March 11, 2021
Ms. Shannon Estenoz
Principle Deputy Assistant Secretary
Department of Interior, Fish and Wildlife and Parks
US DOI, Office of the Secretary
Washington, DC 20240
Dear Deputy Assistant Secretary Estenoz:
I am writing to you on behalf of the Coalition to Protect America’s National Parks, a non-profit organization comprised of more than 1,900 retired, former, and current employees of the National Park Service. Our membership includes a full array of retired park leaders and professionals with over 40,000 years of experience managing and protecting our national parks.
During the transition, the Coalition submitted recommendations to the Department of the Interior in our This Land is Our Land document. In this report, we identified several areas of concern; two items were specifically about a demoralized workforce and lack of a diversified workforce in the National Park Service’s recruitment and hiring processes for both temporary/seasonal and permanent employees.
It has come to our attention that the previous administration’s Executive Order 13932, “Modernizing and Reforming the Assessment and Hiring of Federal Job Candidates” is being implemented within DOI as of December 24, 2020. While our organization strongly supports the modernization of the federal hiring system, we have concerns about E.O. 13932 specifically as it applies to the DOI Supplemental Guidance to Executive Order 13932 and personnel Bulletin 20-21, Assessment Practices Guide, December 2020.
Many of our members are, or have been, hiring officials within the agency and understand the importance of using valid assessment tools in the rating and ranking of job applications. Every hiring official wants to receive a certificate of highly qualified vetted individuals from which to choose the best person for the job. We also understand that the reliability of self-report assessment tools alone are not sufficient in getting to the best qualified applicants due to inflated scoring. Subject Matter Expert (SME) assessments are the best way to validate these self-assessment scores based on the applicants’ knowledge, skills and abilities. However, SMEs are expensive and time-consuming for high volume application processes like seasonal hiring.
According to recent DOI Guidance, the assessment tool must be fair and practical, successful in identifying highly qualified, diverse pool of candidates, developed without discrimination on non-merit factors, offer an opportunity for an applicant to appeal, match basic duties of the job, and be relevant to the position.
The Coalition believes that the USA Hire secondary assessment tool does not meet the DOI guidance. Based on the sample general questions we have seen from USA Hire and reports from applicants and hiring officials, this assessment is a generic cognitive test rather than a measure of specific relevant skills/competencies of the job. There is also concern that some of the questions are “personality” based which, if used inappropriately, can lead to charges of discrimination. Some of the multiple-choice questions have either “extreme” selections or no “right or wrong” answer.
It is our understanding that applicants do not receive notice of their USA Hire score that represents at least 50% of their overall application score. The score received is their rating for up to a year without an opportunity to retake the test. Even colleges are moving away or lowering the weight given to standardized testing and they do allow for a retesting after a couple of months. It is difficult to appeal the results of the assessment if the applicant does not know their score. This year-long score will impact temporary and seasonal applicants the most as they tend to apply for many more jobs within a year trying to build their skills and resumes.
We are especially concerned that the rigidity of this “one year rule” will undo the major progress made by the Land Management Workforce Flexibility Act (LMWF) which allows temporary/seasonal employees with at least 24 months experience to apply for permanent positions. The National Park Service, and other land management agencies, have benefited from the LMWF program in recruiting diverse and highly qualified employees. We are concerned that this new hurdle will negatively impact this extremely successful hiring authority.
There is also concern about the 48-hour window for taking the test. Applicants in remote locations where accessibility to internet service non-existent or unreliable at best may not be able to apply. While some parts of the test are timed, there have been reports of interrupted internet service causing problems with test completion. Some applicants have reported 3-4 hours for test completion. While this is certainly a way to decrease the applicant pool, it is not based on fairness and practicality. Discouraging applicants from applying should not be the goal of an assessment.
The Coalition respectfully requests that DOI/NPS review the USA Hire assessment tool for the relevancy in the NPS hiring process and the impacts that it is having on potential and current applicants. Again, we support a secondary assessment, but want to make sure that whatever tool is used reflects an applicant’s competencies and provides hiring officials the highly qualified certificates they need to fill the agency’s positions. We all want a robust, skilled, and dedicated workforce in place to support the mission of the National Park Service and protect our parks.
Chair, Coalition to Protect America’s National Parks
Cc: Shawn Benge, Acting Director, National Park Service