Section IV
Interpretation and Completion of Workforce Data Tables

 

I. General Information about the Workforce Data Tables

The MD-715 workforce data tables are useful as an initial diagnostic tool to assist agencies in identifying triggers during the barrier analysis process. There are two types of tables: "A" and "B", which contain snapshots of the gains and losses in the total workforce, occupational categories, pay plans/grade levels, mission-critical occupations, senior grade levels, salary, management levels, and awards. With a nearly identical format, the A tables collect race/ethnicity and gender data, and the B tables capture persons with targeted disabilities data.

While the workforce data tables are helpful as a starting point, identification of workplace barriers demands a thorough examination of all relevant circumstances. An agency should focus on what the compiled data reveals about its workforce, and it must recognize that statistics are only the starting point of the barrier analysis process. Once an agency finds triggers, it must investigate to uncover links to specific employment policies, practices, and procedures. The results of this investigation are reported in PART I (race, gender, and national origin) and PART J (disability status).

This Section of the Instructions has been substantially revised to assist agencies in capturing the correct data for their workforce data tables and in understanding how to use the data in the barrier analysis process. EEOC restructured the tables based on our experience reviewing agency reports and in response to feedback received from our stakeholders. The guidance for each table is broken down into three key areas: (1) the purpose for the table; (2) instructions for completing the table; and (3) a non-exhaustive listing of possible triggers to be investigated that may flow from the data revealed in the table. The changes to this Section are explained throughout the document below.

A. Time Period for the Workforce Data

Agencies must capture workforce data during each fiscal year, beginning with October 1^st and ending with September 30^th.

B. Submission Requirements Based on Size of Agency

Agencies with 500 or more full-time and part-time employees must submit Tables A/B 1-9. Agencies with 499 or fewer employees must submit Tables A/B 1-5.

EEOC also collects workforce data from second-level sub-components with 1,000 or more full-time and/or part-time employees, which must submit Tables A/B 1-9.

C. New Online Forms

In the previous version of the Instructions, agencies were required to submit a hardcopy of the workforce data tables with their MD-715 reports. With the transition to online submissions, agencies must now submit their MD-715 reports electronically. Each year EEOC will post an Excel version of the workforce data tables for agencies to complete as part of the online submission. For more information about the online submission process, agencies should review the FedSEP User Guide.

D. Revisions to the Data Tables

The MD-715 workforce data tables has two different sets of tables. While nearly identical in format, the "A" tables capture data on race/ethnicity and gender, and the "B" tables address disability status. The two sets of tables contain snapshots of the gains and losses in the total workforce, ten occupational categories, pay plans/grade levels, salary, mission-critical occupations, senior grade levels, management levels, and awards. Many of the tables contain two versions: the participation rate and the inclusion rate, which show different ways of analyzing the same data. These rates will be discussed in Section I (H).

To simplify the process of identifying triggers, we have substantially revised and consolidated the workforce data tables by topic. For example, Tables A/B 6 incorporate data for employees in the mission-critical occupations (formerly major occupations) and applicant flow data for external hires, and internal promotions. The new tables will make it easier to assess the impact of the agency's workplace policies on the overall participation and upward mobility of various EEO groups. The following chart summarizes how the tables were consolidated:

 

The revised workforce data tables also capture new data. For example, EEOC added employee salaries in Tables A/B 5, grade levels for mission-critical occupations in Tables A/B 6, and applicant flow data for managers and supervisors in Tables A/B 8. Since many agencies do not have Wage Grade employees, that data is now available as an alternative pay plan for Tables A/B 4. Due to the large number of alternative pay systems, the new salary data in Tables A/B 5 will allow EEOC to compare the entire federal workforce. By capturing the grade levels within the mission-critical occupations in Tables A/B 6, EEOC discontinued previous Tables A/B 10 involving non-competitive promotions. As to Tables A/B 8, the grade levels and external applicant flow data for managers and supervisors will allow agencies to track the entire career path of their workforce.

E. Identifying the EEO Groups in the Workforce Data Tables

MD-715 requires agencies to report the race and national origin of employees and applicants for employment. In establishing the race and ethnic categories for these reporting purposes, EEOC was guided by the need to balance three interests: (1) accommodating changing demographics and the Office of Management and Budget's (OMB) government-wide Revisions to the Standards for the Classification of Federal Data on Race and Ethnicity ("OMB Standards"); (2) obtaining data that will be useful to the agencies' Title VII programs; and (3) limiting the burden on agencies. Therefore, EEOC is only asking agencies to report the EEO groups set forth on our tables. The tables include two national origin categories: "Hispanic or Latino" and "Not Hispanic or Latino." Regardless of race, if a person identifies as Hispanic or Latino, that person falls within that EEO group. The "Not Hispanic or Latino" category is comprised of the race categories, which include American Indian or Alaska Native, Asian, Black or African American, Native Hawaiian or Other Pacific Islander, White, and a catch all of Two or More Races. As to gender, each race and ethnic group specifies whether the employees are male or female.

Nothing in EEOC's reporting requirements prohibits agencies from collecting data on race and national origin in a more detailed fashion consistent with OMB guidance so long as the information collected can be aggregated into the categories EEOC requires for reporting on the MD-715 forms. Thus, agencies may wish to ask racial information of those who identify themselves as Hispanic. Similarly, agencies are encouraged to allow employees who identify themselves as members of more than one race to identify those races with specificity (i.e. "White" and "Asian"). It is important to note that Hispanic is not a race; therefore, a person who is Hispanic cannot fall within the Two or More races category. The Two or More races category also does not include people who identify as White and one other type of race. If a person is White and Asian, they would fall under the Asian category. Accordingly, people in the Two or More races category cannot identify as Hispanic, or White and one other race.

Self-identification is the preferred method for gathering information about employees' race, national origin, gender, and disability. Agencies should provide employees with opportunities to do so and should advise employees of the importance of the data and the agency's obligation to report it. If employees refuse to identify their race or national origin, the agency should make visual identification and inform the employee of the data it will be reporting. 29 C.F.R. § 1614.601(b). As to disability status, agencies can classify an employee as an individual with a disability on the basis of the following records: (1) self-identification in the SF-256 form; (2) appointment under a hiring authority that takes disability into account; and/or (2) a request for a reasonable accommodation. 29 C.F.R. § 1614.203(d)(6)(ii).

F. The New Disability Codes

Additionally, in 2016, OPM updated its SF-256 form to reflect the current definitional language with respect to the disability community. In FY 2017, EEOC modified the "B" workforce data tables to account for the new codes in the SF-256 form. Agencies should ensure that their personnel data collection systems capture the new codes.

Unlike the applicant flow data, the SF-256 form currently collects only one type of disability per employee. To ensure consistency with the demographic and applicant flow data, EEOC will coordinate with OPM to ensure that the SF-256 form allows for multiple types of disabilities. For agencies that can collect multiple types of disabilities per employee in their demographic data, they should include that information in the B tables. EEOC will no longer require the types of targeted disabilities to equal the total number of employees with targeted disabilities.

G. Supplementing Demographic Data for Disability Status

EEOC regulation, 29 C.F.R. §1614.203(d)(6)(ii), provides that an employee may be classified as an individual with a disability or a targeted disability based on (1) the Standard Form 256, (2) appointments under a hiring authority that takes disability into account, and (3) requests for reasonable accommodation. It is important to emphasize that agencies must ensure they do not double count employees with disabilities in their demographic data. As such, this supplemental data on disability status must be able to update the existing demographic data obtained from the SF-256 form. EEOC will coordinate with OPM in establishing a process to integrate the supplemental data into the demographic data. For agencies that do not report their demographic data to OPM, they must develop a process to integrate the supplemental data into their demographic data.

H. Permanent vs. Temporary Employees

Tables A/B 1 have separate sections for permanent and for temporary employees. Those agencies with temporary employees must file two sets of Tables A/B 4, A/B 5, and A/B 6, one for permanent employees, and one for temporary employees. All other tables should only capture data for permanent employees. Tenure codes 1 and 2 are considered permanent employee status. Any part time, intermittent, or seasonal employee with tenure code 1 or 2 is reported as permanent.

I. Management Occupational Category

In Tables A/B 3 and 8, the "officials and managers" occupational category has been changed to "management." The "management" category contains new subcategories, including "executives," "managers," and "supervisors," to more accurately describe the functions of these positions. Instead of using grade levels to distinguish the levels of management, Tables A/B 3 and 8 categorize management officials based on their level of responsibility and influence in the organizational hierarchy. The intention is for each subcategory of management to include individuals with equivalent levels of influence and responsibility at different agencies, even though their titles or grades may not always be the same.

Currently, agencies can identify the executives based on their hiring authority (e.g., SES); however, OPM's Guide to Data Standards does not distinguish between managers and supervisors because both fall within the supervisory status code 2. EEOC will coordinate with OPM in establishing a process to identify managers separately from supervisors. Until that process is implemented, agencies can continue to rely upon the grade levels to distinguish between managers and supervisors. Using the GS plan, the managers would be GS-13 and GS-14, while supervisors would be GS-12 and below. Agencies with alternate pay plans should use their grades that are equivalent to the GS grades.

J. Collection of Internal Competitive Promotions

In tables 6, 7, and 8, agencies are required to provide applicant flow data and selection data for internal competitive promotions. Pursuant to Chapter 14 of OPM's Guide to Processing Personnel Actions ("Guide") defines a promotion as a change of an employee while continuously employed from one grade to a higher grade, or makes permanent a temporary selection. The promotions will include data for agency employees as well as employees from other federal agencies, who applied through the merit promotion process. For agencies that use USA Staffing, OPM recommends the best way to collect applicant flow data for promotions is to sort by the announcement type for merit-based promotions. As to the selections data, OPM's Guide provides that agencies should combine the results for the nature of action codes pertaining to promotions (702 and 703). In addition to the promotion codes, agencies can also utilize conversions and/or transfers if they assign federal employees to a higher grade level following a competitive selection process. For the appropriate nature of action codes and legal authorities to consider, agencies should consult Chapters 9 and 14 of OPM's Guide. EEOC will continue to coordinate with OPM in improving the process to collect demographic and applicant flow data for internal competitive promotions.

K. Resurveying for Accurate Workforce Data

Beginning in 2004, EEOC encouraged agencies to resurvey their employees for accurate race and national origin identification. EEOC strongly encourages agencies to resurvey their workforce on all EEO groups at least every other year. It is important to reassure employees that the information collected through the resurvey will only be used to determine if the agency is meeting its hiring and retention goals.

L. Intelligence Agencies

Pursuant to the National Security Act of 1947, as amended, the number of employees in intelligence agencies is classified information and cannot be reported in the MD-715 reports. As such, intelligence agencies should provide only the percentages in the workforce data tables.

M. Foreign Nationals

Employees who are U.S. citizens are included in the workforce data tables, whether they are employed within the United States (including Puerto Rico) or abroad. Foreign nationals are not reported in the workforce data tables, whether or not the foreign national works overseas or in the United States.

N. Intermittent or Seasonal Employees

Intermittent or seasonal employment relate to the employees' work schedules and not the appointment type used to hire them. Both types of employment should be captured by the MD-715 workforce data tables. Seasonal and intermittent employees can be either permanent or temporary status. Seasonal employment occurs when the work lasts at least six months per year on a recurring basis every year. 5 C.F.R. § 340.402. However, intermittent employment involves work that is sporadic and unpredictable, allowing agencies to use such employees in emergencies. 5 C.F.R § 340.403.

II. The "A" and "B" Tables

The remainder of this document provides guidance for completing and analyzing each table. Employee numbers should be obtained from the agency workforce data and personnel action data. Applicant data may also be obtained through a separate tracking system.

A. Tables A/B 1 - Total Workforce

Purpose

The revised Tables A/B 1 combines the prior Tables A/B 1 with Tables A/B 8 (gross hiring) and Tables A/B 14 (separations). This new table allows agencies to examine workforce distribution for the current and prior year to determine whether the changes, including net changes, are relatively uniform or whether any group is not keeping pace with the others. Those changes can be compared with actual employee gains and losses in the total workforce, permanent workforce, and temporary workforce.

In addition, the new Tables A/B 1 do not distinguish between appropriate and non-appropriated employees. Agencies should complete the total, permanent, and temporary workforce sections regardless of their funding sources.

In Table A1, the national CLF must be included; however, if agencies can also use an alternative benchmark (e.g. Relevant CLF or Regional CLF. In addition, Table B2 has replaced the federal high percentage with the goal of 12% for employees with reportable disabilities and 2% for employees with targeted disabilities.

The employee losses section of Tables A/B 1 has been expanded to include the types of resignation that typically occur.

For Table B1, agencies must also provide data concerning the number of competitive and Schedule A new hires.

Instructions for Completing Table A/B 1

In Tables A/B 1, agencies must submit the following data:

• In the workforce sections, enter the number of employees under each race/ethnicity or disability category for the "current fiscal year" and "prior fiscal year";
• Under "employee gains," enter the applicants, qualified applicants, and new hires by each race/ethnicity or disability category;
• Under "employee losses," enter the number of employees under each race/ethnicity or disability category for reductions-in-force, removals, resignations, retirements, and other separations;
• In Table A1, the table must include the national Civilian Labor Force as the benchmark; however, the agency can also submit an alternate benchmark; and
• In the "Total Workforce" section for Table B1, enter the number of employees who were either Schedule A or Competitive new hires.

For those agencies that report data to OPM, the chart below uses OPM's Guide to Data Standards to identify the codes needed to complete Table A/B 1:

 

B. Tables A/B 2 - Total Workforce by Component

Purpose

The purpose of Tables A/B 2 is to compare the permanent workforce distribution within each component to an appropriate benchmark in order to determine if possible hiring or retention barriers exist within specific components of the agency's workforce. This table remains unchanged; however, agencies now have the option of utilizing an alternative comparator as well as the national CLF in Table A2. In addition, Table B2 has replaced the federal high percentage with the goal of 12% for employees with reportable disabilities and 2% for employees with targeted disabilities.

Instructions for Completing Tables A/B 2

Agencies must enter the number of employees in the permanent workforce of each sub-component based on their race/ethnicity/gender or disability.If the agencies use a benchmark other than the national CLF, they can provide an alternative benchmark.

C. Tables A/B 3 - Occupational Categories

Purpose

This table allows agencies to review the distribution of employees among occupational categories to determine whether any group is encountering barriers to full participation in these categories. Tables A/B 3 have nine types of occupational categories, including management, professionals, technicians, sales workers, administrative support workers, craft workers, operatives, laborers and helpers, and service workers.

Instructions for Completing Tables A/B 3

In Tables A/B 3, agencies must enter the number of employees in the permanent workforce by race/ethnicity/gender or disability for each occupational category. EEOC has developed a Federal Sector Occupation Cross-Classification Table to assist agencies in determining the placement of each occupational series in one of the occupational categories. The table is located at http://www.eeoc.gov/federal/directives/00-09opmcode.cfm.

For those agencies that report data to OPM, the chart below uses OPM's Guide to Data Standards to identify the codes needed to complete Tables A/B 3:

 

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D. Tables A/B 4 - General Schedule Grades and Senior Pay Grades

Purpose

Tables A/B 4 covers the distribution of employees within the Senior Pay Grades (GS-13 to SES) as well as the General Schedule (GS) payroll system, which is still the most commonly utilized system throughout the federal government. Gaps in participation rates of particular groups at certain grade levels allow agencies to investigate whether or to what extent barriers exist at various grade levels.

If an agency does not have any GS employees, it can either leave Tables A/B 4 blank or convert its employees to the GS pay plan. Instead of completing Tables A/B 4, agencies with alternative pay systems, including the Wage Grade System, must select and complete the appropriate pay system table(s).

Instructions for Completing Tables A/B 4

In Tables A/B 4, agencies must submit separate data for the permanent and temporary segments of the workforce. To complete the tables, enter the number of permanent and temporary GS and senior pay employees.

E. Tables A/B 5 - Salary

Purpose

A new subject matter has replaced the Wage Grade System in Tables A/B 5. With close to sixty different pay systems utilized throughout the federal government, EEOC has added a salary table that will allow all of the federal pay systems to be compared and will assist EEOC in conducting equal pay analysis. This table tracks adjusted base pay.

Instructions for Completing Tables A/B 5

In Tables A/B 5, agencies must submit separate data for the permanent and temporary segments of the workforce by entering the number of employees in each group based on their adjusted base pay. When reporting part-time or temporary employees, agencies should provide the salary of those employees as if they worked full time for the entire year.

F. Tables A/B 6 - Mission-Critical Occupations

Purpose

Tables A/B 6 has likewise been substantially revised. This table addresses "mission-critical" occupations, as opposed to "major occupations." Mission-critical occupations are those occupations without which the agency cannot fulfill its mission. These occupations also tend to be the most heavily populated relative to other occupations within the agency and also typically follow a career path to senior leadership positions. In addition to tracking participation rates in particular occupations, Tables A/B 6 track participation at various grades within those occupations, obviating the need for the prior Tables A/B 10, which tracked career-ladder promotions. This table also consolidates participation rate data with data on competitive hiring (prior Tables A/B 7) and internal competitive promotions (prior Tables A/B 9).

Instructions for Completing Tables A/B 6

In Tables A/B 6, agencies must submit separate data for the permanent and temporary segments of the workforce. The tables require agencies to enter the following data:

• The occupational CLF data for each mission-critical occupation;
• The numbers of employees in each group for the mission-critical occupations as well as the grade levels within the mission-critical occupation;
• The number of people who applied, were qualified for, referred, interviewed, and were selected for internal competitive promotions and external new hires; and
• The relevant applicant pool for the internal competitive promotions, which typically includes the people who are eligible to apply for the promotion.

For those agencies that report data to OPM, the chart below uses OPM's Guide to Data Standards to identify the codes needed to complete Tables A/B 6. For the internal and external selections, agencies should obtain this data from their personnel system, rather than their applicant flow data. The chart below contains the Nature of Action codes for those agencies that report to OPM.

 

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G. Tables A/B 7 - Senior Grade Levels

Purpose

Tables A/B 7 integrate the data on participation in senior grade levels (prior Tables A/B 4) with promotions data (prior Tables A/B 11) and a new data category pertaining to new hires. Federal agencies frequently recruit senior level employees from external sources; hence, this data needs to be captured and tracked. The data entry procedures are similar to those in Tables A/B 6.

Instructions for Completing Tables A/B 7

In Tables A/B 7, agencies must submit data using the permanent workforce. The tables require agencies to enter the following data:

• The number of employees for each group in the SES or equivalent, GS-15 or equivalent, GS-14 or equivalent, and GS-13 or equivalent;
• The data corresponding to each phase of the selection process for internal competitive promotions, new hires, and career development programs; and
• For the benchmark population, Table A7 requires the upward mobility benchmark; however, agencies may also include an alternate benchmark. As to Table B7, agencies must use the goals of 12% for employees with disabilities and 2% for employees with targeted disabilities.

For purposes of MD-715 reporting, a career development program would qualify a participant for a promotion to a senior grade level upon completion of the program. Unlike typical training pursuant to the Individual Development Program (IDP), employees must compete to participate in career development programs. 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.

Once agencies submit the data for Tables A/B 7, EEOC will generate two formats: 7-1 (participation rate and 7-2 (inclusion rate). For those agencies that report data to OPM, the chart below uses OPM's Guide to Data Standards to identify the codes needed to complete Tables A/B 7. For the internal and external selections, agencies should obtain this data from their personnel system, rather than their applicant flow data. The chart below contains the Nature of Action codes for those agencies that report to OPM.

 

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H. Tables A/B 8 - Management Positions

Purpose

This table consolidates participation rate data for executives, managers, and supervisors with their grade levels, external hiring data, internal promotions, data, and career development programs. Its purpose is to gauge the extent to which any group might be impeded in their efforts to move up through the ranks.

Instructions for Completing Tables A/B 8

In Tables A/B 8, agencies must submit data using the permanent workforce. The tables require agencies to enter the following data:

• The grade levels within the managerial positions (e.g., executive, manager, and supervisor); and
• The data corresponding to each phase of the selection process for internal competitive promotions, new hires, and career development programs.
• For the benchmark population, Table A8 requires the upward mobility benchmark; however, agencies may also include an alternate benchmark. As to Table B8, agencies must use the goals of 12% for employees with disabilities and 2% for employees with targeted disabilities.

For purposes of MD-715 reporting, a career development program would qualify a participant for a promotion to management upon completion of the program. Unlike typical training pursuant to the Individual Development Program (IDP), employees must compete to participate in career development programs. 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.

Once agencies submit the data for Tables A/B 8, EEOC will generate two formats: 8-1 (participation rate and 8-2 (inclusion rate). For those agencies that report data to OPM, the chart below uses OPM's Guide to Data Standards to identify the codes needed to complete Tables A/B 8. For the internal and external selections, agencies should obtain this data from their personnel system, rather than their applicant flow data. The chart below contains the Nature of Action codes for those agencies that report to OPM.

 

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I. Tables A/B 9 - Employee Recognition and Awards

Purpose

This table is the prior Tables A/B 13, with an expanded range of awards under the general categories of time-off awards and cash awards. When looking for triggers, one should compare the average award received by a particular group with the average award in that award category given to all employees listed in the far left column of the table.

Instructions for Completing Tables A/B 9

In Tables A/B 9, agencies must submit data using the permanent workforce. The tables require agencies to enter the following data:

· The number of employees in each group who received an award; and

· The total number of hours or the total dollar amount corresponding to the award.

Once agencies submit the data for Tables A/B 9, EEOC will generate two formats: 9-1 (participation rate and 9-2 (inclusion rate). For those agencies that report data to OPM, the chart below uses OPM's Guide to Data Standards to identify the codes needed to complete Tables A/B 9:

 

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