Compensation for Services Prior to Appointment

Donna D. Beecher, Director of Personnel Systems and Payroll Division, Department of Housing and Urban Development (HUD), requested a decision as to whether three employees may be compensated for days worked prior to their official appointments to positions within HUD. The employees were sworn in and began working for HUD in good faith and with the full knowledge of HUD officials prior to the effective date of their appointments. In such circumstances, the employees may be considered de facto employees and HUD may properly compensate them for the reasonable value of the services performed while in de facto status.