VAL-GAP-RWC-FED-2026-08-29 · HR / EEO / counsel
Validation gap-assessment.
What Federal Fit is, what evidence exists, and what is still missing before anyone could treat scores as a selection procedure. This file is how a CHCO, EEO office, or agency counsel can risk-accept a $14,500 / 290-seat exploration buy without pretending the instrument is USA Hire.
1. Intended-use lock (this is the control)
| Use | Sold? | Validation bar |
|---|---|---|
| Career exploration / counseling | Permitted | Content-related design + purpose label. Not a UGESP “selection procedure” if no hire/refer/reject flows from the score. |
| Internal mobility / development (human review) | Permitted | Decision support. Human decides. Do not auto-route on composite. |
| Workforce planning / occupational-family language | Permitted | Maps are illustrative, not authorized staffing tables. |
| Screening, ranking, cutoffs, referral, grade, clearance, hire | Prohibited as sold | Would require current job analysis, local criterion or content validation, adverse-impact monitoring, and the agency’s own UGESP file. ALA does not sell that SKU. |
Kickoff labels the sitting: exploration / mobility / development — not a qualification determination. Participants see that on the Federal Fit start screen. OPM: job analysis. EEOC: Uniform Guidelines Q&A.
2. What the product actually measures
- 50 timed work-relevant items. Six domains: executive reasoning, quantitative & spatial, verbal & working memory, visual pattern recognition, workplace social judgment, procedural sequencing.
- Scoring lock: +2.0 accuracy if correct; +0.2 speed if correct and RT ≤ 40 s; 60 s window; max composite 110. Career Fit freeze 2026.08-C. Hiring Fit / Federal Fit remain on their published freeze until rebuilt — methodology.
- Not an IQ classification. Not a medical or psychological exam under the ADA. Not USAJOBS. Not OPM-validated. Not a cutoff.
- Output: six-domain profile + occupational-family map + HTML/CSV the agency keeps. Sample: RWC-RPT-086.
3. Uniform Guidelines (29 CFR 1607) — gap table
| UGESP topic | Status for exploration SKU | Status if used for selection |
|---|---|---|
| §1607.2 Scope — “selection procedure” | Out of scope as sold if the agency does not use scores to hire, promote, refer, or reject | In scope the moment scores rank or cut |
| §1607.3 Adverse impact / 4/5ths | Not computed — no federal selection use, no race/sex/national-origin fields collected | Missing. Agency would have to collect and analyze its own file |
| §1607.5 / .14 Technical standards (criterion, content, construct) | Content-related design (work tasks, O*NET-aligned families). Not a completed content-validity study for a named series | Missing for any series-specific hire tool |
| §1607.6 Alternative procedures | N/A while not a selection procedure | Would be the agency’s analysis |
| §1607.7 / .8 Documentation | This gap file, methodology, freeze, sample export, SOW, DPA | Agency job-analysis + local validation file still required |
| §1607.15 Retention of records | Agency owns the download. ALA retains scores 36 months unless deletion is requested (DPA) | Agency records schedule still governs OPF / hiring files |
4. SIOP Principles (2018) and 5 CFR §300.103
| Requirement | Have | Gap |
|---|---|---|
| Define the work / job analysis | Occupational-family mapping; work-relevant item tasks; public “why this item” lines | No series-specific KSA job analysis for GS-XXXX. That is the agency’s if they ever want selection use |
| Reliability | Fixed freeze, server key, 50 items, documented formula | No published Cronbach’s α / test-retest for Federal Fit as a federal instrument |
| Criterion-related validity | Literature class: Schmidt & Hunter 1998; Sackett et al. 2022 — cognitive/work-sample methods predict performance. Research evidence | r ≈ .51 is not an RWC coefficient. No Federal Fit vs. federal performance study |
| Fairness / DIF | No protected-class data stored. ID-only | No DIF tables. Cannot be produced without the agency collecting that data — which this SKU does not |
| 5 CFR §300.103 rational relationship | Purpose label + human decision-maker for permitted uses | Not a professionally developed selection practice for competitive examining |
5. Evidence we do have (do not over-read it)
| Evidence | What it is | What it is not |
|---|---|---|
| 58 of 60 still employed at 9 months | One private employer. Actual headcount. Observational. Case write-up | Not federal past performance. Not CPARS. Not a randomized trial. Not proof the next cohort hits that number. Not UGESP validity |
| Literature (Schmidt & Hunter; Sackett 2022; Kristof-Brown 2005) | Context for the class of methods | Not “our test is 51% accurate.” Validity is not a percentage |
| Item rationales / freeze / scoring lock | Construction documentation | Not a technical manual sufficient for OPM examining |
| IBM Quantum construction record | Form-assembly entropy. Self-disclosed. Record | Not IBM endorsement. Not a bias-free certificate |
6. What would be required to lift the selection prohibition
- Agency job analysis for the specific series/grade (OPM method).
- Local content or criterion study on this instrument, this job, this population — not a literature citation.
- Adverse-impact analysis if the procedure is used to select, with the agency holding the demographic file (ALA does not collect it).
- Written change of intended use. ALA would have to agree to sell a different SKU. Federal Fit as currently sold will not be that SKU.
Until those exist, any agency that ranks, cuts, or auto-refers on Federal Fit scores is using the product off-label. That is the agency’s legal risk, not a hidden ALA feature.
7. Recommendation for a $14,500 Scale buy
Accept for exploration / mobility / development if the contracting officer and CHCO lock the use case in the SOW, participants are told it is not a qualification determination, humans remain the decision-makers, and scores are not written into a competitive examining certificate.
Do not accept as a selection instrument. Do not replace USA Hire, OPM examining, or a validated assessment battery with this file.
Companion files: SOW · packet Q4 · research evidence · DPA.
Not legal advice. Not an EEOC or OPM determination. Advanced Learning Academy LLC · 29 August 2026.