG pays for time incurred – not results delivered.
2. Fixed-Price (Firm Fixed Price, FFP, for contracts, or Fixed Amount Award, FAA/Fixed Obligation Grants, FOG, for grants): The implementer proposes a set fee and is paid for milestones or results (not receipts).

While CPFF simply reimburses providers for costs plus profit, the Fixed-Price alternatives tie funding to achieving milestones, promoting efficiency and accountability. The Code of Federal Regulations (§ 200.1) permits using Fixed-Price mechanisms whenever pricing data can establish a reasonable estimate of implementation costs. 

USAID has acknowledged the need to adapt funding mechanisms to better support local and impact-driven organizations and enhance cost-effectiveness. USAID has already started supporting these goals by incorporating evidence-based approaches and transitioning to models that emphasize cost-effectiveness and impact. As an example, in the Biden administration, USAID’s Office of the Chief Economist (OCE) issued the Promoting Impact and Learning with Cost-Effectiveness Evidence (PILCEE) award, which aims to enhance USAID’s programmatic effectiveness by promoting the use of cost-effectiveness evidence in strategic planning, policy-making, activity design, and implementation. Progress, though, remains limited. Funding disbursed based on performance milestones has remained unchanged since Fiscal Year (FY) 2016. In FY 2022, Fixed Amount Awards represented only 12.4% of new awards, or 1.4% by value. 

An October 2020 Stanford Social Innovation Review article by two USAID officials argued that the Agency could enhance its use of Fixed Amount Awards by promoting “performance over compliance”. Other organizations have already begun to make this shift: the Millennium Challenge Corporation (MCC) and The Global Fund to Fight AIDS, Tuberculosis and Malaria – among others – have invested in increasing results-based approaches and embedding different results-based instruments into their procurement processes for increased aid effectiveness.

Results Over Receipts: Similar Examples

Millennium Challenge Corporation (MCC)	MCC has increasingly adopted results-based approaches and embedded results-based instruments such as performance-based contracts and awards into its Compact procurement to enhance the cost-effectiveness of its investments and of service provision. This progress includes the expansion of MCC’s portfolio to at least USD 40 million RBF programs in implementation or planning. spanning sectors such as health, energy, agriculture, utility management, gender, education, and public infrastructure in seven countries, along with far greater use of Fixed-Amount Grants paying for milestones across MCC’s wider portfolio.
The Global Fund to Fight AIDS, Tuberculosis and Malaria	Since 2021, The Global Fund has supported its Principal Recipients across more than ten countries to use results-based contracts to improve results. It has created a “How to Guide and Toolkit” that offers a systematic path to design results-based contracts that avoid common traps and are compliant with The Global Fund requirements, templates, and intervention-specific guidelines for malaria bed nets mass campaigns and HIV prevention, diagnostic and treatment services for key populations.
Switzerland	Switzerland has increasingly shifted from traditional input-based methods to results-based approaches. A recent review found a diverse body of 51 results-based finance applications with both private and public actors by the State Secretariat of Economic Affairs (SECO) and the Swiss Agency for Development and Cooperation (SDC).

To shift USAID into an Agency that invests in impact at scale, we propose going one step further, and making Fixed-Price awards the de facto default procurement mechanism across USAID by requiring procurement officials to provide written justification for choosing CPFF. 

This would build on the work completed during the first Trump administration under Administrator Mark Green, including the creation of the first Acquisition and Assistance Strategy, designed to “empower and equip [USAID] partners and staff to produce results-driven solutions” by, inter alia, “increasing usage of awards that pay for results, as opposed to presumptively reimbursing for costs”, and the promotion of the Pay-for-Results approach to development.

Such a change would unlock benefits for both the USG and for global development, including:

1. Better alignment of risk and reward by ensuring implementers are paid only when they deliver on pre-agreed milestones. The risk of not achieving impact would no longer be solely borne by the USG, and implementers would be highly incentivized to achieve results.
2. Promotion of a results-driven culture by shifting focus from administrative oversight to actual outcomes. By agreeing to milestones at the start of an award, USAID would give implementers flexibility to achieve results and adapt more nimbly to changing circumstances and place the focus on performing and reporting results, rather than administrative reporting.
3. Diversification of USAID’s partner base by reducing the administrative burden associated with being a USAID implementer. This would allow the Agency to leverage the unique strengths, contextual knowledge, and innovative approaches of a diverse set of development actors. By allowing the Agency to work more nimbly with small businesses and local actors on shared priorities, it would further enhance its ability to counter current Great Power Competition with China and Russia.
4. Incentivization of cost efficiency, motivating implementers to reduce expenses if they want to increase their profits, without extra cost to the USG.
5. Facilitation of greater progress by USAID and the USG toward the UN’s 2030 Agenda for Sustainable Development, in ways likely to attract more meaningful and substantive private sector partnerships and leverage scarce USG resources.

Plan of Action 

Making Fixed-Price the de facto default option for both grants and contracts would provide the U.S. foreign aid procurement process a necessary shock to the system. The success of such a large institutional shift will require effective change management; therefore, it should be accompanied with the necessary training and support for implementing staff. This would entail, inter alia, establishing a dedicated team within OAA specialized in the design and implementation of FFPs and FAAs; and changing the culture of USAID procurement by supporting both contracting and programming staff with a robust change management program, including training and strong messaging from USAID leadership and education for Congressional appropriators. 

Recommendation 1. Making Fixed-Price the de facto “default” option for both grants and contracts, and tying payments to results. 

Fixed-Price as the default option for both grants and contracts would come at a low additional cost to USAID (assuming staff are able to be redistributed). The Agency’s Senior Procurement Executive, Chief Acquisition Officer (CAO), and Director for OAA should first convene a design working group composed of representatives from program offices, technical offices, OAA, and the General Counsel’s office tasked with reviewing government spending by category to identify sectors exempt from the “Fixed-Price default” mandate, namely for work that lacks deep commercial markets (e.g., humanitarian assistance or disaster relief). This working group would then propose a phased approach for adopting Fixed-Price as the default option across these sectors. After making its recommendations, the working group would be disbanded and a more permanent dedicated team would carry this effort forward (see Recommendation 2).

Once reset, Contract and Agreement Officers would justify any exceptions (i.e., the choice of T&M or CPFF) in an explanatory memo. The CAO could delegate authority to supervising Contracting Officers or other acquisition officials to approve these exceptions. To ensure that the benefits of Fixed-Price results-based contracting reach all levels of awardees, this requirement should become a flow-down clause in all prime awards. This will require additional training for the prime award recipient’s own overseers.

Recommendation 2. Establishing a dedicated team within USAID’s OAA, or the equivalent office in the next administration, specialized in the design and implementation of FFPs and FAAs.

To facilitate a smooth transition, USAID should create a dedicated team within OAA specialized in designing and implementing FFPs and FAAs using existing funds and personnel. This team would have expertise in the choices involved in designing Fixed-Price agreements: results metrics and targets, pricing for results, and optimizing payment structures to incentivize results.

They would have the mandate and resources necessary to support expanding the use of and the amount of funding flowing through high-quality FFPs and FAAs. They would jumpstart the process and support Acquisition and Program Officers by developing guidelines and procedures for Fixed-Price models (along with sector-specific recommendations), overseeing their design and implementation, and evaluating effectiveness. As USAID will learn along the way about how to best implement the Fixed-Price model across sectors, this team will also need to capture lessons learned from the initial experiences to lower the costs and increase the confidence of Acquisition and Assistance Officers using this model going forward. 

Recommendation 3. Launching a robust change management program to support USAID acquisition, assistance, program, and legislative and public affairs staff in making the shift to Fixed-Price grant and contract management. 

Successfully embedding Fixed-Price as the default option will entail a culture shift within USAID, requiring a multi-faceted approach. This will include the retraining of Contracts and Agreements Officers and their Representatives – who have internalized a culture of administrative compliance and been evaluated primarily on their extensive administrative oversight skills – and promoting a reorganization of the culture of Monitoring, Evaluation and Learning (MEL) and Collaboration, Learning and Adaptation (CLA) to prioritize results over reporting. Setting contracting and agreements staff up for success requires capacity building in the form of training, toolkits, and guidelines on how to implement Fixed-Price models across USAID’s diverse sectors. Other USG agencies make greater use of Fixed-Price awards, and alternative training for both government and prime contractor overseers exists. OAA’s Professional Development and Training unit should adapt existing training from these other agencies, specifically ensuring it addresses how to align payments with results.

Furthermore, the broader change management program should seek to create the appropriate internal incentive structure at the Agency for Acquisition and Assistance staff, motivating and engaging them in this significant restructuring of foreign aid. To succeed at this, the mandate for change needs to come from the top, reassuring staff that the Fixed-Price model does not expose individuals, the Agency, or implementers to undue legal or financial liability.

While this change will not require a Congressional Notification, the Office of Legislative & Public Affairs (LPA) should join this effort early on, including as part of the design working group. LPA would also play a guiding role in both internal and external communications, especially in educating members of Congress and their staffs on the importance and value of this change to improve USAID effectiveness and return on taxpayer dollars. Entrenched players with significant investments in existing CPFF systems will resist this effort, including with political lobbying; LPA will play an important role informing Congress and the public.

Conclusion

USAID’s current reliance on CPFF has proven inadequate in driving impact and must evolve to meet the challenges of global development and Great Power Competition. To create more agile, efficient, and results-driven foreign assistance, the Agency should adopt Fixed-Price as the de facto default model for disbursing funds, prioritizing results over administrative reporting. By embracing a results-based model, USAID will enhance its ability to respond to global shocks and geopolitical shifts, better positioning the U.S. to maintain strategic influence and achieve its foreign policy and development objectives while fostering greater accountability and effectiveness in its foreign aid programs. Implementing these changes will require a robust change management program, which would include creating a dedicated team within OAA, retraining staff and creating incentives for them to take on the change, ongoing guidance throughout the award process, and education and communication with Congress, implementing partners, and the public. This transformation is essential to ensure that U.S. foreign aid continues to play a critical role in advancing national interests and addressing global development challenges.

This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.

PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.

Frequently Asked Questions​

How does the proposal align with the Code of Federal Regulations?

​The revisions to the Code of Federal Regulations, specifically the Uniform Guidance (2 CFR 200) provision, represent an exciting opportunity for USAID and its partners. These changes, which took effect on October 1, 2024, align with the Office of Management & Budget’s vision for enhanced oversight, transparency, and management of USAID’s foreign assistance. This update opens the door to several significant improvements in key reform areas: simplified requirements for federal assistance; reduced burdens on staff and implementing partners; and the introduction of new tools to support USAID’s localization efforts. The updated regulations will reduce the need for exception requests to OMB, speeding up timelines between planning and budget execution. This regulatory update presents a valuable opportunity for USAID to streamline its aid practices, pave the way for the adoption of the Fixed-Price model, and create a performance-driven culture at USAID. For these changes to come into full effect, USAID will need to ensure the necessary flow-down and enforcement of them through accompanying policies, guidance, and training. USAID will also need to ensure that these changes flow down and are incorporated into both prime and sub-awards.

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How might adopting a Fixed-Price model support localization?

Wider adoption of Fixed-Price could expand USAID’s pool of qualified local partners, enhancing engagement with diverse implementers and facilitating more sustainable, locally-driven development outcomes. Fixed-Price grants and contracts disburse payments based on achieving pre-agreed milestones rather than on incurred costs, reducing the administrative burden of compliance. This simplified approach enables local organizations –many of which often lack the capacity to manage complex cost-tracking requirements –to be more competitive for USAID programs and to be better prepared to manage USAID awards. By linking payments to results rather than detailed expense documentation, the Fixed-Price model gives local organizations greater flexibility and autonomy in achieving their objectives, empowering them to leverage their contextual knowledge and innovative approaches more effectively. This results in a partnership where local actors can operate independently and adapt quickly to changing circumstances, without the bureaucratic burdens traditionally associated with USAID funding.

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How might adopting Fixed-Price acquisition and assistance support USAID’s ability to achieve its small and disadvantaged business goals?

In the same way that Fixed-Price could help USAID diversify its partner base and increase localization, it could also help expand the Agency’s pool of qualified small businesses, enhancing engagement with diverse implementers, and facilitating more sustainable development outcomes while achieving its Congressionally mandated small and disadvantaged business utilization goals. The current extensive use of CPFF favors entrenched implementers who have already paid for the expensive administrative compliance systems it requires. Fixed-Price grants and contracts have fewer administrative burdens enabling new small businesses–many of which often lack the administrative infrastructure necessary to manage complex cost-tracking requirements–to be more competitive for USAID programs and to be better prepared to manage USAID awards.

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Do any divisions or bureaus at USAID already predominantly use FAAs?

USAID’s research and development arm, Development Innovation Ventures (DIV), uses fixed-fee awards almost exclusively to fund innovative implementers. Yet proven interventions rarely transition from DIV into mainstream USAID programs. Innovators and impact-first organizations find themselves well suited for USAID’s R&D, but with no path forward due to the use of CPFF at scale.

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Would switching from CPFF to Fixed-Price translate into more or fewer costs for the government?

USAID has historically relied on expensive procedures to ensure implementers are using funding in ways that align with USG policies and procedures. These concerns are reduced, however, when the government pays for outcomes (rather than tracking receipts). For example, the government would no longer need to verify whether the implementer has the proper accounting and reporting systems in place, nor would the government need to spend time negotiating indirect rates nor implementing incurred cost audits. As detailed regulations on the permissibility of specific costs under federal acquisition and assistance don’t apply to Fixed-Price awards and contracts, neither the government nor the implementer needs to spend time examining the allowability of costs. Furthermore, we expect wider use of Fixed-Price models to lead to significantly improved results per dollar spent. This means that, although there would be initial costs associated with strategy implementation, we would expect Fixed-Price to be significantly more cost-effective.

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Are there existing examples of how USAID has implemented change management efforts to improve aid effectiveness?

Yes, USAID has made recent efforts to provide more effective aid by incorporating evidence-based approaches and transitioning to models that emphasize cost-effectiveness and impact. In order to do this, during the last Trump administration, USAID elevated the Office of the Chief Economist (OCE) by enlarging its size and mandate. The OCE issued the activity Promoting Impact and Learning with Cost-Effectiveness Evidence (PILCEE), which aims to enhance USAID’s programmatic effectiveness by promoting the use of cost-effectiveness evidence in strategic planning, policy-making, activity design, and implementation. Our approach of establishing a team within OAA would draw on lessons learned from the OCE approach while reducing any associated costs by not establishing an entirely new operating unit.

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