Comment on FR Doc # 2011-19623

This program, Pathways which is being used to replace the FCIP program does not appear to be much different. Remember FCIP was found to violate Veterans Preference requirements and was also overused and an estimated 100,000 people were hired under this program. The concern is that veterans already have a higher rate of homelessness and unemployment than a non-veteran. Veterans Preference has been law in some form or another since the civil war. It does not guarantee or entitle a veteran to a federal job, but is an aid. According to 2010 data provided by OPM, 74% of the Federal workforce is non-veteran. So veterans preference is not creating a disproportion nor is it excluding certain scientific and specialized fields or highly qualified non-veterans. While the concept of opening the doors to college students and attract talent to the federal workforce is understood, Veterans Preference is still a law. Allowing college students an opportunity to gain experience in the Federal Workforce is fine for a standard internship. However when a permanent position opens, the vacancy should be open to public in which the intern can gladly apply along with the rest of the public. Interns being allowed to simply transition from an internship to a permanent position raises many concerns including concerns that preference is not be properly honored. Also to note not all veterans are eligible for preference.