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Affirmative Action Plan

for the Recruitment, Hiring, Advancement, and

Retention of Persons with Disabilities

 

Section I: Efforts to Reach Regulatory Goals.. 2

 

Section II: Model Disability Program.. 3

A. Plan to Provide Sufficient & Competent Staffing for Disability Program... 3

B. Plan to Ensure Sufficient Funding for the Disability Program... 4

 

Section III: Program Deficiencies in the Disability Program   4

 

Section IV: Plan to Recruit and Hire Individuals with Disabilities   5

A. Plan to Identify Job Applicants with Disabilities. 5

B. Plan to Establish Contacts with Disability Employment Organizations. 7

C. Progression Towards Goals (Recruitment and Hiring)7

 

Section V: Plan to Ensure Advancement Opportunities for Employees with Disabilities.. 8

A.  Advancement Program Plan.. 8

B.  Career Development Opportunities. 9

C.  Awards. 9

D. Promotions. 10

 

Section VI: Plan to Improve Retention of Persons with Disabilities   14

A. Voluntary and Involuntary Separations. 14

B. Accessibility of Technology and Facilities. 15

C. Reasonable Accommodation Program... 16

D. Personal Assistance Services Allowing Employees to Participate in the Workplace. 17

 

Section VII: EEO Complaint and Findings Data.. 17

A. EEO Complaint Data Involving Harassment. 17

B. EEO Complaint Data Involving Reasonable Accommodation.. 18

 

Section VIII: Identification and Removal of Barriers.. 18

 


 

Affirmative Action Plan

for the Recruitment, Hiring, Advancement, and

Retention of Persons with Disabilities

To capture agencies’ affirmative action plan for persons with disabilities (PWD) and persons with targeted disabilities (PWTD), EEOC regulations (29 C.F.R. § 1614.203(e)) and MD-715 require agencies to describe how their affirmative action plan will improve the recruitment, hiring, advancement, and retention of applicants and employees with disabilities.

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 reportable and 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.

a.    Cluster GS-1 to GS-10 (PWD)                                     Yes  0             No  X

b.    Cluster GS-11 to SES (PWD)                                      Yes  X            No  0

The percentage of PWD in the GS-11 to SES cluster was 10.15% in FY 2016, which falls below the goal of 12%.

  1. 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.

a.    Cluster GS-1 to GS-10 (PWTD)                                   Yes  0            No  X

b.    Cluster GS-11 to SES (PWTD)                                    Yes  X            No  0

 

The percentage of PWTD in the GS-11 to SES cluster was 1.15% in FY 2016, which falls below the goal of 2%.

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

On February 17, 2017, the agency issued a memorandum to HR staff and hiring managers, describing the agency’s commitment to meeting the numerical goals set forth under Section 501. The memorandum emphasized improving hiring efforts in the following occupations: IT Management; Program Analyst; Accounting; and Financial Management Analysis.

Section II: Model Disability Program

Pursuant to 29 C.F.R. § 1614.203(d)(1), 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.

A. Plan to Provide Sufficient & Competent Staffing for 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.

Yes  0             No  X

During FY 2017, the agency’s Reasonable Accommodation Coordinator retired and the position has remained vacant due to a hiring freeze.  The agency plans to post a vacancy announcement for the position in February 2018.

 

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

Disability Program Task

# of FTE Staff by Employment Status

Responsible Official

(Name, Title, Office, Email)

Full Time

Part Time

Collateral Duty

Processing applications from PWD and PWTD

1

2

2

Susan Smith, Disability Recruitment Program Manager, Office of Human Resources, susan.smith@agency.gov

Answering questions from the public about hiring authorities that take disability into account

1

2

2

Susan Smith, Disability Recruitment Program Manager, Office of Human Resources, susan.smith@agency.gov

Processing reasonable accommodation requests from applicants and employees

1

2

1

Stephanie Hernandez, Director, Diversity and Inclusion Programs, Office of Civil Rights, Stephanie.hernandez@agency.gov

Section 508 Compliance

 

1

1

Bill McDowell, Deputy Director, Office of Information Technology, william.mcdowell@agency.gov

Architectural Barriers Act Compliance

 

1

1

Monique Jones, Space and Management Specialist, Office of the Chief Financial Officer, Monique.jones@agency.gov

Special Emphasis Program for PWD and PWTD

1

 

4

Patricia Brown, Director, Office of Civil Rights, patricia.brown@agency.gov

 

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(s) that disability program staff have received.  If “no”, describe the training(s) planned for the upcoming year.

Yes  0             No  X

 

In FY 2017, the agency engaged in activities designed to increase the knowledge and skills among disability program staff.  The agency required all staff responsible for recruiting and hiring to complete OPM’s Special Placement Program Coordinator training. Completion of the comprehensive training was included in employee’s performance plans for FY 2017. Leadership in both HR and EEO offices organized an award ceremony to recognize employees who completed the training curriculum. At the end of FY 2017, nearly three fourths of these staff members completed the training. By the end of FY 2018, the agency anticipates having a 100% completion rate.

 

B. Plan to Ensure Sufficient Funding for the Disability Program

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.

Yes  0             No  X

The agency was unable to get additional funding and staff in FY 2017. The hiring freeze and cuts to the agency’s overall budget hampered the agency’s ability to backfill the HQ Senior Disability Program Manager position which has been vacant since FY 2016. The agency has prioritized funding for this position in FY 2018. However, the disability program did receive IT resources to develop an online reasonable accommodation tracking system.

Section III: Program Deficiencies in the Disability Program

(FedSEP will provide the program deficiencies from the current Part G.  We highlighted the Part G questions in green.  In the chart below, please list the highlighted Part G questions with “No” answers and provide the agencies’ comments, if any.

If there are no program deficiencies, please state “The agency has not reported any program deficiencies involving the disability program.”)

In Part G of its FY 2017 MD-715 report, the agency identified the following program deficiencies involving its disability program:

Program Deficiencies

Agency Comments

D.1.c. Does the agency conduct exit interviews or surveys that include questions on how the agency could improve the recruitment, hiring, inclusion, retention and advancement of individuals with disabilities? [see 29 CFR 1614.203(d)(1)(iii)(C)]

The agency is working on a system to collect and analyze exit interview information. The system should be in-place by the end of FY 2018.

 

 

Section IV: 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.

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

Over the last fiscal year, the agency utilized a variety of recruitment strategies designed to increase the number of qualified applicants with disabilities and applicants with targeted disabilities within the major occupations. Currently, the agency has exceeded the 12% goal for PWD and the 2% sub-goal for PWTD at the GS-10 level and below. However, the agency falls well below the goals set forth in the final rule for senior grade level positions or positions that have upward mobility into the senior grades. As such, the agency developed the following multi-pronged and multi-year recruitment strategy:

 

  • Outreach: The Human Capital Office redesigned its external “my careers” webpage to highlight the agency’s commitment to ensuring a diverse and inclusive workforce at all levels. Over the next fiscal year, the agency will roll out a social media campaign focusing on workforce diversity.
  • Recruitment: In FY 2017, the Affirmative Employment Program (AEP) for PWD and the AEP for Veterans Employment served as recruiters for the Workforce Recruitment Program (WRP). Ten WRP interns were selected for summer internships at HQ, and another five interns were selected for positions at field offices.
  • In the third quarter of FY 2018, the agency will hold a virtual job fair specifically for PWD and PWTD who are eligible for appointment under hiring authorities that take disability into account. Each department with funded vacancies is required to participate in the virtual job fair. The agency anticipates filling forty or more positions in HQ and field offices through the job fair. The AEP for PWD, the Disability Program Manager, and the Veteran Employment Coordinator are working together to promote the event to their respective stakeholder groups. 

 

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. 

The agency uses all available and appropriate hiring authorities to recruit and hire PWD and PWTD. Recruitment efforts include:

  • The agency’s career website has a webpage specifically for applicants with disabilities. The site contains information for Schedule A eligible applicants, provides the contact information for the DPM, requesting reasonable accommodations, and applying for a Workforce Recruitment Program (WRP) internship
  • The agency hosted an online job fair exclusively for qualified, prescreened applicants who are eligible for appointment under the Schedule A hiring authority; the Veterans Recruitment Authority; and/or the 30% or more Disabled Veteran Authority. The agency made offers to 15 candidates.

The staffing specialist for our disabled veteran hiring program and the DPM served as volunteer recruiters for the WRP.

 

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 FY 2016, the Disability Recruitment Program Manager launched a searchable Schedule A candidate database for hiring managers. This database was integrated into the agency’s HRX system – a searchable applicant database for Disabled Veterans, Pathways Interns, and recent graduates. Managers are encouraged to consider all available candidates in HRX system prior to posting the vacancy.

 

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.

Yes  0             No  X              N/A  0

 

The agency provides disability-related training to its management team every three years.  This training covers the hiring goals, the reasonable accommodation program, special hiring authorities, and sensitivity/cultural awareness.  To date, the agency has trained 75% of its management team on the use of Schedule A hiring authority.  In March 2017, the agency plans to provide the disability training to all of its management team.

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 FY 2017, the agency signed a memorandum of understanding (MOU) with the Texas and Michigan State Vocational Rehabilitation Services Agency. The MOU will help the agency build a pipeline of qualified candidates who are eligible for appointment under the Schedule A hiring authority.

C. Progression Towards Goals (Recruitment and Hiring)

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.

a.    New Hires for Permanent Workforce (PWD)                                    Yes  X            No  0

b.    New Hires for Permanent Workforce (PWTD)                      Yes  X            No  0

 

Among the new hires in the permanent workforce, triggers exist for PWD (6.25%) and PWTD (0.85), both of which fall below the respective benchmark of 12% for PWD and 2% for PWTD.

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.

a.    New Hires for MCO (PWD)                  Yes  X            No  0

b.    New Hires for MCO (PWTD)                Yes  X            No  0

 

 

In comparison to the benchmarks, triggers exist for PWD (9.35%) and PWTD (0.76%) among the qualified external applicants for the Attorney position in FY 2016.

 

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.

a.    Qualified Applicants for MCO (PWD)             Yes  X            No  0

b.    Qualified Applicants for MCO (PWTD)          Yes  X            No  0

 

In comparison to the benchmarks, triggers exist for PWD (8.2%) and PWTD (0.17%) among the qualified internal applicants for promotions to the Lead Budget Analyst positions in FY 2016.

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.

a.    Promotions for MCO (PWD)                             Yes  X            No  0

b.    Promotions for MCO (PWTD)                          Yes  X            No  0

 

In comparison to the benchmarks, triggers exist for PWD (7.15%) and PWTD (0.68%) among the selections for promotion involving the Investigator position in FY 2016.

 

Section V: 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 this section, agencies should identify, and provide data on programs designed to ensure advancement opportunities for employees with disabilities.

A.  Advancement Program Plan

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

In FY 2018, the agency engaged in initiatives designed to ensure employees with disabilities and employees with targeted disabilities have sufficient advancement opportunity.  Training - In FY 2017, the Office of Diversity and Inclusion held briefing sessions with the employee resource group (ERG) for PWD to discuss barriers to advancement for employees with targeted disabilities. The agency determined that input from the ERG would enable the agency to tailor the Plan to the needs of the target group. The agency learned that employees were not receiving reasonable accommodations to attend training. As a result, the agency established a centralized accommodation fund for training programs. Beginning in FY 2018, announcements about training opportunities will include information about the centralized fund. In addition, the agency will notify employees about the centralized fund on the training and development intranet portal.

Mentoring - In FY 2017, the agency signed a MOU with the Disability Mentoring Coalition to develop a disability mentoring toolkit for managers. This toolkit will be issued in the 2nd quarter of FY 2018.

B.  Career Development Opportunities

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

The agency allocated 13 slots out of 80 for PWD in its leadership development program for mid-career professionals. The year-long course prepares mid-career professionals for managerial and leadership opportunities at the agency.

2.    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 applicants and the applicant pool for selectees.)  If “yes”, describe the trigger(s) in the text box.

a.    Applicants (PWD)                                  Yes  X            No  0

b.    Selections (PWD)                                  Yes  X            No  0

In FY 2016, triggers exist for PWD in all career development programs, except the mentoring program

3.    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.

a.    Applicants (PWTD)                                Yes  X            No  0

b.    Selections (PWTD)                                Yes  X            No  0

 

In FY 2016, triggers exist for PWTD in all career development programs except the details program.

C. 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.

a.    Awards, Bonuses, & Incentives (PWD)                     Yes  0             No  X

b.    Awards, Bonuses, & Incentives (PWTD)                   Yes  X            No  0

 

In FY 2016, the agency identified a trigger involving the percentage of PWTD who received time-off awards.

  1. 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.

a.    Pay Increases (PWD)                                        Yes  X            No  0

b.    Pay Increases (PWTD)                                     Yes  0             No  0

 

In FY 2016, the agency identified a trigger involving the percentage of PWD who receive a quality step increase.

  1. 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.

a.    Other Types of Recognition (PWD)    Yes  0             No  X              N/A 0

b.    Other Types of Recognition (PWTD)  Yes  X            No  0               N/A 0

 

In FY 2016, the agency identified a trigger involving the percentage of PWTD who receive a certificate of recognition.

D. Promotions

  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  X

                        ii.    Internal Selections (PWD)                         Yes  0             No  X

b.    Grade GS-15      

                          i.    Qualified Internal Applicants (PWD)        Yes  X            No  0

                        ii.    Internal Selections (PWD)                         Yes  X            No  0

c.    Grade GS-14

                          i.    Qualified Internal Applicants (PWD)        Yes  X            No  0

                        ii.    Internal Selections (PWD)                         Yes  0             No  X

 

d.    Grade GS-13

                          i.    Qualified Internal Applicants (PWD)        Yes  0             No  X

                        ii.    Internal Selections (PWD)                         Yes  0             No  X

In FY 2017, the percentage of PWD among the qualified internal applicants for grade GS-14 (10.10%) fell below the benchmark.

 

In FY 2017, the percentage of PWD among the selectees for promotion at grade GS-15 (5.67%) fell below the benchmark.

 

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

                          i.     Qualified Internal Applicants (PWTD)                 Yes  0             No  X

                        ii.    Internal Selections (PWTD)                                   Yes  0             No  X

b.    Grade GS-15      

                            i.    Qualified Internal Applicants (PWTD)                Yes  0             No  X

                          ii.    Internal Selections (PWTD)                                  Yes  0             No  X

c.    Grade GS-14

                            i.    Qualified Internal Applicants (PWTD)                Yes  0             No  X

                          ii.    Internal Selections (PWTD)                                  Yes  X            No  0

d.    Grade GS-13

                            i.    Qualified Internal Applicants (PWTD)                Yes  X            No  0

                          ii.    Internal Selections (PWTD)                                  Yes  X            No  0

In FY 2017, the percentage of PWTD among the qualified internal applicants for grade GS-13 (1.10%) fell below the benchmark.

 

In FY 2017, the percentage of PWTD among the selectees for promotion at grade GS-14 (0.75%) fell below the benchmark.

  1. 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.

a.    New Hires to SES (PWD)                                 Yes  0             No  X

b.    New Hires to GS-15 (PWD)                              Yes  0             No  X

c.    New Hires to GS-14 (PWD)                              Yes  X            No  0

d.    New Hires to GS-13 (PWD)                              Yes  X            No  0

In FY 2017, the percentage of PWD among the new hires at grade GS-14 (9.75%) fell below the benchmark.

 

  1. 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.

 

a.    New Hires to SES (PWTD)                               Yes  0             No  X

b.    New Hires to GS-15 (PWTD)                           Yes  0             No  X

c.    New Hires to GS-14 (PWTD)                           Yes  X            No  0

d.    New Hires to GS- 13 (PWTD)                          Yes  0             No  X

In FY 2017, the percentage of PWTD among the new hires at grade GS-14 (0.75%) fell below the benchmark.

 

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

                          i.    Qualified Internal Applicants (PWD)        Yes  X            No  0

                        ii.    Internal Selections (PWD)                         Yes  X            No  0

b.    Supervisors

                          i.    Qualified Internal Applicants (PWD)        Yes  0             No  X

                        ii.    Internal Selections (PWD)                         Yes  0             No  X

 

 

In comparison to the relevant applicant pool (10.25%), triggers exist for PWD among the qualified applicants for promotion to manager (7.62%) and executive (6.45%) positions.

In comparison to the qualified applicant pool, triggers exist for PWD among the selectees for promotions to executive (3.25%) positions.

 

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

                          i.    Qualified Internal Applicants (PWTD)      Yes  X            No  0

                        ii.    Internal Selections (PWTD)                       Yes  X            No  0

b.    Managers

                          i.    Qualified Internal Applicants (PWTD)      Yes  X            No  0

                        ii.    Internal Selections (PWTD)                       Yes  X            No  0

c.    Supervisors

                          i.     Qualified Internal Applicants (PWTD)     Yes  0             No  X

                        ii.     Internal Selections (PWTD)                       Yes  0             No  X

 

In comparison to the relevant applicant pool (1.25%), triggers exist for PWTD among the qualified applicants for promotion to manager (0.62%) and executive (0.45%) positions.

In comparison to the qualified applicant pool, triggers exist for PWTD among the selectees for promotions to executive (0.25%) positions.

 

  1. 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.

a.    New Hires for Executives (PWD)                                Yes  X            No  0

b.    New Hires for Managers (PWD)                                  Yes  0             No  X

c.   New Hires for Supervisors(PWD)                              Yes  0             No  X

 

In comparison to the qualified applicant pool, triggers exist for PWD among the selectees for new hires to executive (3.25%) positions.

  1. 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.

a.    New Hires for Executives (PWTD)                              Yes  X            No  0

b.    New Hires for Managers (PWTD)                               Yes  X            No  0

c.    New Hires for Supervisors (PWTD)                            Yes  0             No  X 

 

In comparison to the qualified applicant pool, triggers exist for PWTD among the selectees for new hires to executive (0.25%) positions.

Section VI: Plan to Improve Retention of Persons 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.

A. Voluntary and Involuntary Separations

  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.

Yes  0             No  X             N/A  0

The agency has not established a system to monitor the status of Schedule A employees with disabilities.  In FY 2017, supervisors did not realize that the two-year deadline expired for 5 Schedule A employees.  The agency plans to implement a tracking system in FY 2018.

  1. 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.

a.    Voluntary Separations (PWD)                                     Yes  0             No  X

b.    Involuntary Separations (PWD)                      Yes  X            No  0  

Using the inclusion rate, triggers exist for PWD (3.53%) who involuntarily separated from the agency, as compared to the rate of persons without disabilities (1.25%).

  1. 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.

a.    Voluntary Separations (PWTD)                       Yes  X            No  0

b.    Involuntary Separations (PWTD)                    Yes  X            No  0

Using the inclusion rate, triggers exist for PWTD (4.27%) who voluntarily separated from the agency, as compared to the rate of persons without disabilities (2.52%).

Using the inclusion rate, triggers exist for PWTD (20.2%) who involuntarily separated from the agency, as compared to the rate of persons without disabilities (0.0%).

  1. 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.

The agency does not have a system to collect exit interview results.  In FY 2017, the Director of Human Resources, in collaboration with the EEO Director, convened a working group to identify a system that would allow the agency to collect and analyze exit interview data. The working group issued a report with recommendations in September 2017 to the Agency Head. The agency plans to implement a system to collect and analyze exit interview data by the second quarter of FY 2018.

 

B. Accessibility of Technology and Facilities

Pursuant to 29 C.F.R. § 1614.203(d)(4), federal agencies are required to inform job 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

 

The agency has not issued a notice of rights pursuant to 29 C.F.R. § 1614.203(d)(4), but the draft notice is in the review process.  The agency plans to post the notice on its public website by March 2018.

 

  1. 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.

 

The agency has not issued a notice of rights pursuant to 29 C.F.R. § 1614.203(d)(4), but the draft notice is in the review process.  The agency plans to post the notice on its public website by March 2018.

  1. 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.

The agency did not implement any projects to improve accessibility of facilities or technology during the reporting period, but the agency plans to lower one sink in each bathroom to accommodate wheelchairs.

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.)

The average processing time for accommodation requests in FY 2017 was 50 days; as compared to the 30-day time frame in its reasonable accommodation procedures. The delay in processing accommodation requests can be attributed to the fact that the agency was unable to backfill the reasonable accommodation program manager position.

  1. 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 FY 2017, the agency developed an online reasonable accommodation portal to reduce the average processing time from 50 days to 30 days. Additionally, the agency established a centralized fund for reasonable accommodations so that the cost of accommodations does not impact individual office budgets.

Starting in FY 2016, the agency requires managers and supervisors to take a three-hour reasonable accommodation training. As a result of managers being more engaged in the interactive process, they were less likely to deny requests, which decreased the number of complaints filed in FY 2017

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, timely providing approved services, conducting training for managers and supervisors, and monitoring PAS requests for trends.

 

In FY 2017, the agency submitted its PAS procedures to the EEOC for approval. Additionally, the agency has implemented its standard operating procedures for approving telework requests under the PAS procedures.

Section VII: EEO Complaint and Findings Data

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?

Yes  0             No  X              N/A  0

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?

Yes  X            No  0               N/A  0

  1. 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.

The agency provided all managers and supervisors with training on the anti-harassment procedures. In addition, the agency modified the performance plan for managers and supervisors to include an EEO element, which addresses the implementation of the anti-harassment procedures.

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?

Yes  0             No  0               N/A  X

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?

Yes  X                        No  0               N/A  0

  1. 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.

 

The agency provided all managers and supervisors with reasonable accommodation and sensitivity training. In addition, the agency modified the performance plan for managers and supervisors to include an EEO element, which addresses the implementation of the reasonable accommodation procedures.

Section VIII: 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.

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

Yes  X            No  0

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

Yes  X            No  0               N/A  0

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.

 

Trigger 1

The lower than expected participation rate (0.23%) of persons with targeted disabilities (PWTD) in the agency’s total workforce, as compared to the goal of 2%.

Barrier(s)

An ineffective reasonable accommodation program, involving the untimely processing of requests, has resulted in PWTD leaving the agency

Objective(s)

Improve the timeliness of its response to accommodation requests

Responsible Official(s)

Performance Standards Address the Plan?

(Yes or No)

Stephanie Hernandez, Director of Diversity and Inclusion Programs, Office of Civil Rights

Yes

Target Date

(mm/dd/yyyy)

Planned Activities

Sufficient Staffing & Funding

(Yes or No)

Modified Date

(mm/dd/yyyy)

Completion Date

(mm/dd/yyyy)

9/30/2017

Establish a tracking system for reasonable accommodation program.

Yes

 

7/28/2017

1/30/2018

Backfill the GS-14 accommodation program manager position which has been vacant since the previous RA program manager retired.

Yes

 

 

7/31/2018

Revise reasonable accommodation procedures to shorten the time frames for deciding requests.

Yes

 

 

Fiscal Year

Accomplishments

2017

The agency implemented a new tracking system to ensure that the reasonable accommodation program timely issues decisions on requests.

 

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

 

Although the responsible official’s performance standards contain an EEO element, the rating official did not address the untimely planned activities in Plan J-2 during FY 2016.  The EEO Director and Chief Human Capital Officer plan to provide a refresher course for the management team in FY 2017 concerning the requirement to rate responsible management officials on their implementation of the Affirmative Action Plan.  Starting in October 2017, the EEO Director also plans to provide feedback to the rating officials on the status of Affirmative Action Plans at the end of each fiscal year.

 

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

 

The agency has not had sufficient time to assess the impact of the planned activities.

 

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.

 

After implementing the plan six months ago, the planned activities have not impacted the trigger.  The agency plans to monitor the progress of the plan for another six months before modifying the plan.