Federal agencies are working toward an ambitious set of hiring goals: stronger position descriptions and assessments, greater efficiency throughout the hiring process and an average time-to-hire of 80 days. Artificial intelligence (AI) is an important tool to help agencies reach these targets. Recent guidance from the U.S. Office of Personnel Management (OPM) gives Human Capital leaders a practical framework for applying AI across the hiring lifecycle while aligning with the Office of Management and Budget’s (OMB) Memorandum M-25-21.
Five insights from this framework stand out for Chief Human Capital Officers (CHCOs), Chief AI Officers (CAIOs) and the teams that support them.
AI Directly Supports Federal Hiring Modernization Goals
Executive Order (EO) 14170 and the Merit Hiring Plan call on agencies to improve position descriptions and assessments, increase hiring efficiency and reduce time-to-hire. OPM positions AI as a key enabler of these objectives and advises agencies to adopt AI across the full hiring lifecycle, from drafting job announcements to evaluating program outcomes. The guidance also encourages agencies to pursue additional beneficial uses beyond the common examples it outlines.
The “Principal Basis” Test Clarifies How AI Is Assessed
Under M-25-21, an AI use is considered high-impact when its output serves as a principal basis for a decision with a legal, material, binding or significant effect on an individual, including access to employment. The assessment is functional rather than formal; agencies identify what the documented workflow actually uses to justify a decision.
When an appropriate agency official independently reviews the supporting data, evaluates the decisional logic and adopts the AI-assisted work product, the output generally does not serve as a principal basis for the resulting decision. Traceability is central to this approach. AI outputs that point back to the specific documentation they rely on allows officials to confirm the result from the source records themselves.
The Four Most Common Hiring Uses Are Generally Not High-Impact
OPM identified several AI applications that, with the right workflow in place, generally fall outside the high-impact category:
- Content development for job opportunity announcements: Position descriptions, evaluation statements, qualification requirements, crediting plans and interview questions are reviewed and adopted by the responsible official before use
- Decision support for applicant evaluations: Resume screening, minimum qualifications review and candidate summaries that reference the underlying application materials
- Pre-offer quality control: Staffing case file review to identify missing documentation or procedural inconsistencies for human follow-up
- Aggregate hiring program evaluation: Analysis of applicant flow, time-to-hire and assessment performance across completed hiring actions
Agencies still assess their specific workflows and deployment contexts, and an appropriate agency official documents each non-high-impact determination to the CAIO.
A High-Impact Designation Is a Pathway, Not a Prohibition
OPM is clear that a high-impact designation does not prevent adoption. For use cases that remain high-impact, such as AI-scored assessments where agencies cannot trace the score derivation back to the adopted crediting plan, agencies can implement the minimum risk management practices outlined in M-25-21 or submit a waiver request to their CAIO. Waiver requests describe compensating controls like human review and certification, sampling, audit logs and performance monitoring. OPM also provides model determination language to help agencies document these decisions efficiently.
Established Safeguards and Cross-Functional Collaboration Remain Essential
Every AI-enabled hiring step continues to align with existing personnel requirements. Before deployment and periodically afterward, agencies verify that:
- AI-assisted rating, ranking and referral correctly apply veterans’ preference
- AI-enabled steps meet Rehabilitation Act accessibility and reasonable accommodation requirements
- Applicant data is processed only in agency-authorized tools with applicable privacy protections
- Each hiring action remains documented and auditable
- A reconsideration avenue remains available for adverse eligibility determinations
OPM encourages CHCOs to partner with CAIOs, Chief Privacy Officers, Chief Information Officers and Chief Data Officers to put these practices into action while streamlining processes wherever possible.
Looking Ahead
OPM plans to introduce new AI features across its USA Suite of tools, including USA Staffing, USAJOBS, USA Hire, USA Class and USA Performance. Agencies are encouraged to begin adopting AI now rather than waiting for those releases, and OPM offers support through its AI Governance and Adoption Program (AI GAP).
With a clear assessment framework, defined documentation steps and a strong foundation of existing safeguards, Federal agencies are well positioned to use AI to hire faster, improve assessment quality and strengthen the Federal workforce. As The Trusted Government IT Solutions Provider™, Carahsoft supports agencies with Human Capital and AI solutions available through trusted technology partners and established contract vehicles that simplify procurement.
Learn more about Carahsoft’s Human Capital solutions portfolio to discover workforce and talent technologies available to Government agencies.
Explore Carahsoft’s Artificial Intelligence portfolio to see how agencies can adopt AI across the hiring lifecycle efficiently and responsibly.
Reach the Carahsoft Human Capital team at HRIT@Carahsoft.com or (703) 673-3570 to discuss AI-enabled hiring solutions for your agency.
