Instructions to Federal Agencies for MD-715 Section III Reporting Requirements and Line-By-Line Instructions

I. Basic Reporting Information

A. General Reporting Requirements

This section contains an overview of EEOC FORM 715-02, which must be submitted to EEOC on an annual basis, followed by detailed, line-by-line instructions on how to complete it.

EEOC FORM 715-02 prescribes the standard format for federal agencies' use in reporting progress in establishing and maintaining continuous programs of equal employment opportunity. Agencies are reminded that the component parts of EEOC FORM 715-02 are designed to collect federal agency, government-wide information in a consistent format. Agencies must submit EEOC FORM 715-02, as prescribed by the EEOC; however, agencies can attach supplemental tables when submitting the report.

B. MD-715 Reporting Format and Due Date

The requirement to file an EEOC FORM 715-02 applies to all covered federal departments and agencies (see Appendix). The heads of all covered departments and agencies are responsible for preparing and submitting department/agency-wide annual fiscal year status reports. EEOC FORM 715-02 is due by February 28 following the end of the fiscal year that is being reported. If the 28^th falls on a weekend or a federal holiday, the due date will be moved to the next business day. EEOC may, at its discretion, grant extensions necessitated by unforeseen circumstances.

C. What Must Be Filed?

All covered agencies must submit a Federal Agency Annual EEO Program Status Report (EEOC FORM 715-02) for the Commission's review and approval, consistent with 29 C.F.R. §1614.602(c).

Status reports must include the annual certification that each agency has a continuing program of equal employment opportunity that is consistent with the requirements outlined in MD-715 and report on activities undertaken and accomplishments made in implementing its EEO Plans.

The implementation of the new MD-715 PART forms (except PART J) and workforce data tables will occur for the FY 2018 MD-715 report, which is due on February 28, 2019. Please note that new PART J form will be utilized in the FY 2017 MD-715 report, which is due on February 28, 2018, because this information will generate the Affirmative Action Plan, which agencies must post on their external website.

Consistent with the requirements at 29 C.F.R. §1614.601, the reports shall be in the format prescribed by the Commission.

D. How to File?

Annual status reports must be submitted electronically. In FY 2011, EEOC established an online data collection system for agencies to upload their MD-715 data. Agencies must submit their report using the Federal Sector EEO Portal (FedSEP), which is located at http://egov.eeoc.gov/fedsep. As a result, EEOC will no longer accept the MD-715 report through the mail, hand-delivery, facsimile, or email. Instructions on electronic filing are available on the Guidance page in FedSEP.

E. EEOC Point of Contact

Inquiries and correspondence about federal affirmative programs for equal employment opportunity should be directed to the Office of Federal Operations, which oversees federal agency equal employment opportunity programs for compliance and administers MD-715 guidance.

Correspondence may be mailed to:

Equal Employment Opportunity Commission
Office of Federal Operations
P.O. Box 77960
Washington, D.C. 20013

Email: FederalSectorEEO@eeoc.gov

Telephone: (202) 663-4599

Facsimile: (202) 663-7022

F. Overview of the EEOC FORM 715-02 and Related Documentation

The EEOC FORM 715-02 is divided into ten (10) parts, designated PART A through PART J. For FY 2017 reporting period, the MD-715 report will include the current 28 Workforce Data Tables, 14 of which provide data on the participation of persons by race, ethnicity and sex (Workforce Data Tables A1 through A14) and 14 of which provide data on the participation of persons with disabilities (Workforce Data Tables B1 through B14).

Beginning with the FY 2018 reporting period, EEOC will reduce the number of Workforce Data Tables to 18, including nine tables with data on the participation of persons by race, ethnicity and sex (Workforce Data Tables A1 through A9) and nine tables with data on the participation of persons with disabilities (Workforce Data Tables B1 through B9). For Tables A/B 4, 5, and 6, agencies must file two sets of data: one for permanent employees and one for temporary employees.

PARTS A through C

PARTS A through C require agencies to provide information that identifies the reporting agency or sub-component, the total number of employees, and the agency officials responsible for the oversight of the agency's EEO programs.

All covered agencies, regardless of size, are required to submit PARTS A through C.

PART D

PART D.1 requires agencies and sub-components to identify all units (i.e., regions, field installations, etc.) that are included in the subject report. Depending on the size and structure of the reporting agency or sub-component, not all agencies may not have reporting components. Please check the box if there are no reporting components.

PART D.2 requires agencies to verify that the mandatory supporting documents have been included in the MD-715 submission. Agencies may also include any of the optional supporting documents in the MD-715 submission.

All covered agencies, regardless of size, are required to submit PART D.

PART E

PART E, the Executive Summary, requires agencies to provide a succinct narrative of the status of the agency's overall EEO program, discuss any problems discovered during its self-assessment, report on the barriers identified as a result of its barrier analyses, and briefly outline what activities will be undertaken to address any program deficiencies and identified barriers.

All agencies, regardless of size, must complete PART E.1; however, only agencies with 199 or fewer employees in permanent FT/PT appointments are required to complete PART E.2 to E.5. Agencies with 200 or more employees in permanent FT/PT appointments have the option to PART E.2 to E.5.

PART F

PART F requires the agency head and the EEO Director/Official for the reporting agency or sub-component to certify that the agency has completed an annual self-assessment of its EEO Program against the MD-715 essential elements and conducted comprehensive barrier analyses.

All covered agencies, regardless of size, are required to submit PART F.

PART G

PART G is the Self-Assessment Checklist. As noted in Section I, the Self-Assessment Checklist provides agencies with a comprehensive list of programs and policies necessary to operate a model EEO program.

All covered agencies, regardless of size, are required to submit PART G.

PART H

PART H is the EEO Plan for Attaining the Essential Elements of a Model EEO Program. Agencies must report specific plans of action aimed at correcting aspects of their EEO Program that are not fully compliant with the essential elements prescribed in MD-715.

Covered agencies that employ 200 or more employees in permanent FT/PT appointments are required to submit PART H.

PART I

PART I, EEO Plan to Eliminate Identified Barrier, requires agencies to report specific plans of action aimed at identifying and removing barriers from their policies, procedures, or practices that limit or restrict free and open competition for groups involving race, ethnicity, and sex groups. To address barriers involving disability status, agencies must establish plans in PART J. For more information about the barrier analysis process, please review Section II.

Covered agencies that employ 200 or more employees in permanent FT/PT appointments are required to submit PART I.

PART J

PART J, the Special Program Plan for the Recruitment, Hiring, Advancement, and Retention of Persons with Disabilities, requires reporting agencies to examine employment trends and participation rates of persons with disabilities and persons with targeted disabilities in agency programs. Based on the analysis of their workforce, agencies must establish plans with numerical and/or percentage goals to improve the participation rates of employees with reportable and targeted disabilities.

Pursuant to Section 501 of the Rehabilitation Act of 1973 (29 U,S,C, § 791(b)), all covered agencies must submit an Affirmative Action Plan for the recruitment, hiring, advancement, and retention of persons with disabilities (AA Plan) for the Commission's review and approval, consistent with 29 C.F.R. 1614.203(e). PART J must be completed for FedSEP to generate the Affirmative Action Plan.

All covered agencies, regardless of size, are required to submit PART J.

II. Line-by-Line Instructions for EEOC FORM 715-02

A. PART A - Department or Agency Identifying Information

PART A identifies the reporting agency or agency component that is the subject of the report. This part of the EEOC FORM 715-02 requires information about the organizational and geographic location of the reporting agency or sub-component.

• Agency - Enter full name of the department or agency. This line identifies all agencies that must submit an agency-wide report, regardless of their size. Please enter the official name of the agency.

Example:

• Second Level Component - If applicable, enter the name of the 2^nd level reporting component on Line 1.a. For Departments, the 2^nd level components might be separate bureaus. For example, the U.S. Marshals Service, Drug Enforcement Administration, and Federal Bureau of Investigation are 2^nd level components of the Department of Justice.
  
  For independent and Executive Branch agencies, the 2^ndlevel components might be identified as a region. Any agency wishing to inquire as to the proper classification of a component should contact the Office of Federal Operations, Federal Sector Programs.

 

Example:

• Address - Enter the official address for the agency or reporting component, including the street address (or post office box), city, state, and zip code.

Example:

• Agency Code - Enter the agency code which is based on the Enterprise Human Resource Integration (EHRI) code.
  
  EEOC utilizes the Agency code to access personnel statistics from the annual EHRI download provided by the U.S. Office of Personnel Management. The information is based upon federal agency Standard Form (SF)-50 transactions, or what can be termed as "personnel actions." Each covered agency has an Agency Code which appears in block 47 of the SF-50. Agency codes consist of two letters for the agency and those two letters plus at least two numerals for agency subcomponents. For example, the Agency code for the Federal Bureau of Investigation is DJ02.
  
  For assistance in identifying these codes, agencies should review the list of agencies at OPM's website, https://www.opm.gov/about-us/open-government/Data/Apps/Agencies. For information about EHRI in general and federal employment statistics, see OPM's website at https://www.opm.gov/policy-data-oversight/data-analysis-documentation/enterprise-human-resources-integration/.

• FIPS Code - Enter the reporting component Federal Information Processing Standards (FIPS) code, or codes, as appropriate.
  
  The Office of Management and Budget publishes the FIPS code, which identifies the geographic area where most federal employees and applicants reside. If an agency's region covers more than one FIPS code, identification of the specific codes will assist the agency and EEOC in assuring that the agency is using the appropriate data. FIPS codes generally consist of five numerals.
  
  For assistance in identifying these codes, agencies should review the listing of local pay areas on OPM's website at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2016/locality-pay-area-definitions .

B. PART B - Total Employment

PART B requires the agency to include the number of full-time and part-time employees in its permanent and temporary workforce.

Example:

Enter the number of permanent and temporary employees in the agency's workforce, regardless of the agency's source of funding (e.g., appropriated and non-appropriated). The workforce data should be identical to the information reported in Tables A/B 1. FedSEP will calculate the total workforce by adding the permanent and temporary employees. For more information, please review Section IV.

C. PART C - Head of Agency and EEO Program Officials

C.1 - Head of Agency and Head of Agency Designee

PART C.1 identifies the name and title of the head of the agency and the head of the agency designee. For a department-wide report, a designee could be a Deputy Secretary. In an independent agency-wide report, the delegation could be made to the Chief Operating Officer. All agencies are required to provide information about the Head of Agency, but the Agency Head Designee is optional. The definitions for head of agency and head of agency designee are as follows:

• Head of Agency - Enter the name and official title of the head of the department or agency. For example, the head of the EEOC is the "Chair," the head of a department might be a "Secretary" or "Administrator," and the head of an independent agency may have a unique title, such as "The Archivist of the United States."
• Agency Head Designee - Enter the name and official title of the agency official who has been delegated authority by the agency head under 29 C.F.R. § 1614.607 to be the signatory for the MD-715 report.

Example:

C.2 - Agency Official(s) Responsible for Oversight of EEO Program

PART C.2 identifies the agency officials at the reporting agency or sub-component who are responsible for the oversight and administration of the EEO Program. Agencies are only required to provide information for the Principal EEO Director/Official, while all other EEO staff are optional.

• Principal EEO Director/Official - Enter the name, official title, occupational series, pay plan/grade, phone number, and email address of the agency official who has been designated by the agency head under 29 C.F.R. § 1614.102(b)(4) to carry out the EEO functions described in the regulations.
  
  In the PART 1614 regulations, the title for this official is the EEO Director. Agencies have a variety of titles for the Principal EEO Director/Official, ranging from "EEO Director" to "Director of Office of Civil Rights." No matter what title an agency chooses, the official designated the overall responsibility for the day-to-day operation and coordination of Section 717 and Section 501 programs of equal employment opportunity should be listed on Line 1. For a sub-component report, the component EEO Manager or Official should be listed on Line 1.
• Other EEO Staff - Enter the name, official title, occupational series, pay plan/grade, phone number, and email address of any other agency officials delegated responsibility for aspects of an EEO or EEO-related program or function. This could include, but is not limited to, the ADR Program Manager, Special Emphasis Program Manager(s), or the Disability Program Manager.

Example:

D. PART D - Subordinate Components and Mandatory Documents

PART D.1 - List of Subordinate Components Covered in this Report

PART D.1 identifies the subordinate units that are included in the agency or sub-component. Those identified subordinate units may or may not file separate reports to the EEOC under MD-715, as indicated above on the Quick Guide to What Must Be Filed chart.

• Subordinate Component - List the name of each subordinate unit included in the report.
• Address - Provide the city and state for each subordinate unit. Agencies can choose to provide the country.
• Agency Code - Enter the agency code which is based on the Enterprise Human Resource Integration (EHRI) code.
• FIPS Code - Enter the reporting component Federal Information Processing Standards (FIPS) code, or codes, as appropriate.

Example:

PART D.2 - Mandatory and Optional Documents for this Report

PART D.2 identifies all mandatory and optional supporting documents for the MD-715 submission.

• Mandatory Documents - Agencies must identify whether they have submitted the mandatory documents with the MD-715 report. While agencies are required to re-issue the EEO Policy Statement annually, that is not necessary for the other mandatory documents. As such, the agency should submit the most recent version of the document. If an agency has not issued a particular document, such as Personal Assistance Services Procedures, the agency should answer "no" and then provide a brief explanation in the comments column.
• Optional Documents - Agencies must identify whether they have chosen to include any of the optional documents with the MD-715 submission.

Example:

 

E. PART E - Executive Summary

The purpose of the Executive Summary is to alert all managers and supervisors of their responsibilities regarding the status of the agency's EEO program. The Executive Summary also provides the reader with a quick and informative review of the EEO program deficiencies that will be addressed during the upcoming year as well as the barriers that have been identified.

The Executive Summary should be as short and concise as possible. The Executive Summary is intended to be an introductory summary that catches the attention of the agency's top managers and supervisors. This is to ensure their understanding of (1) the agency's overall EEO program direction and (2) the expected contributions necessary for the agency to become a Model Employer.

The Executive Summary can be written only after all the data is compiled and analyzed, and the agency has identified barriers and plans for addressing the barriers. While brevity is desired, agencies should not feel limited in fully describing the results of their self-assessment and plans for achieving a Model EEO Program.

Elements of the Executive Summary include:

• A brief narrative description of the agency's mission and mission-related functions (PART E.1);
• A description of strengths (e.g., leading practices) and weaknesses (e.g., deficiencies) of the agency's EEO Program when evaluated against each of the six essential elements of a model program (PARTs E.2 to E.7);
• A description of activities undertaken in connection with the annual self-assessment and workforce analyses, including the barriers identified for elimination and program deficiencies that require correction and what has been accomplished from those activities (PARTs E.8 and E.9); and
• A description of action items and plans to be implemented by the agency during the upcoming year (PART E.10).

Agencies with 199 or fewer employees in permanent FT/PT appointments must submit each section of PART E in order to provide their EEO action plans to remove program deficiencies and/or barriers. Agencies with 200 or more employees are only required to provide PART E.1, but can choose to provide additional information in PART E.2 to E.5.

F. PART F - Certification of Establishment of Continuing Program of Equal Employment Opportunity

PART F requires agencies to certify that they conducted an annual self-assessment and established plans to correct any program deficiencies. In addition, agencies must confirm that they analyzed workforce profiles, conducted barrier analysis, and established plans to eliminate identified barriers.

The EEO Director and the Agency Head (or Designee) of the agency or sub-component must sign and date PART F prior to submitting the EEOC FORM 715-02.

G. PART G - Agency Self-Assessment Checklist

The Self-Assessment Checklist is designed to provide an efficient and effective means for each federal agency to determine whether its overall EEO program is properly established and compliant with the essential elements (standards) set forth in MD-715.

With the goal of each federal agency achieving model EEO program status, the Self-Assessment Checklist provides a guide for agencies to evaluate their EEO programs with each essential element. As such, the questions within PART G are intended to assist agencies in promoting compliance, quality, and timeliness in all facets of the EEO program.

Using this checklist will assist agencies in identifying trends and/or issues in areas where they need to provide more attention. It is important to note that PART G sets forth the minimum requirements for a model EEO program; however, agencies may establish more stringent or comprehensive standards. Use of the checklist also permits certification that the agencies have conducted the required annual self-assessment in PART F. If an agency highlights leading practices in its plans, EEOC may share those practices with the EEO community as a whole. The columns in PART G are as follows:

• Description of Essential Elements - the checklist provides "indicator" statements, which are followed by a series of questions (measures) that will assist the agency in determining whether its EEO program(s) are properly established.
• Answer Column - The answer column allows agencies to choose from three answers: "Yes", "No", or "N/A". If a question is not applicable to a particular agency, please check "N/A" and provide a succinct explanation in the comments column.
• Comments Column - The agencies can discuss particular measures for each essential element in the comments column.

For every "No" response in PART G, agencies must develop a plan to correct the program deficiency. Depending on the size of the agency, the plans should be in either PART E or PART H. Please note that program deficiencies concerning the disability program will be automatically incorporated into the Affirmative Action Plan.

Example: If the EEO Director does not report directly to the agency head, then a "No" response would require the agency to establish a plan to correct this program deficiency.

All agencies, regardless of size, are required to submit PART G to EEOC.

H. Part H - EEO Plan for Attaining the Essential Elements of a Model EEO Program

After completing the Self-Assessment Checklist, agencies will have a clearer picture of what actions they need to take to meet the minimum requirements of a model EEO program.

For each deficiency that is identified, a plan in PART H must be prepared by agencies and sub-components with 200 or more employees in permanent FT/PT appointments. EEOC recognizes that agencies may not be able to address all deficiencies in a one-year period; however, EEOC expects agencies to demonstrate meaningful progress toward the removal of the deficiencies. If certain program deficiencies are sufficiently related, they may be addressed in one PART H, but agencies should ensure that the plan is clear and understandable. The elements of the PART H are described below.

• Check the Box - If an agency has not identified any program deficiencies during the reporting period, the agency should click the box to indicate that the agency has not established any plans in PART H.
  Example: ☐ If the agency did not address any deficiencies during the reporting period, please check the box.
• Statement of Model Essential Element Deficiency - For each model program element deficiency, identify the type of program deficiency by providing the related question number in PART G or selecting "Other". Then, the agency should briefly describe the program deficiency.
  
      Example: 75% of the agency's 3,000 managers and supervisors have received training on the reasonable accommodation procedures.

Statement of Model Program Essential Element Deficiency

• Objective(s) and Dates for EEO Plans - For each model program element deficiency described, the agency should provide a clear statement of the measurable objective that will correct the problem. It is critically important for the agency to identify the reason(s) for the program deficiency before establishing an objective to correct the problem.
  
  The agency should also include the date the objective was initiated as well as the target date when the agency plans to complete the objective. Objectives can be short-term or long-term depending on the simplicity or complexity of the plan. In addition, the agency must identify whether each objective has sufficient funding and staffing to be implemented by the target date. When applicable, the agency should also enter the modified target date and the completion date.
  
  For example, the measurable objective might be to ensure 25% of the untrained managers and supervisors participate in a comprehensive EEO course that covers the reasonable accommodation program. Since 750 existing managers/supervisors need training and an estimated 50 new managers/supervisors will also need training each year, the agency will need to train 900 managers/supervisors. Taking current training resources into consideration, the agency can reasonably conduct nine comprehensive EEO courses per year (i.e., 34 participants per course equals 306 trained per year). Thus, the agency could establish a plan with a three-year time frame to complete the objective.

Example: Objective(s) and Dates for EEO Plan

• Responsible Official(s)- Enter the official title and name of the agency official(s) who will be responsible for implementing/overseeing the agency's completion of the objective. The responsible official must have the authority to implement the planned activities for the program where the deficiency exists. Based on the previous example, the agency assigned the objective to the Training Officer, John Smith, who is in the Office of Human Resources. Next, the agency should identify whether the performance standards of that official include implementing the plan.

Example: Responsible Official(s)

• Planned Activities toward Completion of Objective - Enter the specific activities that will be undertaken to complete the objective. The target dates for the activities should lead to the completion date for the objective (i.e., if the target date for the Objective is the last quarter of FY 2012, the target date for one of the planned activities should not be in FY 2013).
  
  If necessary, the agency should enter the modified target date, and explain the reason(s) for the new date in the Report of Accomplishments section. When the agency has completed the activity, provide the completion date.

Example: Planned Activities Toward Completion of Objective

• Report of Accomplishments and Modifications to Objective - This section is used to describe the status of activities undertaken by fiscal year. As such, the same plan can be updated from year to year. EEOC expects agencies to demonstrate meaningful progress toward the removal of all program deficiencies.

Example: Report of Accomplishments

I. PART I - EEO Plan to Eliminate Identified Barrier for Race, Sex, and National Origin

During the barrier analysis process, agencies will seek to identify policies, procedures, or practices that are impeding the full realization of equal employment opportunity for all employees and applicants. At the end of the reporting cycle, agencies may be at various stages of the barrier analysis process. Agencies with 200 or more employees in permanent FT/PT appointments must prepare a PART I for identified barriers as well as the triggers that were investigated during the reporting period. EEOC recognizes that agencies may not be able to address all triggers in a one-year period and that agencies may need to prioritize the investigation of the most significant triggers. For more information about the barrier analysis process, please review Section II.

PART I only addresses plans for triggers and barriers based on race, sex, and national origin. Plans for triggers and barriers involving people with disabilities and people with targeted disabilities must be entered in PART J.

For example, if, after reviewing workforce data and exit interview results, the agency has yet to find a barrier, the agency should fill out a PART I with the status of its investigative process.

• Check the Box - If an agency has not conducted barrier analysis during the reporting period, the agency should click the box to indicate that the agency has not established any plans in PART I.
  Example: ☐ If the agency did not conduct barrier analysis during the reporting period, please check the box.
• Statement of Condition that Was a Trigger for a Potential Barrier - Enter a narrative statement that succinctly describes the condition that raised a warning flag ("trigger"). For example, a trigger might be a lower than expected participation rate (0.23%) of American Indian or Alaska Native females in the Senior Executive Service. The agency must also provide the source of the trigger and, if applicable, the specific workforce data table.

Example: Statement of Condition that Was a Trigger for a Potential Barrier

• EEO Group(s) Affected by Trigger - Identify the EEO groups that have this trigger. The EEO groups are limited to race, ethnicity, and sex, because disability status is addressed in PART J. Agencies can decide whether to include multiple EEO groups in the same PART I. In making this decision, agencies should consider whether the barriers are similar for all EEO groups.

Example: EEO Group(s) Affected by Trigger

• Barrier Analysis Process - Agencies should briefly describe the steps taken and the data sources analyzed to determine the underlying cause(s) of the trigger. Agencies should also identify whether they reviewed the listed sources of data.

Example: Barrier Analysis Process

• Status of Barrier Analysis Process - If the agency has completed the barrier analysis process, then select "Yes". Similarly, the agency should report whether it has identified a barrier.

Example: Status of Barrier Analysis Process

• Statement of Identified Barrier(s) - For each barrier, agencies should describe the specific agency policy, procedure or practice that is causing the barrier. These barrier statements should logically flow from the results of the barrier analysis.

Example: Statement of Identified Barrier(s)

• Objective(s) and Dates for EEO Plan - For each barrier, provide a clear statement of one or more measurable objectives (such as the implementation of an alternative or revised agency policy, procedure or practice) which will be implemented to correct the undesired condition. Also include the date that the agency initiated the objective and the target date for achieving the objective. In addition, the agency must identify whether each objective has sufficient funding and staffing to be implemented by the target date. When applicable, the agency should also enter the modified target date and the completion date.

Example: Objective(s) and Dates for EEO Plan

• Responsible Official(s)- Agencies should enter the official title and name of each agency official who is responsible for implementing/overseeing the agency's completion of the objective. The responsible official must have the authority to implement the planned activities for the program that has the potential barrier. Next, the agency should identify whether the performance standards of that official include implementing the plan.

Example: Responsible Official(s)

• Planned Activities toward Completion of Objective - In this section, enter the specific activities/actions that will be implemented to complete the objective. Activities/actions should be designed to directly contribute toward completion of the objective. The target dates for the activities should lead to the completion date for the objective (i.e., if the target date for the Objective is the last quarter of FY 2012, the target date for one of the planned activities should not be in FY 2013). When applicable, the agency should provide the modified date and the completion date for each planned activity.

Example: Planned Activities Toward Completion of Objective

• Report of Accomplishments - This section is used to report the status of activities undertaken for each fiscal year. As such, the same plan can be updated from year to year. EEOC expects agencies to demonstrate meaningful progress toward the removal of all barriers to equal opportunity.

Example: Report of Accomplishments

J. PART J - Special Program Plan for the Recruitment, Hiring, Advancement, and Retention of Persons with Disabilities

In accordance with Section 501 of the Rehabilitation Act of 1973 and EEOC regulation, 29 C.F.R. § 1614.203(d), federal agencies are required to maintain an affirmative action plan for the recruitment, hiring, advancement and retention of persons with disabilities. PART J is designed for agencies to report the changes in the permanent workforce to determine if progress is being made in the participation rate of persons with disabilities (PWD), including specifically persons with targeted disabilities (PWTD). EEOC defines individuals with disabilities and targeted disabilities based on the Office of Personnel Management's SF-256 form.

FedSEP will automatically generate the Affirmative Action Plan, using the information from PART J. Agencies are required to post the Affirmative Action Plan on their public website.

All agencies, regardless of size, must complete PART J.

Section I: Efforts to Reach Regulatory Goals

EEOC regulations (29 C.F.R. § 1614.203(d)(7)) require agencies to establish specific numerical goals for increasing the participation of persons with disabilities and persons with targeted disabilities in the federal government.

1. Using the goal of 12% as the benchmark, does your agency have a trigger involving PWD by grade level cluster in the permanent workforce? If "yes", describe the trigger(s) in the text box.

 

In Section I.1, agencies should examine whether triggers exist for PWD in two grade level clusters: GS-1 to GS-10 and GS-11 to SES. Agencies should use the goal of 12% as the benchmark. For agencies with other pay plans, please use the approximate grade clusters that are above or below GS -11 Step 1 in the Washington, DC metropolitan region.

• Choose "Yes," if the percentage of PWD in either grade level cluster falls below the goal. Then, describe the trigger in the text box.
• Choose "No," if the percentage of PWD in either grade level cluster exceeds the goal.

Example:

2. Using the goal of 2% as the benchmark, does your agency have a trigger involving PWTD by grade level cluster in the permanent workforce? If "yes", describe the trigger(s) in the text box.

 

In Section I.2, agencies should examine whether triggers exist for PWTD in two grade level clusters: GS-1 to GS-10 and GS-11 to SES. Agencies should use the goal of 2% as the benchmark. For agencies with other pay plans, please use the approximate grade clusters that are above or below GS -11 Step 1 in the Washington, DC metropolitan region.

• Choose "Yes," if the percentage of PWTD in either grade level cluster falls below the goal. Then, describe the trigger in the text box.
• Choose "No," if the percentage of PWTD in either grade level cluster exceeds the goal.

Example:

3. Describe how the agency has communicated the numerical goals to the hiring managers and/or recruiters.

InSection I.3, describe the steps taken by the agency to notify hiring managers and other personnel involved in the hiring process about the agency's commitment to achieving the numerical goals for PWD and PWTD. The response to this question may include the following:

• Memoranda from the agency head to hiring managers about the goals; and
• A letter from the Chief Human Capitol Officer to staff about strategies to achieve the goals.

Example:

Section II: Model Disability Program

Pursuant to 29 C.F.R. § 1614.203, agencies must ensure sufficient staff, training and resources to recruit and hire persons with disabilities and persons with targeted disabilities, administer the reasonable accommodation program and special emphasis program, and oversee any other disability hiring and advancement program the agency has in place.

Section II.A: Plan to Provide Sufficient & Competent Staffing for the Disability Program

This section is designed to capture data to determine whether the agency has sufficient and competent staffing for the disability program.

1. Has the agency designated sufficient qualified personnel to implement its disability program during the reporting period? If "no", describe the agency's plan to improve the staffing for the upcoming year?

 

In Section II.A.1, assess whether the disability program has the necessary personnel resources to implement the requirements set forth in 29 C.F.R. § 1614.203. Please note that the response should not be limited to EEO staff or disability program staff because various offices, including Human Resources, Diversity and Inclusion, and Information and Technology, may be involved in implementing the plan.

• Choose "Yes," if the agency has designated sufficient qualified personnel.
• Choose "No," if the agency has not designated sufficient qualified personnel. Then, describe the agency's plan to improve the staffing.

Example:

2. Identify all staff responsible for implementing the agency's disability employment program by the office, staff employment status, and responsible official.

In Section II.A.2, complete the table by identifying all staff responsible for implementing the agency's disability employment program. Agencies should complete Section A as follows:

• In column 2, provide the number of staff assigned to each task based on their employment status in the disability program: full-time; part-time; or collateral duty.
• In column 3, list the name title, office, and email address for the staff person who is responsible for overseeing the task.

Example:

3. Has the agency provided disability program staff with sufficient training to carry out their responsibilities during the reporting period? If "yes", describe the training that disability program staff have received. If "no", describe the training planned for the upcoming year.

 

In Section II.A.3, EEOC regulations and MD-715 require agencies to provide sufficient training to its disability program staff so they can successfully implement the agency's Affirmative Action Plan. For example, the Disability Program Manager (DPM) should be participating in the barrier analysis process; however, the lack of barrier analysis training could impede the DPM from performing that task.

• Choose "Yes," if the agency has provided sufficient training to disability program staff. Then, describe the training provided to disability program staff.
• Choose "No," if the agency has not provided sufficient training to disability program staff. Then, describe the agency's plan to provide sufficient training.

Example for "Yes" Response:

Example for "No" Response:

Section II.B: Plan to Ensure Sufficient Funding for the Disability Program

Pursuant to 29 C.F.R. § 1614.203(d)(1) agencies are required to ensure all disability program staff have sufficient training, resources and support to implement the agency's Affirmative Action Plan.

Has the agency provided sufficient funding and other resources to successfully implement the disability program during the reporting period? If "no" describe the agency's plan to ensure all aspects of the disability program have sufficient funding and other resources.

In Section II.B, agencies must answer whether the disability program has sufficient funding and resources to implement the agency's Affirmative Action Plan. The agency's responseshould not be limited to EEO staff or disability program staff, because various offices, including Human Resources, Diversity and Inclusion, and Information and Technology, may be involved in implementing the plan. As such, the response should discuss the steps taken to provide training and resources for all employees who are responsible for the tasks identified in Section II.A.2.

• Choose "Yes," if the agency has provided sufficient funding to the disability program.
• Choose "No," if the agency has not provided sufficient funding to disability program staff. Then, describe the agency's plan to ensure sufficient funding and resources over the next fiscal year.

Example:

Section III: Plan to Recruit and Hire Individuals with Disabilities

Pursuant to 29 C.F.R. § 1614.203(d)(1)(i) and (ii), agencies must establish a plan to increase the recruitment and hiring of individuals with disabilities. The questions below are designed to identify outcomes of the agency's recruitment program plan for PWD and PWTD.

Section III.A - Plan to Identify Job Applicants with Disabilities

1. Describe the programs and resources the agency uses to identify job applicants with disabilities, including individuals with targeted disabilities.

In Section III.A.1, describe the methods used to recruit PWD and PWTD as well as the outcomes of these efforts. In particular, the narrative should address the following topics:

• Action items designed to ensure that qualified PWD and PWTD are aware of existing vacancies and encouraged to apply for them;
• Targeted recruitment initiatives to increase the number of qualified applicants with disabilities, particularly for the mission-critical occupations;
• The use of hiring authorities that take disability into account; and
• The use of internship programs, such as the Workforce Recruitment Program, the Wounded Warrior Program, the Non-Paid Work Experience Program, and the Pathways Program.

Example:

2. Pursuant to 29 C.F.R. § 1614.203(a)(3), describe the agency's use of hiring authorities that take disability into account (e.g., Schedule A) to recruit PWD and PWTD for positions in the permanent workforce.

In Section III.A.2, agencies are asked whether they utilize hiring authorities that take disability into account to recruit and select PWD and PWTD for positions in the permanent workforce. The term, hiring authorities that take disability into account, means a hiring authority that permits an agency to consider disability status during the hiring process (e.g., Schedule A hiring authority for persons with certain disabilities, Veterans' Recruitment Appointment authority, 30% or More Disabled Veteran authority).

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3. When individuals apply for a position under a hiring authority that takes disability into account (e.g., Schedule A), explain how the agency (1) determines if the individual is eligible for appointment under such authority and (2) forwards the individual's application to the relevant hiring officials with an explanation of how and when the individual may be appointed.

In Section III.A.3, discuss the agency's hiring process as it relates to applicants who are eligible for appointment under a hiring authority that takes disability into account such as:

• The process used to accept and review applications from PWD and PWTD (e.g., DPM is the point of contact for applicants, not the staffing specialist listed on the vacancy announcement);
• The criteria used to determine whether an applicant is eligible for appointment under a hiring authority that takes disability into account (e.g., Schedule A);
• The criteria used to create a certificate of eligibles. Depending on the hiring authority, agencies can utilize different procedures to rate and rank applicants eligible for appointment under such authority than those used in the competitive process; and
• The information provided to hiring officials regarding how and when the individual may be appointed.

4. Has the agency provided training to all hiring managers on the use of hiring authorities that take disability into account (e.g., Schedule A)? If "yes", describe the type(s) of training and frequency. If "no", describe the agency's plan to provide this training.

In Section II.A.4, agencies must answer whether they have provided training to all hiring managers on the use of hiring authorities that take disability into account. See 29 C.F.R. §§ 1614.203(d)(1)(i)(A); 1614.203(d)(7)(ii)(C). Examples of training for hiring managers on hiring authorities that take disability into account include: OPM's Roadmap to Success: Hiring, Retaining and Including People with Disabilities; Veteran Employment Training; and other agency specific training on hiring authorities,

• Choose "Yes," if the agency has trained all of its hiring managers on the hiring authorities that take disability into account. Then, describe the type of training and frequency in the text box.
• Choose "No," if the agency has not trained all of its hiring managers on the hiring authorities that take disability into account. Then, describe the agency's plan to provide the training.
• Choose "N/A," if the agency cannot utilize hiring authorities that take disability into account.

Example:

Section III.B - Plan to Establish Contacts with Disability Employment Organizations

Describe the agency's efforts to establish and maintain contacts with organizations that assist PWD, including PWTD, in securing and maintaining employment.

In Section III.B, describe the agency's efforts to establish and maintain contacts with disability employment organizations and the outcomes of these efforts See 29 C.F.R. § 1614.203(d)(1)(i)(B). Agencies that have not established contacts with disability organizations should explain why it has not done so. Examples of disability employment organizations include: American Job Centers; State Vocational Rehabilitation Agencies; Veteran's Vocational Rehabilitation and Employment Program; Centers for Independent Living; and Employment Networks.

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Section III.C: Progress Towards Goals (Recruitment and Hiring)

EEOC regulations (29 C.F.R. § 1614.203(d)(7)) require agencies to establish specific numerical goals to increase the participation of persons with reportable and targeted disabilities in the federal government. The questions in Section II.C are designed to identify triggers involving the agency's recruitment program for PWD and PWTD. If the agency answers "Yes" to any of the questions in Section II.C that involve triggers for PWD or PWTD, the agency should consider establishing a plan to identify and remove a potential barrier in Section VI.

1. Using the goals of 12% for PWD and 2% for PWTD as the benchmarks, do triggers exist for PWD and/or PWTD among the new hires in the permanent workforce? If "yes", please describe the triggers below.

In Section III.C.1, examine the applicant flow data for new hires in the permanent workforce to determine whether triggers exist for the qualified applicants and/or new hires. The benchmark is the goals of 12% for PWD and 2% for PWTD.

• Choose "Yes," if the percentage of qualified applicants and/or new hires in the permanent workforce falls below the goal. Then, describe the trigger in the text box.
• Choose "No," if the percentage of qualified applicants and/or new hires in the permanent workforce exceeds the goal.

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2. Using the qualified applicant pool as the benchmark, do triggers exist for PWD and/or PWTD among the new hires for any of the mission-critical occupations (MCO)? If yes, please describe the triggers below.

In Section III.C.2, use the qualified applicant pool as the benchmark to examine the external applicant flow data for new hires to mission-critical occupations in Table B6. A glass wall barrier may exist for PWD and/or PWTD if they are unable to obtain employment in any of the agency's mission-critical occupations.

• Choose "Yes," if the percentage of qualified external applicants and/or new hires falls below the benchmark. Then, describe the trigger in the text box.
• Choose "No," if the percentage of qualified external applicants and/or new hires exceeds the benchmark.

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3. Using the relevant applicant pool as the benchmark, do triggers exist for PWD and/or PWTD among the qualified internal applicants for any of the mission-critical occupations (MCO)? If "yes", please describe the triggers below.

 

In Section III.C.3, use the relevant applicant pool as the benchmark to examine the qualified internal applicants for promotions to mission-critical occupations in Table B6. A glass wall barrier may exist for PWD and/or PWTD if they are unable to obtain employment in any of the agency's mission-critical occupations.

• Choose "Yes," if the percentage of qualified internal applicants falls below the benchmark. Then, describe the trigger in the text box.
• Choose "No," if the percentage of qualified internal applicants exceeds the benchmark.

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4. Using the qualified applicant pool as the benchmark, do triggers exist for PWD and/or PWTD among employees promoted to any of the mission-critical occupations (MCO)? If yes, please describe the triggers below.

 

In Section III.C.4, use the qualified applicant pool as the benchmark to examine promotions to mission-critical occupations in Table B6. A glass wall barrier may exist for PWD and/or PWTD if they are unable to obtain employment in any of the agency's mission-critical occupations.

• Choose "Yes," if the percentage of selections for promotion falls below the benchmark. Then, describe the trigger in the text box.
• Choose "No," if the percentage of selections for promotion exceeds the benchmark.

Example:

 

Section IV: Plan to Ensure Advancement Opportunities for Employees with Disabilities

Pursuant to 29 C.F.R. § 1614.203(d)(1)(iii), agencies are required to provide sufficient advancement opportunities for employees with disabilities. Such activities might include specialized training and mentoring programs, career development opportunities, awards programs, promotions, and similar programs that address advancement. In the sections below, agencies should identify, and provide data on programs designed to ensure advancement opportunities for employees with disabilities.

Section IV.A: Advancement Program Plan

Describe the agency's plan to ensure PWD, including PWTD, have sufficient opportunities for advancement.

In Section IV.A, describe the agency's efforts to establish an Advancement Program Plan and provide the outcomes of these efforts. The response should provide the participation rates of PWD and PWTD in the existing advancement programs. Examples of advancement programs include:

• Leadership development programs (e.g., pre-supervisory training);
• Formal mentoring programs for employees with disabilities;
• Training opportunities;
• Apprenticeship programs;
• On-the-Job training opportunities;
• SES candidate development programs; and
• Schedule A usage for internal promotions.

Example:

Section IV.B: Career Development Opportunities

The purpose of this section is to identify whether triggers exist for PWD and PWTD that prevent them from obtaining career development opportunities.

1. Please describe the career development opportunities that the agency provides to its employees.

In Section IV.B.1, describe the career development opportunities that require competition and/or supervisory recommendation/approval to participate. However, please note that participants would still need to compete for a promotion after they complete the training. Tables B6, B7, and B8 contain data concerning career development opportunities for the mission-critical occupations, senior grade levels, and management positions. Examples of career development opportunities include:

• President's Management Council Interagency Rotation Program;
• SES Candidate Development Programs;
• Details or rotational assignments;
• Coaching or mentoring programs; and
• Internship or fellowship programs.

Example:

2. In the table below, please provide the data for career development opportunities that require competition and/or supervisory recommendation/approval to participate.

In Section IV.B.2, agencies must complete the table beginning with the FY 2018 MD-715 report, which is due on February 28, 2019. The table includes data concerning the career development opportunities that require competition and/or supervisory recommendation/approval to participate. Please use the following definitions for each type of career development program:

• Internship Programs - provides students in high schools, colleges, trade schools, and other qualifying educational institutions with paid and unpaid opportunities to work in agencies and explore federal careers while completing their education. For more information, see OPM's website at https://www.opm.gov/policy-data-oversight/hiring-information/students-recent-graduates/#url=intern.
• Fellowship Programs - a sub-specialty training program that allows individuals to study and gain experience into a particular field of study. For example, OPM offers the Presidential Management Fellows Program, which is a leadership development program at the entry-level for advanced degree candidates. For more information, see OPM's website at https://www.opm.gov/policy-data-oversight/hiring-information/students-recent-graduates/#url=intern.
• Mentoring Program - a process that focuses specifically on providing guidance, direction, and career advice, which will enable individuals to achieve their full potential. Agencies can establish formal or informal mentoring programs. For more information, see OPM's website at https://www.opm.gov/policy-data-oversight/training-and-development/career-development/#url=Mentoring.
• Coaching Programs - a process that maximizes people's potential by working on their perceptions, self-confidence, and creative drive. For more information, see OPM's website at https://www.opm.gov/policy-data-oversight/training-and-development/career-development/#url=Coaching.
• Career Development Programs - training for promotion or placement in other positions, including SES candidate development programs. For more information, please review 5 C.F.R. §§ 410.307; 410.312
• Detail Programs - a process that allows employees to receive a temporary reassignment which exposes them to challenges or otherwise expands their capacity to serve.

Agencies with second level reporting components can report career development programs separately depending on where they are housed. For those programs housed at the department level, the parent agency should report those programs. For programs housed in the second level reporting components, each component should separately report their programs.

Example:

3. Do triggers exist for PWD among the applicants and/or selectees for any of the career development programs? (The appropriate benchmarks are the relevant applicant pool for the applicants and the applicant pool for selectees.) If "yes", describe the trigger(s) in the text box.

In Section IV.B.3, the benchmark for examining the career development programs is the relevant applicant pool for applicants and the applicant pool for selectees.

• Choose "Yes," if the percentage of applicants and/or selectees falls below the benchmark. Then, describe the trigger in the text box.
• Choose "No," if the percentage of applicants and/or selectees exceeds the benchmark.

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4. Do triggers exist for PWTD among the applicants and/or selectees for any of the career development programs identified? (The appropriate benchmarks are the relevant applicant pool for applicants and the applicant pool for selectees.) If "yes", describe the trigger(s) in the text box.

In Section IV.B.4, the benchmark for examining the career development programs is the relevant applicant pool for applicants and the applicant pool for selectees.

• Choose "Yes," if the percentage of applicants and/or selectees falls below the benchmark. Then, describe the trigger in the text box.
• Choose "No," if the percentage of applicants and/or selectees exceeds the benchmark.

Example:

Section IV.C: Awards

The purpose of this section is to identify whether triggers exist for PWD and PWTD in the distribution of agency awards.

1. Using the inclusion rate as the benchmark, does your agency have a trigger involving PWD and/or PWTD for any level of the time-off awards, bonuses, or other incentives? If "yes", please describe the trigger(s) in the text box.

 

In Section IV.C.1, using the inclusion rate as the benchmark, agencies should compare the percentage of PWD and/or PWTD who received time-off awards, bonuses, and other incentives to the benchmark.

• Choose "Yes," if the percentage of PWD and/or PWTD who received time-off awards, bonuses, and other incentives falls below the benchmark. Then, describe the trigger in the text box.
• Choose "No," if the percentage of PWD and/or PWTD who received time-off awards, bonuses, and other incentives exceeds the benchmark.

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2. Using the inclusion rate as the benchmark, does your agency have a trigger involving PWD and/or PWTD for quality step increases or performance-based pay increases? If "yes", please describe the trigger(s) in the text box.

In Section IV.C.2, using the inclusion rate as the benchmark, agencies should compare the percentage of PWD and/or PWTD who received pay increases to the benchmark.

• Choose "Yes," if the percentage of PWD and/or PWTD who received pay increases falls below the benchmark. Then, describe the trigger in the text box.
• Choose "No," if the percentage of PWD and/or PWTD who received pay increases exceeds the benchmark.

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3. If the agency has other types of employee recognition programs, are PWD and/or PWTD recognized disproportionately less than employees without disabilities? (The appropriate benchmark is the inclusion rate.) If "yes", describe the employee recognition program and relevant data in the text box.

 

In Section IV.C.3, agencies should use the inclusion rate as the benchmark to examine their employee recognition program. Agencies should compare the percentage of PWD and/or PWTD who received other types of recognition to the benchmark.

• Choose "Yes," if the percentage of PWD and/or PWTD who received other types of recognition falls below the benchmark. Then, describe the trigger in the text box.
• Choose "No," if the percentage of PWD and/or PWTD who received other types of recognition exceeds the benchmark.

Example:

Section IV.D: Promotions

The purpose of this section is to examine whether there are any triggers limiting the upward mobility for PWD and PWTD at the agency. This section takes a step by step approach to identify triggers throughout the workforce lifecycle. An analysis of the workforce data in table B(x) may indicate the existence of a glass wall or a blocked pipeline in the agency's promotion program limiting upward mobility opportunities for PWD and/or PWTD.

1. Does your agency have a trigger involving PWD among the qualified internal applicants and/or selectees for promotions to the senior grade levels? (The appropriate benchmarks are the relevant applicant pool for qualified internal applicants and the qualified applicant pool for selectees.) For non-GS pay plans, please use the approximate senior grade levels. If "yes", describe the trigger(s) in the text box.

• a. SES

  i. Qualified Internal Applicants (PWD)	Yes	0	No	0
  ii. Internal Selections (PWD)	Yes	0	No	0

• b. Grade GS-15

  i. Qualified Internal Applicants (PWD)	Yes	0	No	0
  ii. Internal Selections (PWD)	Yes	0	No	0

• c. Grade GS-14

  i. Qualified Internal Applicants (PWD)	Yes	0	No	0
  ii. Internal Selections (PWD)	Yes	0	No	0

• d. Grade GS-13

  i. Qualified Internal Applicants (PWD)	Yes	0	No	0
  ii. Internal Selections (PWD)	Yes	0	No	0

In Section IV.D.1, examine the applicant flow data in each of the senior grade levels for triggers involving PWD. The appropriate benchmarks are the relevant applicant pool for qualified internal applicants and the qualified applicant pool for selectees. Using the benchmarks, compare the percentage of PWD among qualified internal applicants and promotions in each of the senior grade levels to the benchmark.

• Choose "Yes," if the percentage of PWD among qualified internal applicants and/or selectees for promotion in each of the senior grade levels falls below the benchmark. Then, describe the trigger(s) in the text box.
• Choose "No," if the percentage of PWD among qualified internal applicants and/or selectees for promotion in each of the senior grade levels exceeds the benchmark.

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2. Does your agency have a trigger involving PWTD among the qualified internal applicants and/or selectees for promotions to the senior grade levels? (The appropriate benchmarks are the relevant applicant pool for qualified internal applicants, and the qualified applicant pool for selectees.) For non-GS pay plans, please use the approximate senior grade levels. If "yes", describe the trigger(s) in the text box.

a. SES

b. Grade GS-15

c. Grade GS-14

d. Grade GS-13

In Section IV.D.2, examine the applicant flow data in each of the senior grade levels for triggers involving PWTD. The appropriate benchmarks are the relevant applicant pool for qualified internal applicants and the qualified applicant pool for selectees. Using the benchmarks, compare the percentage of PWTD among qualified internal applicants and promotions in each of the senior grade levels to the benchmark.

• Choose "Yes," if the percentage of PWTD among qualified internal applicants and/or selectees for promotion in each of the senior grade levels falls below the benchmark. Then, describe the trigger(s) in the text box.
• Choose "No," if the percentage of PWTD among qualified internal applicants and/or selectees for promotion in each of the senior grade levels exceeds the benchmark.

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3. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving PWD among the new hires to the senior grade levels? For non-GS pay plans, please use the approximate senior grade levels. If "yes", describe the trigger(s) in the text box.

Section IV.D.3, examine the applicant flow data in each of the senior grade levels for triggers involving PWD. Using the qualified applicant pool as the benchmark, compare the percentage of PWD among qualified external applicants and new hires in each of the senior grade levels to the benchmark.

• Choose "Yes," if the percentage of PWD among selectees for new hires in each of the senior grade levels falls below the benchmark. Then, describe the trigger(s) in the text box.
• Choose "No," if the percentage of PWD among selectees for new hires in each of the senior grade levels exceeds the benchmark.

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4. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving PWTD among the new hires to the senior grade levels? For non-GS pay plans, please use the approximate senior grade levels. If "yes", describe the trigger(s) in the text box.

In Section IV.D.4, examine the applicant flow data in each of the senior grade levels for triggers involving PWTD. Using the qualified applicant pool as the benchmark, compare the percentage of PWTD among qualified external applicants and new hires in each of the senior grade levels to the benchmark.

• Choose "Yes," if the percentage of PWTD among selectees for new hires in each of the senior grade levels falls below the benchmark. Then, describe the trigger(s) in the text box.
• Choose "No," if the percentage of PWTD among selectees for new hires in each of the senior grade levels exceeds the benchmark.

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5. Does your agency have a trigger involving PWD among the qualified internal applicants and/or selectees for promotions to supervisory positions? (The appropriate benchmarks are the relevant applicant pool for qualified internal applicants and the qualified applicant pool for selectees.) If "yes", describe the trigger(s) in the text box.

a. Executives

b. Managers

c. Supervisors

In Section IV.D.5, identify the percentage of PWD among the qualified internal applicants and selectees for promotion to each of the supervisory levels. The appropriate benchmarks are the relevant applicant pool for qualified internal applicants and the qualified applicant pool for selectees. Using the benchmarks, compare the percentage of PWD among the qualified internal applicants and selectees for promotion to the benchmark in each of the supervisory levels.

• Choose "Yes," if the percentage of PWD among qualified internal applicants and/or selectees for promotion in each of the supervisory levels falls below the benchmark. Then, describe the trigger(s) in the text box.
• Choose "No," if the percentage of PWD among qualified internal applicants and/or selectees for promotion in each of the supervisory levels exceeds the benchmark.

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6. Does your agency have a trigger involving PWTD among the qualified internal applicants and/or selectees for promotions to supervisory positions? (The appropriate benchmarks are the relevant applicant pool for qualified internal applicants and the qualified applicant pool for selectees.) If "yes", describe the trigger(s) in the text box.

a. Executives

b. Managers

c. Supervisors

In Section IV.D.6, identify the percentage of PWTD among the qualified internal applicants and selectees for promotion to each of the supervisory levels. The appropriate benchmarks are the relevant applicant pool for qualified internal applicants and the qualified applicant pool for selectees. Using the benchmarks, compare the percentage of PWTD among the qualified internal applicants and selectees for promotion to the benchmark in each of the supervisory levels.

• Choose "Yes," if the percentage of PWTD among qualified internal applicants and/or selectees for promotion in each of the supervisory levels falls below the benchmark. Then, describe the trigger(s) in the text box.
• Choose "No," if the percentage of PWTD among qualified internal applicants and/or selectees for promotion in each of the supervisory levels exceeds the benchmark.

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7. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving PWD among the selectees for new hires to supervisory positions? If "yes", describe the trigger(s) in the text box.

In Section IV.D.7, identify the percentage of PWD among the selectees for new hires to each of the supervisory levels. Using the qualified applicant pool as the benchmark, compare the percentage of PWD among the selectees for new hires to the benchmark in each of the supervisory levels.

• Choose "Yes," if the percentage of PWD among selectees for new hires in each of the supervisory levels falls below the benchmark. Then, describe the trigger(s) in the text box.
• Choose "No," if the percentage of PWD among selectees for new hires in each of the supervisory levels exceeds the benchmark

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8. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving PWTD among the selectees for new hires to supervisory positions? If "yes", describe the trigger(s) in the text box.

In Section IV.D.5, identify the percentage of PWTD among the selectees for new hires to each of the supervisory levels. Using the qualified applicant pool as the benchmark, compare the percentage of PWTD among the selectees for new hires to the benchmark in each of the supervisory levels.

• Choose "Yes," if the percentage of PWTD among qualified external applicants and/or selectees for new hires in each of the supervisory levels falls below the benchmark. Then, describe the trigger(s) in the text box.
• Choose "No," if the percentage of PWTD among qualified external applicants and/or selectees for new hires in each of the supervisory levels exceeds the benchmark

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Section V: Plan to Improve Retention of Individuals with Disabilities

To be a model employer for persons with disabilities, agencies must have policies and programs in place to retain employees with disabilities. In this section, agencies should: (1) analyze workforce separation data to identify barriers retaining employees with disabilities; (2) describe efforts to ensure accessibility of technology and facilities; and, (3) provide information on the reasonable accommodation program and workplace personal assistance services.

Section V.A: Voluntary and Involuntary Separations

In this section, agencies should analyze workforce separation data to identify whether triggers exist for retaining PWD and PWTD. Triggers may include failing to convert eligible Schedule A employees into the competitive service; terminations due to medical examinations or background investigations; workplace culture that marginalizes employees with disabilities; or a lack of advancement opportunities.

1. In this reporting period, did the agency convert all eligible Schedule A employees with a disability into the competitive service after two years of satisfactory service (5 C.F.R. § 213.3102(u)(6)(i))? If "no", please explain why the agency did not convert all eligible Schedule A employees.

In Section V.A.1, assess whether the agency has converted all eligible Schedule A employees with disabilities to the competitive service after two years of satisfactory performance.

• Choose "Yes," if the agency has converted all eligible Schedule A employees with disabilities.
• Choose "No," if the agency has not converted all eligible Schedule A employees with disabilities. Then, explain the agency's plan to establish a process to convert eligible Schedule A employees.
• Choose "N/A"," if the agency does not employ any Schedule A individuals with disabilities.

Example:

2. Using the inclusion rate as the benchmark, did the percentage of PWD among voluntary and involuntary separations exceed that of persons without disabilities? If "yes", describe the trigger below.

In Section V.A.2, identify the percentage of PWD who separated from the permanent workforce, both voluntarily and involuntarily. Using the inclusion rate as the benchmark, compare the percentage of PWD who voluntarily and involuntarily separated from the permanent workforce to the corresponding rate of persons without disabilities.

• Choose "Yes," if the inclusion rate of PWD who voluntarily and/or involuntarily separated from the permanent workforce is higher than that of persons without disabilities. Then, describe the trigger(s) in the text box.
• Choose "No," if the inclusion rate of PWD who voluntarily and/or involuntarily separated from the permanent workforce is lower than that of persons without disabilities.

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3. Using the inclusion rate as the benchmark, did the percentage of PWTD among voluntary and involuntary separations exceed that of persons without targeted disabilities? If "yes", describe the trigger below.

In Section V.A.3, identify the percentage of PWTD who separated from the permanent workforce, both voluntarily and involuntarily. Using the inclusion rate as the benchmark, compare the percentage of PWTD who voluntarily and involuntarily separated from the permanent workforce to the corresponding rate of persons without disabilities.

• Choose "Yes," if the inclusion rate of PWTD who voluntarily and/or involuntarily separated from the permanent workforce is higher than that of persons without disabilities. Then, describe the trigger(s) in the text box.
• Choose "No," if the inclusion rate of PWTD who voluntarily and/or involuntarily separated from the permanent workforce is lower than that of persons without disabilities.

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4. If a trigger exists involving the separation rate of PWD and/or PWTD, please explain why they left the agency using exit interview results and other data sources.

In Section V.A.4, review exit interview survey results so the agency can identify what has motivated PWD and/or PWTD to leave the agency. Agencies unable to report this information should discuss steps to gather and analyze separation data over the next fiscal year.

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Section V.B: Accessibility of Technology and Facilities

Pursuant to 29 C.F.R. § 1614.203(d)(4), federal agencies are required to inform applicants and employees of their rights under Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. § 794(b)), concerning the accessibility of agency technology, and the Architectural Barriers Act of 1968 (42 U.S.C. § 4151-4157), concerning the accessibility of agency facilities. In addition, agencies are required to inform individuals where to file complaints if other agencies are responsible for a violation.

1. Please provide the internet address on the agency's public website for its notice explaining employees' and applicants' rights under Section 508 of the Rehabilitation Act, including a description of how to file a complaint.

In Section V.B.1, report whether the agency complies with 29 C.F.R. § 1614.203(d)(4), which requires them to post a notice of rights under Section 508 of the Rehabilitation Act of 1973, including a description of how to file a complaint, on its public website. Additional information on agency obligations under Section 508 of the Rehabilitation Act, is available on the General Services Administration's Government-wide Section 508 Accessibility Program website at https://section508.gov/

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2. Please provide the internet address on the agency's public website for its notice explaining employees' and applicants' rights under the Architectural Barriers Act, including a description of how to file a complaint.

In Section V.B.2, report whether the agency complies with 29 C.F.R. § 1614.203(d)(4), which requires them to post a notice of rights under the Architectural Barriers Act of 1968, including a description of how to file a complaint, on its public website.

Example:

3. Describe any programs, policies, or practices that the agency has undertaken, or plans on undertaking over the next fiscal year, designed to improve accessibility of agency facilities and/or technology.

In Section V.B.3, briefly discuss the agency's programs, policies, or practices that are designed to improve accessibility within agency facilities and/or technology. If the agency does not currently have any programs, policies, or practices, the agency should explain its plans to develop and implement programs, policies, and practices.

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Section V.C: Reasonable Accommodation Program

Pursuant to 29 C.F.R. § 1614.203(d)(3), agencies must adopt, post on their public website, and make available to all job applicants and employees, reasonable accommodation procedures.

1. Please provide the average time frame for processing initial requests for reasonable accommodations during the reporting period. (Please do not include previously approved requests with repetitive accommodations, such as interpreting services.)

In Section V.C.1, provide the time frame to decide requests pursuant to its reasonable accommodation procedures and then provide the average number of days that the agency took to decide accommodation requests during the reporting period. Please do not include previously approved requests with repetitive accommodations, such as interpretive services.

Example:

2. Describe the effectiveness of the policies, procedures, or practices to implement the agency's reasonable accommodation program. Some examples of an effective program include timely processing requests, timely providing approved accommodations, conducting training for managers and supervisors, and monitoring accommodation requests for trends.

In Section V.C.2, describe the effectiveness of the agency's policies, procedures, or practices to implement the reasonable accommodation program. Some examples of an effective program include timely processing requests, timely providing approved accommodations, conducting training for managers and supervisors, and monitoring the requests for trends.

Example:

 

Section V.D: Personal Assistance Services Allowing Employees to Participate in the Workplace

Pursuant to 29 C.F.R. § 1614.203(d)(5), federal agencies, as an aspect of affirmative action, are required to provide personal assistance services (PAS) to employees who need them because of a targeted disability, unless doing so would impose an undue hardship on the agency.

Describe the effectiveness of the policies, procedures, or practices to implement the PAS requirement. Some examples of an effective program include timely processing requests for PAS, timely providing approved services, conducting training for managers and supervisors, and monitoring PAS requests for trends.

In Section VI.D.2, describe whether the agency's policies, procedures, and/or practices have been effective in providing PWTD with personal assistance services. Some examples of an effective program include timely processing requests, timely providing approved personal assistance services, conducting training for managers and supervisors, and monitoring the requests for trends. If the agency has modified its PAS procedures, or plans to do so in the next fiscal year, please describe the changes to the procedures.

Example:

Section VI: EEO Complaint and Findings Data

In addition to workforce data, the analysis of EEO complaint data can reveal triggers for PWD and PWTD. The frequency of EEO complaints alleging discrimination based on disability status or the failure to provide reasonable accommodations can suggest real or perceived barriers for PWD and PWTD. Moreover, findings of discrimination or settlement agreements involving PWD and PWTD provide strong evidence that barriers exist.

Section A: EEO Complaint Data involving Harassment

1. During the last fiscal year, did a higher percentage of PWD file a formal EEO complaint alleging harassment, as compared to the government-wide average?

 

In Section VI.A.1, review the formal complaints filed by PWD against the agency and determine whether a higher percentage alleged harassment than the government-wide average.

• Choose "Yes," if the agency's percentage of complaints filed by PWD alleging harassment exceeded the government-wide average.
• Choose "No," if the agency's percentage of complaints filed by PWD alleging harassment was lower than the government-wide average.
• A "N/A" response indicates that PWD did not file any complaints against the agency during the reporting period.

2. During the last fiscal year, did any complaints alleging harassment based on disability status result in a finding of discrimination or a settlement agreement?

 

In Section VI.A.2, review final agency decisions to determine if the agency found harassment or entered into settlement agreements with PWD who alleged harassment.

• Choose "Yes," if there was a finding of discrimination or a settlement agreement involving PWD who alleged harassment.
• Choose "No," if there were no findings of discrimination or settlement agreements involving PWD who alleged harassment.
• A "N/A" response indicates that the agency did not have any findings of discrimination and settlement agreements during the reporting period.

3. If the agency had one or more findings of discrimination alleging harassment based on disability status during the last fiscal year, please describe the corrective measures taken by the agency.

In Section VI.A.3, describe the type(s) of corrective action that the agency has implemented to address findings of discrimination alleging harassment based on disability status.

Example:

Section B: EEO Complaint Data Involving Reasonable Accommodation

1. During the last fiscal year, did a higher percentage of PWD file a formal EEO complaint alleging failure to provide a reasonable accommodation, as compared to the government-wide average?

 

In Section VI.B.1,review the formal complaints filed by PWD against the agency and determine whether a higher percentage alleged failure to provide a reasonable accommodation than the government-wide average.

• Choose "Yes," if the agency's percentage of complaints filed by PWD alleging failure to accommodate exceeded the government-wide average.
• Choose "No," if the agency's percentage of complaints filed by PWD alleging failure to accommodate was lower than the government-wide average.
• A "N/A" response indicates that PWD did not file any complaints against the agency during the reporting period.

2. During the last fiscal year, did any complaints alleging failure to provide reasonable accommodation result in a finding of discrimination or a settlement agreement?

 

In Section VI.B.2, review final agency decisions to determine if the agency found the failure to provide a reasonable accommodation or entered into settlement agreements with PWD who alleged failure to accommodate.

• Choose "Yes," if there was a finding of discrimination or a settlement agreement involving the agency's failure to provide a reasonable accommodation.
• Choose "No," if there were no findings of discrimination or settlement agreements involving the agency's failure to provide a reasonable accommodate.
• A "N/A" response indicates that the agency did not have any findings of discrimination and settlement agreements during the reporting period.

3. If the agency had one or more findings of discrimination involving the failure to provide a reasonable accommodation during the last fiscal year, please describe the corrective measures taken by the agency.

In Section VI.B.3, describe the type(s) of corrective action that the agency has implemented to address findings of discrimination involving the failure to provide a reasonable accommodation.

Example:

Section VII: Identification and Removal of Barriers

Element D of MD-715 requires agencies to conduct a barrier analysis when a trigger suggests that a policy, procedure, or practice may be impeding the employment opportunities of a protected EEO group.For more information about the barrier analysis process, please review Section II.

1. Has the agency identified any barriers (policies, procedures, and/or practices) that affect employment opportunities for PWD and/or PWTD?

 

In Section VII.1, answer whether the agency has identified any policies, procedures, or practices that limit the employment opportunities of PWD and/or PWTD during the reporting period.

• Choose "Yes," if the agency has identified any barriers involving PWD and/or PWTD.
• Choose "No," if the agency has not identified any barriers involving PWD and/or PWTD.

2. Has the agency established a plan to correct the barrier(s) involving PWD and/or PWTD?

In Section VII.2, report whether the agency has established a plan to correct any policies, procedures, or practices that limit the employment opportunities of PWD and/or PWTD.

• Choose "Yes," if the agency has established a plan to correct barriers involving PWD and/or PWTD.
• Choose "No," if the agency has not established a plan to correct barriers involving PWD and/or PWTD.
• A "N/A" response indicates that the agency did not identify any barriers involving PWD and/or PWTD.

3. Identify each trigger and plan to remove the barrier(s), including the identified barrier(s), objective(s), responsible official(s), planned activities, and, where applicable, accomplishments.

In Section VII.3, describe the trigger in each plan to remove the identified barrier(s). The agency can generate multiple plans in PART J. Each field in the plan is described as follows:

• Barrier(s): Describe the policies, procedures, or practices that are limiting employment opportunities for PWD and/or PWTD.
• Objective(s): For each barrier, provide a clear statement of one or more measurable objectives (e.g., the implementation of a revised policy, procedure or practice) which will be implemented to correct the barrier.
• Responsible Official(s): Agencies should enter the name and title of each agency official who is responsible for implementing the agency's completion of the plan.
• Planned Activities: In this section, enter the specific activities and target date for completing the activities. Activities should be designed to directly contribute toward completion of the objective. In addition, the agency should identify whether there is sufficient staffing and funding to complete each activity by the target date. When applicable, the agency should provide the modified date and the completion date for each planned activity.
• Accomplishments: Agencies should describe the status of activities undertaken for each fiscal year. As such, the same plan can be updated from year to year. EEOC expects agencies to demonstrate meaningful progress toward the removal of all barriers to equal opportunity. If the agency did not have sufficient staffing or funding to complete one or more activities by the target date, the agency should provide an explanation.

 

Example:

 

4. Please explain the factor(s) that prevented the agency from timely completing any of the planned activities.

 

In Section VII.4, describe why the agency did not timely complete one or more of its planned activities and provide its plan to ensure future activities are timely completed. If applicable, the agency should explain its process for holding the responsible official accountable for untimely planned activities.

Example:

 

5. For the planned activities that were completed, please describe the actual impact of those activities toward eliminating the barrier(s).

In Section VII.5, describe the impact that the planned activities had on addressing the identified barrier(s). For example, the agency should consider whether the activities removed the trigger(s).

Example:

 

6. If the planned activities did not correct the trigger(s) and/or barrier(s), please describe how the agency intends to improve the plan for the next fiscal year.

In Section VII.6, describe whether the agency intends to modify any of the plans because the planned activities did not correct the trigger(s).

Example: