DHS Launching First Federal Civilian Position Exempt from Longevity Requirements

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The Cyber Talent Management System has been in the works since a 2014 law granted the department authorities to sidestep rigid classification formats such as the General Schedule.

The Department of Homeland Security is officially establishing a recruitment and retention system it says re-envisions the federal government’s current talent management to meet its demand for cybersecurity workers.

“With [the Cyber Talent Management System], DHS is creating a new type of Federal civil service position, called a qualified position, and the cadre of those positions and the individuals appointed to them is called the DHS Cybersecurity Service (DHS-CS),” reads a notice set to publish in the Federal Register Thursday. 

The major thrust of the regulations is to codify that the new DHS system will base hiring and compensation decisions on individuals’ skills, which will be assessed through relevant tests, instead of having to adhere to formats such as the General Schedule. The schedule ties advancement and pay levels to how many years an employee has been with the government. 

“Work and career structures are constructs, analogous to General Schedule classes and grades, that DHS establishes under the CTMS work valuation system and uses instead of classes and grades from the General Schedule or other traditional Federal position classification methods,” according to the notice. “DHS uses work and career structures to support several elements of CTMS, including the compensation system, and DHS determines applicable work and career structures for a DHS-CS employee as part of selection and appointment under the CTMS talent acquisition system.”

DHS-CS employees will enjoy the typical aspects of other federal hiring programs such as health and retirement benefits, and they will also be compensated for extenuating circumstances such as working through long or unusual hours, as is often the case when responding to cyber threats. However, “CTMS does not feature automatic salary increases or payments,” according to the notice. “Moreover, longevity in position or prior federal government service are not factors in CTMS compensation.” 

The exemptions for DHS are similar to those already in use by the National Security Agency and the Defense Department’s Cyber Command. 

The notice also acknowledges the steep demand for cybersecurity workers and the regulations will allow for competitive compensation based on certain location-based market rates. However there will still be certain limits for basic and aggregate annual pay that will be informed by comparable positions within the DOD.  

“Constant, often unpredictable, changes in cybersecurity work require a focus on individuals and their skills instead of a focus on narrowly-defined and mostly static jobs or positions created for predictable, stable work,” the notice says. “Significantly, DHS organizations struggle to effectively describe cybersecurity work using outdated and rigid position classification methods designed to apply generically across government and myriad fields of expertise.”

The CTMS will use a strategic planning process based on the department’s priorities, and reward workers under the program based on their contributions to DHS’ cybersecurity work, according to the notice. Compensation will be affected by mission-impact reviews. 

Other elements of the system include an adaptive compensation system that recognizes exceptional qualifications, a deployment program that requires designated staffing assignments and work scheduling, a performance management program for individual accountability and recognition, and a career development program to enable continual learning and tailored guidance for professional advancement.

The system will be led by the secretary, or their designee, who will also select DHS officials executing cybersecurity missions to serve on a Cyber Talent Management Board to assist in its administration.

After reforms to the Homeland Security Act of 2002 granting the relevant authorities at the end of 2014, DHS received about $49 million between 2016 and 2020 to design and run the program and to compensate those who apply and are accepted into it.

“For FY 2022, DHS requested that funding be increased to approximately $16 million both to launch and administer CTMS and to support the management of an expanding population of DHS-CS employees,” according to the notice. 

The rule to implement the CTMS will take effect Nov. 15 and the department is accepting public comments through Dec. 31.

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