DEPARTMENT OF THE NAVY
CIVILIAN HUMAN RESOURCES MANUALSUBCHAPTER 1604
GUIDE FOR CONDUCTING AN EFFECTIVE BARRIER ANALYSISTABLE OF CONTENTS

Sections
1.
2.
3.
4.
5.
6.

BackgroundPurpose
PolicyResponsibilities
ActionBarrier Analysis Manual Table of Contents¬ Section 1 – Data Collection¬ Section 2 – Data and Trend Analyses¬ Section 3 – Barrier Identification¬ Section 4 – Responsibility To Continually
Assess and Monitor EEO Plans¬ Section 5 – The Role/Responsibilities of Special
Emphasis Program (SEP) Managers
In Barrier Analysis¬ Appendix A Definitions

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DEPARTMENT OF THE NAVY
EQUAL EMPLOYMENT OPPORTUNITY GUIDE FOR CONDUCTING AN
EFFECTIVE BARRIER ANALYSISSUBCHAPTER 1604

References:

1.

(a) Equal Employment Opportunity Commission (EEOC) Management
Directive (MD 715)(b) Civilian Human Resources Manual, Subchapter 1603, Equal
Employment Opportunity Program Assessment(c) 29 Code of Federal Regulations § 1614.101 and 1614.102(d) Office of the Secretary of Defense Administrative Instruction No. 31(e) Department of Defense (DoD) Directive 1440.1

Background:a. Reference (a) establishes the ongoing obligation for agencies to conduct anannual assessment of their EEO programs. There are two aspects of an EEO Programthat must be addressed during a self assessment.
(1) The first element is a self-assessment of the command’s/activity’s EEO
program measured against the six essential elements of a model EEO program using the
EEOC Agency Self-Assessment Checklist provided in reference (a).
(2) The second element of the self-assessment process is a snapshot of thestatus of command/activity efforts to identify and eliminate any barriers to EEO. Barrier
identification and elimination is the process by which commands/activities uncover,examine and remove barriers to equal participation at all levels of the workforce. A
barrier is an agency policy, principle or practice that limits or tends to limit employment
opportunities for members of a particular sex, race, or ethnic background, or based on an
individual’s disability status.
(a) Reference (a) provides 28 Workforce Data Tables to assist
commands/activities in the examination of their workforce racial, national origin, genderand disability profiles, the first step of the barrier analysis process. EEOC guidance andinformation about the EEOC Workforce Data Tables and copies of blank table forms may
be found at http://www.eeoc.gov/federal/715instruct/datatables.html andhttp://www.eeoc.gov/federal/715instruct/tables.html, respectively(b) Reference (a) also provides guidance and a specific format, i.e.,
EEOC Form 715-01 PART I, for command/activities to document their barrier analysis
efforts and plans to eliminate any identified barriers.

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b. DON specific requirements for accomplishing, documenting and reporting
barrier analysis efforts are provided in reference (b).

2.

Purpose:a. To provide DON specific guidance and requirements to individuals responsiblefor implementing, coordinating and conducting command and/or activity barrier analysis
efforts to identify and eliminate any impediments to equality of opportunity in theworkplace. All commands/activities are required to work proactively to ensure equal
employment opportunity (EEO) for all DON employees and applicants for employment
to prevent potential discrimination before it occurs and to establish systems to monitor
our compliance with the requirements of Title VII of the Civil Rights Act of 1964, as
amended, and Section 501 of the Rehabilitation Act. All commands/activities must
regularly evaluate their employment practices to identify barriers to equality ofopportunity for all individuals. Where such barriers are identified, commands/activities
must take measures to eliminate them. Only through these efforts will it be ensured that
all individuals are provided opportunities to participate in the full range of employment
opportunities and achieve their fullest potential.
b. This subchapter is intended to augment the information provided in references(a) and (b) and sets forth DON policy and requirements for barrier analysis efforts.
3.

Policy:a. In accordance with references (a) through (c), all DON employees will work
towards the goal of creating an inclusive work environment where qualified applicantsand employees have the freedom and opportunity to compete and participate in all
applicable employment processes, e.g., recruitment, employment, promotion, training,
awards, etc.
b. In order to achieve this goal, focused, methodical and on-going efforts to
identify and eliminate any barriers to equality of opportunity must be developed andimplemented at all levels of the DON.
c. Each command and activity will designate a senior management official(s)who will be responsible for: implementing and executing barrier analysis efforts that are
ongoing; accomplishing these efforts in accordance with the requirements of reference (a)and this CHRM; working collaboratively with their EEO offices/servicing offices andother relevant stakeholders; and, achieving the goal of the identification and eliminationof any barriers to equality of opportunity.
d. Per reference (a), agencies have an on-going obligation to eliminate barriers
that impede free and open competition in the workplace and prevent individuals of any
racial, national origin group, either sex, or individuals with a disability from realizing
their full potential. As part of this on-going obligation, all DON commands/activities

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must conduct a self assessment on at least an annual basis to monitor progress and their
ongoing efforts towards identifying and eliminating any barriers that exclude certain
groups.
4.

Responsibilities:

a. In accordance with references (a) through (c), the Secretary of the Navy(SECNAV) is responsible for communicating and demonstrating a commitment toequality of opportunity for all employees and applicants for employment.
b. The Assistant Secretary of the Navy (ASN) (Manpower and Reserve Affairs(M&RA)), as EEO Director, is responsible for establishing and maintaining a DON-wide
EEO Program that is compliant with EEOC MD-715, implementing instructions from
EEOC and DoD guidance.
c. The Deputy Assistant Secretary of the Navy (DASN) (Civilian Human
Resources (CHR)) is delegated the responsibility for developing DON-wide policies,
programs and directives to ensure successful accomplishment of all aspects of the EEO
Program to include the identification and elimination of any barriers to equality ofopportunity. The DASN (CHR) has the authority to further delegate these
responsibilities to enforce compliance with this instruction.
d. The Director, Office of Civilian Human Resources (OCHR), is responsible for:(1) Ensuring that EEO professionals are involved with and consulted on
the management and deployment of human resources.
(2) Attracting, developing and retaining EEO professionals with thestrategic competencies necessary to accomplish the agency’s EEO mission, and interface
with agency officials, managers and employees.
e. The Program Director, Office of EEO and Diversity Management is
responsible for:(1) Establishing and disseminating DON policy for barrier analysis efforts.
(2) Providing advice and guidance to DON officials who are responsible
for the identification and elimination of barriers to equality of opportunity.
(3) Developing and submitting the agency’s Annual EEO Program Status
Report to EEOC and DoD.
f. The Chief of Naval Operations, Commandant of the Marine Corps, Assistantfor Administration USN, and Heads of Echelon 2 Commands are designated as
Command EEO Officers (CEEOO). As such, they are responsible for:

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(1) Communicating and demonstrating their commitment to equality ofopportunity for all employees and applicants for employment.
(2) Ensuring that adequate resources are allocated to effectively achieveand sustain a model EEO program.
(3) Designating a senior level manager(s) to execute and coordinate all
barrier analysis efforts with the command’s EEO office.
(4) Ensuring that officials responsible for barrier identification andelimination are trained on program requirements.
(5) Ensuring that EEO professionals are involved with and consulted on
the management and deployment of human resources.
(6) Attracting, developing and retaining EEO professionals with thestrategic competencies necessary to accomplish the agency’s EEO mission, and interface
with agency officials, managers and employees.
g. The Command Deputy EEO Officer (CDEEOO) is responsible for:(1) Serving as the primary advisor to the CEEOO on the command’s
process for barrier analysis.
(2) Working collaboratively with senior level manager(s) responsible forthe command’s barrier analysis efforts.
(3) Providing guidance, assistance, and command specific training on
barrier analysis to subordinate command/activity officials.

(4) Serving as a link between subordinate activities and OCHR and the
DON EEO Program Manager to monitor and enforce compliance with this subchapter.
(5) Reviewing the Annual EEO Program Status Report submission of all
subordinate activities/commands to ensure compliance with this subchapter.
(6) Developing and submitting the command’s Annual EEO Program
Status Report to DON.
h. The Director, Civilian Policy and Procedures (DCPP) is responsible for:(1) Ensuring that sufficient resources are allocated to execute effective
analysis efforts at the command and subordinate activity levels.

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(2) Ensuring that EEO professionals are involved with and consulted on
the management and deployment of human resources.
(3) Attracting, developing and retaining EEO professionals with thestrategic competencies necessary to accomplish the agency’s EEO mission, and interface
with agency officials, managers and employees.
i. The Activity Commander or Head serves as the EEOO and is responsible for:(1) Communicating and demonstrating their commitment to equality ofopportunity for all employees and applicants for employment.
(2) Designating a senior level manager(s) to execute and coordinate all
barrier analysis efforts with the activity’s EEO office or servicing office.
(3) Ensuring that officials responsible for barrier identification andelimination are trained on program requirements.
(4) Ensuring that EEO professionals are involved with and consulted on
the management and deployment of human resources.
(5) Attracting, developing and retaining EEO professionals with thestrategic competencies necessary to accomplish the agency’s EEO mission, and interface
with agency officials, managers and employees.
(6) Evaluating managers and supervisors on efforts to ensure equality ofopportunity for all employees.
j. The servicing Deputy EEO Officer (DEEOO) is responsible for:(1) Serving as the primary advisor to the EEOO on the activity’s process
for conducting regular internal audits, on at least an annual basis, to assess whether theactivity has made a good faith effort to identify and eliminate barriers to equality ofopportunity.
(2) Working collaboratively with senior level manager(s) responsible forthe activity’s barrier analysis efforts.
(3) Providing guidance, assistance, and training on barrier identificationand elimination to individuals responsible for developing, coordinating and implementing
the activity’s barrier analysis efforts.
(4) Ensuring that barrier analysis efforts continue on an ongoing basis andinvolving appropriate stakeholders in this process.

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(5) Annually developing objectives and action items as a result of barrier
analysis efforts and submitting the activity’s Annual EEO Program Status Report to themajor command.
k. The Human Resources Director (HRD) is responsible for:(1) Ensuring that sufficient resources are allocated to execute effective
barrier identification and elimination efforts for serviced commands/activities.
(2) Ensuring that EEO professionals are involved with and consulted on
the management and deployment of human resources.
(3) Attracting, developing and retaining EEO professionals with thestrategic competencies necessary to accomplish the agency’s EEO mission, and interface
with agency officials, managers and employees.
l. Human Resources (HR) Specialists are responsible for becoming
knowledgeable on and participating in, as needed, the activity’s barrier analysis efforts.
m. Special Emphasis Program (SEP) Managers are responsible for enhancing theemployment, training, and advancement of minority groups, women and/or individuals
with disabilities by assisting, supporting and participating in the activity’s barrier analysis
efforts.
n. The Human Resources Service Center (HRSC) is responsible for supporting
the barrier analysis efforts of their serviced commands/activities as requested.
o. Managers and supervisors are responsible for:
(1) Assisting, supporting and participating in the activity’s barrier analysis
efforts.
(2) Maintaining clearly defined, well-communicated, consistently appliedand fairly implemented personnel policies, selection and promotion procedures,
evaluation procedures, rules of conduct and training systems.
p. Employees and/or other stakeholders are responsible for assisting, supportingand participating in the activity’s barrier analysis efforts.
5.
Action: All DON components will comply with the requirements of thisSubchapter.

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BARRIER ANALYSIS MANUALSUBCHAPTER 1604
TABLE OF CONTENTSPAGE

SECTION 1 – DATA COLLECTION
I.

II.

Collecting the Data
A. The Importance of Collecting Accurate Data
B. Data Categories
C. Tracking and Monitoring Systems

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Data Organization

Attachment 1 – Excerpt from EEOC MD-715, Section II, Analyzing
Employment Processes

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SECTION 2 – DATA AND TREND ANALYSES
I.

II.

III.

Data Analysis
A. Purpose
B. Triggers
C. How to Analyze the Data
Trend Analysis
A. Baseline for Future Analysis
B. Monitoring Employment Processes for the
Identification of Triggers
Analysis Procedures

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SECTION 3 – BARRIER IDENTIFICATIONI.

II.

How to Identify a Potential Barrier
A. What to do with Information Uncovered at theData analysis Step
B. Utilize all Available Data
Documentation of an Identified Barrier
A. Documentation of Barrier Analysis Efforts
B. EEOC Form 715-01, Part I, EEO Plan to

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Eliminate Identified Barrier
SECTION 4 – CONTINUOUS ASSESSMENT AND MONITORINGOF EEO PLANS
I.

II.

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After the Submittal of EEO Plans (Part I)
A. Required Actions
B. DON EEO Plans to Eliminate Identified Barriers

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Purpose of EEO Plans

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SECTION 5 – THE ROLE/RESPONSIBILITIES OF SPECIAL EMPHASISPROGRAM (SEP) MANAGERS IN BARRIER ANALYSIS
I.

II.

SEPs
A. Definition of SEP
B. Authorized SEPs

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Responsibilities of SEP Managers
A. Program Management
B. Program Responsibilities
C. Role/Responsibilities of SEP Manager in Barrier Analysis

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APPENDIX:
A. Definitions

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BARRIER ANALYSIS MANUALSECTION 1
DATA COLLECTION
I. COLLECTING THE DATA
A. The Importance of Collecting Accurate Data: Data is the foundation for
executing an accurate, relevant, sound, and complete analysis that will meet the intent ofgoverning laws/regulations by ensuring that we are providing the maximum opportunity
for all employees to advance and to perform at their highest potential. The datacollection step can be one of the most time-consuming portions of the analysis process.
Therefore, in most instances, it is not advisable to initiate efforts to collect data at the
point the command/activity is ready to commence an analysis or at the end of thereporting period. Focused, pre-planned efforts to collect relevant data on an ongoingbasis are critical to the effective execution of the next steps in the barrier analysis
process. Note: The workforce data tables that are submitted at the end of each fiscal year,
i.e., 30 September, are merely a snapshot of the workforce at that point in time andshould not be used for initiating barrier analysis efforts that should have been executedduring the relevant reporting period.
B. Data Categories
l. EEOC MD-715 Workforce Data Tables: The first step of the barrier analysis
process is to look at the workforce racial, national origin, gender and disability profiles.
To assist the commands/activities in this first step, EEOC developed 28 Workforce Data
Tables. Completion of the workforce data tables will assist the command/activities intheir review of the workforce, as generally compared to appropriate comparators, toidentify possible triggers. While the EEOC Workforce Data Tables are merely one
source of data to be reviewed in this process, if completed properly, they will identify
triggers to be explored. A trigger is a situation or a ‘red flag’ that indicates the possible
existence of a barrier to equal opportunity. As the command/activity performs its reviewof their completed Workforce Data Tables, a trigger for a potential barrier will typicallymanifest itself through the identification of low participation rates of a particular groupwhen compared to the Relevant Civilian Labor Force (RCLF). Guidance for completingthe EEOC Workforce Data Tables and copies of blank table forms may be found at
http://www.eeoc.gov/federal/715instruct/datatables.html andhttp://www.eeoc.gov/federal/715instruct/tables.html respectively. These workforce datatables are a basic starting point for collecting personnel data to initiate thecommand/activity barrier analysis efforts. It must be emphasized that the merecompletion of the workforce data tables is not the desired end result. Rather it is theinformation that is revealed in these tables that results in the initiation of the more
important process of barrier identification and elimination.

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a. The DON currently has the DON Affirmative Employment Reporting
Tool (DART), an automated tool that provides some of the data required to populate theWorkforce Data Tables. In the future it is anticipated that other automated tools will be
developed and/or will become available to obtain this data. Command and/or activity
level personnel may also develop additional automated tools to augment the capability
provided by DART, depending upon local accessibility and resources.
b. Personnel data is obtained from the Defense Civilian Personnel Data
System (DCPDS). DCPDS is a “live” reporting system, which means that every action
entered into DCPDS is reported, e.g., if an accession requires a correction to the originalaction, DCPDS will record this one accession as two accessions – the original accession
and the correction. Therefore, it is recommended that command/activity level personnel“clean-up” the data, when possible, before beginning analysis.
c. As indicated above, the data submission requirements of MD-715 aremerely a starting point for data collection. Additional data will usually be required inorder to conduct a more in-depth analysis. For example, in order to conduct a more indepth analysis of new hires, data such as: types of series, grade levels, identifying the
sub-units within the organization that has the majority of the new hires, Nature of Action
Code, etc., are necessary. The following examples illustrate how obtaining additional
relevant information may result in the ability to more specifically identify potential
barriers and the development of meaningful objectives:(1) If the data reviewed indicates that the majority of a command’s
and/or activity’s accessions are in a specific series and a further examination reveals thatthe relevant applicant pool is not sufficiently diverse, an appropriate objective may be tofocus future recruitment efforts so that they will result in a diverse pool of candidates
who are qualified for that particular series. An objective that identifies a broad, nonseries specific recruitment effort to attract a diverse pool of candidates may not eliminate
this identified problem.
(2) If the data collected indicates that the majority of a command
and/or activity’s accessions are at the journey level and further examination reveals thatthe applicant pool for journey level positions is not sufficiently diverse, an appropriate
objective may be to consider entry level hires vice only at the journey level.
(3) If the data collected indicates that the majority of a command
and/or activity’s accessions are from a specific sub-unit of the organization, an
appropriate objective may be to examine the selection process for that particular segmentof the organization to determine if there are any barriers to EEO in their selection
policies, practices or procedures.
(4) If the data collected indicates that the majority of a command
and/or activity’s accessions are hired through the use of CHART, an appropriate
objective might be to explore the use of different hiring authorities potentially resulting ina more diverse applicant pool.

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2. Employment Processes: Barriers to equal opportunity will typicallyarise in the different employment processes. Therefore, as a required part of their barrier
analysis efforts, commands/activities must include an examination of their program,policies and procedures for following processes:• Recruitment• Hiring and Placement• Employee Development and Training Opportunities• Promotions and Other Internal Selections• Award Distribution• Discipline• Separations
a. Reference (a) includes a list of questions that will be helpful to thecommand/activity during its thorough investigation into each process. A copy of thesequestions is provided as Attachment 1. Due to the scope of these examinations, theseprocesses should be reviewed during the course of the reporting period, not at the end, todetermine the existence of any possible barriers.
b. The results of an investigation into these processes may assist thecommand/activity in further pinpointing any potential barriers. Documentation of theoutcome of a command/activity’s investigation into these processes should be maintainedin the working file for each annual assessment reporting period.
c. It may not be feasible to examine each employment process on an annual
basis. In this event, a schedule and timetable to review each employment process should
be developed and implemented. Information regarding the schedule and timetable should
be included in the command/activity’s annual assessment report.
d. Command/activities should address all employment processes that are
relevant to current issues within their organization. For example, if an activity is
downsizing its workforce, an examination of its procedures for the Voluntary Separation
Incentive Program/Voluntary Early Retirement Authority (VSIP/VERA) may beappropriate.
e. Other employment processes that may be considered for examination
include, but are not limited to:• Performance rating procedures• Advertisement and selection for reassignment opportunities• Honorary awards• Comparison of pay rates between males/females performing
substantially similar work
• Pay distribution in a pay for performance system (i.e., NSPS,
Demonstration Projects)• Command/activity level career development programs

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3. Other Relevant Data: Additional data that should be considered as part of thebarrier analysis may include, but is not limited to:a. Discrimination complaint activity (formals, informals, contacts)
b. More detailed information on accessions, promotions and separations, i.e.,name of employee, organizational code, pay plan, series, grade, gender, Ethnicity andRace Indicator (ERI) code, handicap code, EEOC job category, nature of action
description, nature of action code, authority code, entry date, effective date, veterans’
preference (NOTE: this information is covered under the provisions of the Privacy Act
and must be safeguarded and used for official use only)c. Organizational environment, e.g., hiring freeze, BRAC activity, downsizing
efforts, fiscal constraints, increased hiring efforts, etc.
d. Exit survey resultse. Input from Special Emphasis groups
f. Input from union officials
g. Input from employees, to include supervisors and managers
h. Input from Human Resources practitioners
i. Government reports, e.g., EEOC, GAO, OPM, MSPB, DOL
j. Reports and/or studies in local and national news periodicals
4. Collecting information from stakeholders: In order to perform an
accurate and relevant analysis, various stakeholders, e.g., supervisors/managers,
employees, Special Emphasis groups/committees, union officials, counsel, humanresources, financial, IT, etc. should be involved in the process when applicable. These
individuals may be able to provide critical information that should be considered in theanalysis, e.g., organizational environment, budget forecast, human capital plan, humanresources employment processes expertise, business practices/policies/procedures,
employee concerns/issues, etc.
a. The information provided by stakeholders is not only invaluable, but serves
as an opportunity to involve individuals critical to the successful implementation of
barrier elimination plans.
b. Some of the positive outcomes of successfully integrating stakeholders into
the barrier analysis process include:• Ownership of the barrier analysis process by individuals external
to the EEO Office;• Additional sources of information for the identification of potential
triggers or barriers to EEO;
• Acquired knowledge and a heightened awareness that will ensure
equality of opportunity is carefully considered and integrated into
the process during the development/revision of employment
practices, policies and procedures;• The creation of an inclusive work environment that provides equal
employment opportunity to all employees with the anticipatedpositive outcome of fewer filings of discrimination complaints.

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C. Tracking and Monitoring Systems: Some of the data needed to conduct athorough analysis must be collected over a period of time and may be quite voluminous.
Examples of this type of information include, but are not limited to:• Applicant flow data for recruitments and selections• Applicant flow data for career development programs andselections• Disciplinary actions• Exit surveys• Climate survey results• Performance evaluation data
• Pay comparisons (in pay for performance systems)
Due to the volume of this data, it is strongly recommended that tracking and monitoring
systems, preferably automated, be developed as a means to efficiently collect the data.
Access to these systems should be strictly limited and the information, e.g., ERI code,
handicap code, names, performance ratings, etc., be safeguarded in accordance with theprovisions of the Privacy Act. Prior to making a determination that the development of a
tracking/monitoring system is needed, EEO practitioners should verify that an existing
system is not already in place at the command or DON levels.
II. DATA ORGANIZATION All the data collected through various sources should beassembled and organized so that all the relevant information is available for the next stepin the analysis process, i.e., data and trend analyses. Section II provides information on
the data and trend analyses steps of the barrier analysis process.

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Excerpt from EEOC MD-715, Section II
Analyzing Employment Processes
The following is a list of employment processes where barriers typically arise, followed bya list of questions to be answered during a thorough investigation into each process.
Agencies should consider this list a minimum starting point and feel free to add to the listof processes and questions, as the need arises.

Recruitment (See Tables A1, B1, A2, B2, A7, B7, A8, B8)
1. What opportunities are anticipated for external/internal hiring for the agency?
2. What criteria are considered in the development of the agency recruitment plan?
With respect to the agency's SES candidacy program and/or succession planning,
what criteria are considered?
3. Are disabilities, and targeted disabilities in particular, considered in the plan? If
yes, how?
4. What is the applicant rate of persons with disabilities, including individuals withtargeted disabilities? Are applications being received at the expected rate?
5. Do present recruitment sources yield the expected rate of qualified applicants of
all racial and national origin groups, and both sexes, who meet organizational
needs?
6. When were qualification requirements last examined to determine whether they
are still current and necessary?
7. Does recruitment literature reflect the agency's desire to reach all segments ofthe potential workforce? How so?
8. Do/did EEO officials participate in the development of the recruitment plan?
9. Do/did EEO officials provide technical assistance to the personnel office andmonitor recruitment efforts?
10. When paid advertising is used for recruitment or institutional purposes, is a wide
variety of media with diverse readership included?
11. Does management make itself available to community, civic, and other groupsinterested in enhancing equal employment opportunity? If yes, how?
12. Does the agency provide opportunities and services to the community such as
cooperative education programs and shared use of training facilities?
13. Does the agency participate in community career information programs,
conferences, and occupational study projects? Provide examples.
14. Has the agency examined means for expanding worker-trainee placement?
ATTACHMENT 1

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15. Do current plans call for maximum participation in the worker-trainee
opportunities program, or other such programs, with particular emphasis on theidentification of developmental positions?
16. By what methods are applicants invited to apply? If the agency uses an on-line
application product, does it comply with the Rehabilitation Act? Was the productreviewed by both the agency's information technology office for technicalsufficiency and the agency's legal counsel for legal sufficiency? When?

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Hiring and Placement (See Tables A3, B3, A4, B4, A5, B5, A6, B6, A, B7, A8, B8)
1. Are workforce participation rates substantially similar to those rates in therelevant civilian labor force (RCLF)?
2. Where there are variations, in what specific area(s) is the variation occurring(e.g., particular job category, particular grade, particular installation, etc.)?
3. What feeder groups affect the categories identified above? Are those feeder
groups substantially similar to the RCLF benchmark? If not, determine where thedisparity is occurring. If yes, determine whether a disparity appears between
feeder group population and next category.
4. Is the selection process reviewed periodically to ensure equal treatment
regardless of race, sex, national origin, disability or EEO participation?
5. Are selection panels used? If so, how is it determined who will serve on thepanels?
6. Is the EEO office consulted when it is determined who will serve on a selection
panel? Is the EEO office consulted with respect to selections for SES candidacy
programs and succession planning?
7. Are selection requirements and procedures job-related and consistent withbusiness necessity? Do they include unnecessary barriers to full utilization of
population? If barriers are job-related and consistent with business necessity, canthe effect of the barrier be nonetheless minimized ?
8. Are there a substantial number of EEO complaints where non-selection(s) is
identified as the issue? If yes, is there an identifiable trend (e.g., particular group,
supervisor, or installation)? What can be done to address this trend (e.g., train
selecting officials, train employees, improve communication of the selection
criteria or the application process)?
9. Has the union, the ombudsman, an employee advocacy group, special emphasis
group, or any other interested stake holder group expressed concern regarding
recent selections? If yes, what were the specific concerns raised and what is theagency's response and plan of action?

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Employee Development and Training Opportunities (See Tables A12, B12)
1. What developmental opportunities were made available during the last fiscal year
(i.e., training, details, etc.)? Which of these opportunities provided competency
experience required for advancement to the SES level?
2. What is the workforce distribution of the participants for identified opportunities
for the last fiscal year (grade, occupation, installation, race, sex, national origin,disability)?
3. Were the opportunities provided in the last fiscal year balanced across all parts of
the workforce? If not, which group(s) were less utilized than others, and why?
4. How are participants for identified opportunities selected?
5. Is the selection process reviewed periodically to ensure equal treatment
regardless of race, sex, national origin or disability?
6. How are training/developmental opportunity selection panels comprised, if at all?
7. Is EEO consulted when training/developmental opportunity selection panels arecomposed?
8. Are systems for tracking information on employee skills and training in operation?
9. Has a survey of current skills and training of the agency's workforce been
conducted to determine the availability of employees from the entire workforce
that have skills required to meet agency mission needs?
10. Are efforts being made to ensure that appropriate training and otherdevelopmental opportunities are available to employees at all grade levels,
including management and executive training, and in all occupational areas,
without regard to race, national origin, sex or disability?
11. Are internal selection requirements and procedures for developmental
opportunities job-related and consistent with business necessity? Do they include
unnecessary barriers to full utilization of skills and training? If barriers are jobrelated and consistent with business necessity, can the effect of the barrier beminimized?
12. Are there a substantial number of EEO complaints wherein developmental
opportunities, such as denial of training or non-selection for a detail, is identified
as the issue? If yes, is there an identifiable trend e.g., particular group,
supervisor, or installation? What can be done to address this trend (objective
criteria, better communication of process and expectations)?
13. Has the union, the ombudsman, an employee advocacy group, special emphasis
group, or any other interested stake holder expressed concern regarding the
distribution of opportunities? If yes, what were the specific concerns raised andwhat is the agency's response and plan of action?

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Promotions and Other Internal Selections (See Tables A9, B9, A10, B10, A11,
B11B)
1. Of the promotions that occurred in the last fiscal year, were the selections
reflective of the pool of eligible candidates? Also, if the pool of eligible candidates
did not include representatives from particular groups, was consideration given to
including external candidates?
2. Where there are variations, in what specific area(s) are the variations occurring(e.g., particular job category, particular grade, particular installation, etc.)?
3. Are variations occurring in management, executive or SES selections? Are suchselections meeting the needs of the agency's succession plans?
4. What feeder groups were available for each identified promotion? Are thosefeeder groups substantially similar to the RCLF benchmark? If not, determine
where the disparity is occurring (e.g., recruitment, selection, promotion, etc.). If
yes, determine why the disparity appears between feeder group population andpromotion selectees.
5. Is the promotion/selection process reviewed periodically to ensure equal
treatment regardless of race, sex, national origin, or disability?
6. For career-ladder promotions, is there a difference in time with which one or moregroups achieve their full grade potential as compared to other groups (i.e., is thetime-in-grade higher for a particular group)?
7. Are employees achieving full performance for their occupation at similar rates
with others of different race, national origin, sex or disability?
8. How are promotion selection panels composed when they are used?
9. Is EEO consulted when selection panels are composed?
10. Are internal promotion qualification requirements and procedures job-related andconsistent with business necessity? Do they include unnecessary barriers to full
utilization of skills and training? If barriers are job-related and consistent withbusiness necessity, can the effect of the barrier be minimized nonetheless?
11. Are there a number of EEO complaints where non-promotion is identified as theissue? If yes, is there an identifiable trend (e.g., particular group, supervisor, or
installation)? What can be done to address this trend (train selecting officials,
train employees, better communication of process and expectations)?

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Award Distribution (See Table A13, B13)
1. What is the workforce distribution of award recipients for the last fiscal year
(grade, occupation, installation, race, sex, national origin, disability, etc.)?
2. Of the awards given in the last fiscal year, was the rate of success substantiallysimilar for all parts of the population? If not, which group(s) enjoyed less successthan others, and why?
3. How are award recipients selected? Are there objective criteria available forselecting officials?
4. Is the awards selection process reviewed periodically to ensure equal treatment
regardless of race, religion, sex, national origin, disability or EEO participation?
5. Are award selection panels utilized and, if so, how is it determined who will serve
on a panel?
6. Is EEO consulted when award selection panels are composed?
7. Are there a substantial number of EEO complaints where award non-selection is
identified as the issue? If yes, is there an identifiable trend (e.g., particular group,
supervisor, or installation)? What can be done to address this trend (objective
criteria, better communication of process and expectations)?
8. Has the union, the ombudsman, an employee advocacy group, special emphasis
group, or any other interested stakeholder expressed concern regarding the
distribution of awards? If yes, what were the specific concerns raised and what is
the agency's response?

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Discipline (See Table A14, B14)
1. What is the workforce distribution of discipline, including removal, during the last
fiscal year (grade, occupation, installation, race, sex, national origin, disability,
EEO participation, types of discipline, etc.)?
2. Of the disciplinary actions based on conduct taken in the last fiscal year, was therate of receipt substantially similar for all parts of the population? If not, whichgroup(s) received more or harsher discipline than the others, and why?
3. Of the disciplinary actions based on performance taken in the last fiscal year, wasthe rate of such actions substantially similar for all parts of the population? If not,which group(s) received more or harsher discipline than the others, and why?
4. Where there is a difference in rates based on conduct, does the difference occur
at the proposal stage, the implementation stage, or in both (i.e., was one group
recommended for disciplinary action at a higher rate than all other groups; is thatgroup's conduct subjected to a higher level of scrutiny; do others engage insimilar misconduct without having disciplinary actions proposed or taken againstthem)?
5. Where there is a difference in rates based on performance, does the difference
occur at the proposal stage, the implementation stage, or in both (i.e., did theindividuals in the group with higher occurrence rates receive sufficient training,assignments, and supervisory assistance; were they given opportunities toimprove compared to opportunities given to other employees; what information
can be gleaned from prior performance appraisals; were the recommending
decision/performance appraisals based on predetermined objective criteria and/or
were they were highly subjective; was the affected group held to a higher
standard of demonstrated performance than other employees and/or subjected tostricter scrutiny of their work; did performance appraisal and/or recommendation
narratives disclose that recommending and/or rating official held stereotyped orotherwise negative views of the affected group)?
6. How are disciplinary actions determined?
7. Are there objective criteria used (i.e., table of offenses with corresponding
appropriate discipline)? If disciplinary decisions (type and timing) are left to thediscretion of individual supervisors, why?
8. Is the disciplinary table of offenses reviewed periodically to ensure equal
treatment regardless of race, religion, sex, national origin, disability or EEO
participation (i.e., is there something that typically occurs only at one installation,such that disciplinary action for this issue will have a particularly negative effecton one group)?
9. Is the EEO office consulted when developing or modifying the table of offenses?
10. Are there a substantial number of EEO complaints where discipline, including
removal, is identified as the issue? If yes, is there an identifiable trend (i.e.,
particular group, supervisor, or installation)? What can be done to address thistrend (objective criteria, better communication of process and expectations)?

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11. Has the union, the ombudsman, an employee advocacy group, special emphasis
group, or any other interested stake holder expressed concern regarding the rateof discipline for a particular group? If yes, what were the specific concerns raised
and what is the agency's response?

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Separations (See Tables A14, B14)
1. What is the workforce distribution of separations, including disability retirement,
for the last fiscal year (grade, occupation, installation, race, sex, national origin,disability, EEO participation, etc.)?
2. Did a higher percentage of a particular group separate from the agency, or from aparticular installation?
3. Were exit interviews conducted? If not, why not? If yes, were any trends
identified (e.g., leaving: because of harassment, perceived barriers toadvancement for certain groups, for more money, because of atmosphere ofagency, because of particular supervisor, for personal reasons, etc.)?
4. Where a trend emerges in the above analysis, what is the agency's response toaddress the issue now, as well as prevent it from occurring in the future?
5. Are efforts made to ensure that separations are conducted fairly and in a nondiscriminatory manner? If yes, what are those efforts?
6. Are reductions-in-force conducted in a non-discriminatory manner? What
procedures are in place to ensure this?
7. Are there a substantial number of EEO complaints where constructive discharge isidentified as the issue? If yes, is there an identifiable trend (i.e., particular group,
supervisor, or installation)? What can be done to address this trend(implementation of EEO policies, managers held accountable for implementing
policies, etc.)?
8. Has the union, the ombudsman, an employee advocacy group, special emphasis
group, or any other interested stake holder expressed concern regarding the rateof separations for a particular group? If yes, what were the specific concerns
raised and what is the agency's response?

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BARRIER ANALYSIS MANUALSECTION 2
DATA AND TREND ANALYSES
I. DATA ANALYSIS
A. Purpose: It is important to remember that the end product of collecting, tracking
and monitoring the data outlined in Section 1 is not merely to produce a report of thesenumbers. Rather, the end result of any data analysis is to gather enough information to
identify problem areas that may indicate the existence of potential barriers to EEO. Keepin mind that the problem areas identified by an analysis of the data are NOT the barriers
to equality of opportunity, but are a symptom of a problem that needs to be addressed.
B. Triggers: Triggers are problem areas that may indicate the existence of a potential
barrier to EEO and could be identified by a variety of different methods, e.g., the analysisof data, examination of employment processes, discrimination complaint activity andtrends, etc. Triggers serve a red flag that a particular employment process should be
investigated further to determine whether or not a barrier exists. Some examples oftriggers include:• Low participation rates for a particular group(s)• Information revealed as a result of an investigation into an employment
process(es), e.g., a particular group(s) is separating from the organization
at a significantly higher rate in comparison to their representation rate in
the workforce.
• Input from Special Emphasis groups• Input from union officials, e.g., a high number of grievances have been
filed that raise issues about selection procedures.
• Input from employees, to include supervisors and managers• Input from Human Resources practitioners• Government reports, e.g., EEOC, GAO, OPM, MSPB, DOL• Reports in local and national news periodicals• Applicant flow information• Discrimination complaints trends
The identification of a potential problem should prompt an investigation into why asituation exists and the initiation of efforts to pinpoint the actual barrier.
C. How to Analyze the Data:
1. EEOC MD-715 Workforce Data Tables: Utilize these workforce data tables tobecome familiar with the organization’s make-up and composition. Information
uncovered by the analysis of this data should not lead to any conclusions without a morein-depth barrier analysis. The following example serves as an illustration of why further
analysis to accurately identify a potential barrier is an important and critical step.
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a. The data in Table A-1, Total Workforce, indicates that the Relevant Civilian
Labor Force (RCLF) for Hispanic males is 20%. Hispanic males represent 3% of theactivity’s workforce. At first glance, this may appear to be a trigger for a potential
barrier.
b. Before a determination that this is indeed a trigger for a potential barrier, areview of the data in Table A-3, Job Categories, should be accomplished. A review ofthis table indicates that 50% of the activity’s workforce is in the professional category.
The officials/managers category has the next highest representation of employees in theworkforce with 24%. The technician category represents 18% of the workforce and theoffice and clerical category represents 7%. Lastly, the craft workers, operatives, laborers
and service workers collectively represent only 2% of the activity’s workforce.
(1) The RCLF for Hispanic males in the professional category is 2.3%. The
activity’s representation of Hispanic males in this category is 3.4% which is above the
RCLF.
(2) The RCLF for the craft workers, operatives, laborers and service workers
are 25.8%, 33.2%, 55.4%, and 14.9%, respectively. The surrounding area that is includedin the RCLF is predominantly agricultural and/or industrial. Occupations in these fields
are not found at this particular activity as validated by a review of its workforce
representation in the Table A-3, Job Categories.
(3) Before concluding that this particular trigger does not uncover a potential
barrier, a review of the data found in Table A-6, Participation Rates for Major
Occupations, should be completed. This review indicates that out of the 5 top major
occupations at this activity, 4 are in the professional series, i.e., 0855 Electronics
Engineer, 1550 Computer Scientist, 0830 Mechanical Engineer, and 0861 Aerospace
Engineer. In order to accurately identify a potential barrier, a more specific CLF should
now be used, i.e., a series specific CLF. The comparison with a series specific CLF
indicates that Hispanic males represent:• 4.2% of workforce for the 855 series compared to a series specific
CLF of 3.6%;• 5.5% of the workforce for the 1550 series compared to a series specific
CLF of 3.1%;• 2.5% of the workforce for the 0830 series compared to a series specific
CLF of 3.1%; and,• 4.8% of the workforce compared to a series specific CLF of 4.1%.
Further calculations for the only professional series (0830 series) that shows a low
participation rate for Hispanic males (total # of the workforce in series X series CLF% =Y, subtract total # of Hispanic males in that series from Y; the numerical result of thiscalculation is the number of Hispanic males needed to reach parity) indicate that if theactivity hired 1 Hispanic male in this series, they would be at parity. Based on this data

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analysis, the trigger of a low participation rate of Hispanic males in the professional
category did not uncover a significant problem in this series.
(a) Before we leave this particular example, let’s review the last of the top
5 major occupations at this activity. The 2nd highest major occupation at this activity is
the 0856, Electronic Technician series. Hispanic males represent 4.5% of the workforce
in this series compared to a series specific CLF of 14.2%. After executing the formula todetermine the actual number of Hispanic males required in this series to reach parity, thedelta is 23.
(b) Whether or not this situation uncovers a potential barrier requires yet
more information. For example, the following information should be considered:•••

The organization is currently in the process of downsizing the numberof employees in this particular series through recent VSIP/VERA
opportunities;
A review of the hiring trend for the last 3 years in this series indicatesa continuing downward trend in the number of hires.
The organization’s current human capital plan does not identify a needfor future hiring in this series.

In view of the information provided above, in this example it is not likely that efforts to
pinpoint any specific barriers, for this particular series, would be useful to theorganization. Although the organization’s future hiring plans did not indicate a need forthis series, the activity’s analysis efforts and findings should be documented in its annual
assessment report.
2. Workforce Analysis: A workforce analysis, utilizing the information in the
EEOC MD-715 Workforce Data Tables and any other relevant data, should be completed
on an annual basis. It is recommended that this data analysis include an examination of
the following:• The organization’s total workforce compared to the relevant CLF.
• The organization’s permanent and temporary workforce compared to
the relevant CLF.
• The organization’s occupations compared to EEOC’s nine job
categories and the relevant CLF.
• The organization’s major occupations compared to a series specific
CLF.
• The organization’s grade group structure by GS, WG, NSPS, or otherdemo system compared to the relevant CLF, i.e., thecommand/activity’s total workforce which is further broken down by
Ethnicity and Race Identification (ERI) and gender. (The collection of
ERI data is authorized under the authority of 42 U.S.C. Section 2000e16 and in compliance with the Office of Management and Budget’s
1997 Revisions to the Standards for the Classification of Federal Data

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on Race and Ethnicity. Employees are requested to provide ERI dataon Standard Form 181.)
This analysis, at a minimum, will include a comparison of the organization’s workforce
by ERI categories, gender and disability.
a. The results of this data analysis will serve as the organization’s starting point
for further analysis because it will identify any “red flags” or triggers for potential
barriers that should be examined.
b. A written summary of the results of an annual workforce analysis will serve
as a useful tool to:• Benchmark progress or lack of progress from one year to the next.
• Conduct appropriate trend analysis.
• Document identified triggers for potential barriers without having to readthrough voluminous reports.
• Document an organization’s analysis efforts.
3. Employment Processes: The data obtained as a result of reviewsof the employment processes described in MD-715 should be analyzed in conjunction
with the data obtained from the MD-715 workforce data tables and the workforce
analysis to identify any potential triggers and to further pinpoint any potential barriers.
The following is an example of how this data may be utilized.
a. The workforce data tables and the activity’s workforce analysis both indicate
a low participation rate of Black males in the 0855, Electronics Engineer, series. The
recruitment employment process analysis shows a sufficiently diverse applicant pool andthat the recruitment schedule includes Historically Black Colleges and Universities andthe National Society of Black Engineers conference. Based on the above, there does notappear to be any apparent potential barriers in the recruitment process.
b. This information should next direct the activity to review its hiring andplacement employment process to determine if there is a potential barrier in their hiring
practices, policies and/or procedures. Information that may be useful in pinpointing any
barriers may include the answers to questions such as:• What hiring authorities are normally utilized to fill the 0855 positions?
• What specific subcomponent(s) of the organization typically hires in
the 0855 series?
• What are the hiring procedures utilized by these subcomponents?
• How are candidates typically referred to the selecting officials?
• What are the factors considered in the hiring process?
• Are positions typically filled at the entry or journey level?
The answers to these questions and any other relevant information should allow thecommand/activity to determine if a potential barrier exists.

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4. Other Relevant Data Sources: Other relevant sources of information include thevarious stakeholders in the barrier analysis process, government reports, local andnational news reports, etc.
a. Input from the various stakeholders, e.g., Special Emphasis groups, union
officials, supervisors/managers, employees, HR practitioners, etc. may answer some ofthe questions that may arise during the analysis process. For example, supervisors andmanagers may provide information regarding the factors that are considered in fillingvacancies, provide information about internal hiring procedures, etc.
b. These same stakeholders may also provide information on other triggers topotential barriers. For example: an employee’s observation on how training opportunities
are not marketed to all individuals who are similarly situated, a supervisor who questions
a policy of hand-picking candidates for developmental assignments, etc.
c. Government and news reports may provide valuable insight into a particular
employment situation. For example, OPM issues an annual report to the President on the
Employment of Hispanics in the Federal Government. In some instances, these various
reports may provide information that is not available from any other source and/or
provide answers to questions that cannot be explained at the activity level.
5. How to Use the Available Data: Data obtained from the workforce data tables,
workforce analysis, employment processes analyses, stakeholders, government reports,
etc. should not be analyzed in a stove pipe fashion. Rather, the totality of all the available
data should be analyzed and put in the proper context to narrow and focus barrier
identification efforts.
II. TREND ANALYSIS
A. Baseline for Future Analysis: A trend analysis is a process of documenting
baseline information for a particular employment process. This baseline information inturn is then used to compare and monitor changes to the established baseline. For
example, an analysis of awards in the $501 and over category this year indicates that all
females, on average, receive a lower dollar amount than their male counterparts. It would
be difficult to determine, based on just one year’s data, whether or not this is a trigger fora potential barrier. However, a snapshot of this baseline data can be used as acomparison for future award activity for females in the $501 and over category. If thissituation persists over a period of time, it could be considered a trigger for a potential
barrier and warrant further analysis.
B. Monitoring Employment Processes for the Identification of Triggers: There are anumber of processes that should be monitored over a period of time to determine whether
or not the data reveals a trend that warrants further investigation. For example:• The level of complaint activity involving a particular group and/or aparticular employment process over a period of time.
• Hiring statistics for a particular group(s) over a period of time.

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•••

Separation statistics for a particular group(s) over a period of time.
Career progression for a particular group(s) over a period of time.
Composition of the supervisory population over a period of time.

As an illustration, if a trend analysis reveals that individuals with targeted disabilities
represent the highest percentage of separations for the last 5 years, this situation would
warrant further investigation. Does further analysis indicate that members of this groupseparate at a higher rate in comparison to the rest of the workforce because of theperception they don’t receive consideration for developmental assignments, training,
promotions, etc? Or, does the analysis indicate that the average age of this group is 57
and nearly all the separations are due to a voluntary retirement action? The data obtained
as a result of this analysis will allow a more focused effort for the identification of any
potential barrier.
III. ANALYSIS PROCEDURES
An analysis cannot and should not be conducted in a “cookbook” type approach. In otherwords, it may not necessarily be a chronological, step-by-step process. Instead, one
should follow the “trail” that the information uncovered during an analysis provides.
This information will influence and determine the next steps in the analysis process. For
example: What does the information uncovered tell you, where does the information leadyou, do you need more data or information, what is the purpose of a current
policy/practice/procedure, is it needed, why does a situation exist, etc. The answers tothese and other questions will lead to the next steps in the analysis process.

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BARRIER ANALYSIS MANUALSECTION 3
BARRIER IDENTIFICATION
I. HOW TO IDENTIFY A POTENTIAL BARRIER
A. What to do with Information Uncovered at the Data Analysis Step:
1. Identification of a Trigger: The data uncovered during the data analysis step
could result in the identification of triggers to potential barriers. These triggers should
prompt an investigation into why a situation exists in order to pinpoint the actual barrier.
2. Barrier Identification: The identification of a potential barrier requires
the investigation into all the possible reasons why the trigger exists. To illustrate thispoint further, let’s look at a possible scenario. In a review of MD-715 Table A-13,
Employee Recognition and Awards, the data reveals that all females, on an average,
receive a lower dollar award amount in the $501+ category. The trigger is the lower
dollar award amount for females. Is the barrier a practice, policy or procedure that resultsin females being awarded a lower dollar amount or is there another reason? To pinpoint
the actual barrier in this example, the following questions need to be asked and answeredas part of the examination process:• What are the criteria for awards in the $501+ category?
• If the answer is – grade level determines the award amount, the next question
might be what is the average grade level of females compared to males?
• If the answer is – on average females are employed at a much lower gradelevel than males, the next question might be which series are most typically
represented in the higher grade levels?
• If the answer is – those series that represent craft workers, the next question
might be what is the representation of females in the craft workers job
category?
• If the answer is – they participate at a low rate, the next question might bewhat does an analysis of hires in the craft worker category indicate?
• If the answer is – females typically represent a small percentage of hires in thecraft worker category, the next question might be what is the make-up of theapplicant pool?
• If the answer is – females represent a small percentage of the potential
applicant pool, the next question might be how does the activity recruit forthese positions?
• If the answer is – there is no recruitment plan in place, then we may have
pinpointed the actual barrier.
Based on the scenario above, the identified barrier could be, “A recruitment plan thatseeks out a diverse pool of applicants for craft workers does not exist.”

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a. In this scenario, there should have been multiple triggers identifying thissituation as a potential barrier, e.g., low participation rate of females in high grade
positions, low participation rate of females in a major occupation, etc.
b. Note that a different answer to any one of the questions listed above could
potentially lead to the identification of a different barrier all together. For example, if
there was no standard criteria for determining award amounts, that may have been
identified as the barrier. It is important to note that this scenario also illustrates what
initially began as a potential barrier in the awards process ultimately led to theidentification of a barrier in the recruitment process. This scenario demonstrates why
conclusions made without further examination could lead to the inaccurate identificationof a barrier and a waste of resources by pursuing the wrong objective.
B. Utilize all Available Data: Make sure to utilize all the relevant data at yourdisposal. In the scenario described in paragraph A.2. above, data from the MD-715
workforce data tables, the awards employment process analysis, hiring trend analysis,
applicant flow information, input from stakeholders, etc. was used to identify the relevant
questions to be asked, provide responses to the questions that arose, identify otheravenues to explore for the identification of potential barriers, etc.
II. DOCUMENTATION OF AN IDENTIFIED BARRIER
A. DOCUMENTATION OF BARRIER ANALYSIS EFFORTS: The
command’s/activity’s complete barrier analysis efforts should be documented in writing,even if the analysis does not result in the identification of a barrier to EEO, and include
the following:• Sources of information, e.g., EEOC MD-715 workforce data tables, trends
analysis, government studies, etc.
• Summary of findings.
• Basis for findings.
• Recommended actions for the elimination of the identified barrier.
This documentation should be maintained as part of the working documents used tosupport and prepare the command’s/activity’s Annual EEO Program Status Report. This
documentation should also simplify the process of completing EEOC Form 715-01, PartI, EEO Plan to Eliminate Identified Barrier, for the annual assessment report.
B. EEOC FORM 715-01, PART I, EEO PLAN TO ELIMINATE IDENTIFIEDBARRIER (BARRIER ELIMINATION PLANS): After the command/activity has
analyzed all available source materials, followed clues to pinpoint potential barriers,
conducted thorough investigations of these potential barriers, and identified specificbarriers, the next step is to plan for improvement by developing overall objectives forbarrier elimination, with corresponding action items, identify responsible personnel andtarget dates. The command/activity plan will be documented on EEOC Form 715-01 PartI (Part I). A blank copy of this form may be found at
http://www.eeoc.gov/federal/715instruct/forms.html.

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1. Timeframe for Completing Barrier Elimination Plans (Part I Forms): As
appropriate, Barrier Elimination Plans should be developed and updated over the courseof the entire reporting period. Commands/activities have an ongoing obligation toeliminate barriers to equal employment opportunity in the workplace. Therefore, analysis
efforts should not be conducted only at the end of the fiscal year. DON policy is to, at aminimum, conduct appropriate data and barrier analysis on data collected through the endof the 3rd quarter, i.e., 30 June.
2. Format of Barrier Elimination Plans (Part I Forms): The command/activity
annual assessment reports should include three separate categories of Barrier Elimination
Plans as follows:(a) Barrier Elimination Plan (Part I) – Command/Activity Accomplishment
Report on their Plans reported in the previous fiscal year’s report.
(b) Barrier Elimination Plan (Part I) – Command/Activity EEO Plans to
Eliminate Identified Barrier for the upcoming fiscal year.
(c) Barrier Elimination Plan (Part I) – Accomplishment Report on the DON
EEO Plans to Eliminate Identified Barrier for the previous fiscal year, as applicable.
The three (3) different categories of Barrier Elimination Plans (Part I) forms should beclearly marked so that they can be easily distinguished.
3. Determining the Appropriate Number of Barrier Elimination Plans: After ananalysis of all the relevant data, a listing of potential barriers should be made and thecommand’s/activity’s most significant problems identified. Depending on the available
resources, it may not be feasible to conduct an in-depth barrier analysis into all thepotential barriers. It is recommended that each command/activity work and report on no
more than 3-5 issues/concerns each fiscal year. These Barrier Elimination Plans should
focus on the command’s/activity’s most significant problem areas. An explanation
should be provided in the Executive Summary that identifies all potential barriers andexplains the basis for those selected.

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BARRIER ANALYSIS MANUALSECTION 4RESPONSIBILITY TO CONTINUALLY ASSESS AND MONITOR EEO PLANS
I. A RECAP OF THE BARRIER ANALYSIS PROCESS: Up to this point in the barrier
analysis process, commands/activities should have: established tracking/monitoring
systems to collect relevant data, collected the relevant data, performed the appropriate
statistical/trend analyses for the purpose of identifying triggers for potential barriers to
EEO; identified other sources for triggers for potential barriers to be examined to include
the monitoring of employment processes; conducted in-depth investigations/examinations
to pinpoint and identify specific barriers; identified specific barriers and developed
objectives to eliminate these barriers; and, documented barrier analysis efforts in their
EEO plans. It is important to note that a plan is nothing more than a piece of paper if it is
not implemented. The process of barrier identification and elimination is a continuous,
evolving process as described below.
II. AFTER THE SUBMITTAL OF BARRIER ELIMINATION PLANS (PART I)
A. Required Actions:
1. All commands/activities are expected to monitor all the planned activities
identified in their respective Plans throughout the reporting period, to ensure completionby the established Target Date. All commands/activities are expected to document
accomplishments as they occur to simplify annual assessment reporting requirements.
The successful elimination of any identified barriers will typically be attained inincremental steps. Therefore, Plans will identify only those Planned Activities that acommand/activity expects to complete within the next reporting cycle. Objectives that
represent a long-term effort may be reported as the same Plan for two or threeconsecutive annual assessment reports. However, the Planned Activities associated with
the Objective will likely be different from year to year as incremental milestones are
established, completed and/or adjusted. In other words, it is expected that Planned
Activities will change from year-to-year, unless some unforeseen event prevents thecompletion of an Activity.
2. Assess the effectiveness of Planned Activities toward the completion of thestated Objective.
a. If Planned Activities are successful and an Objective is achieved prior to theend of the reporting period, document results and close out the applicable Part I.
b. If at any time during the reporting period it is determined that the Planned
Activities do not meet the stated Objective, an adjustment to the Planned Activity(ies)may be required. As soon as it is determined that an adjustment is necessary, thecommand/activity’s explanation of the modification(s) and new actions should be

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documented in the Planned Activities Toward Completion of Objective and Report ofAccomplishments and Modification to Objective sections of the Barrier Elimination Plan.
The following is provided as an example of a situation that might require an adjustmentof a Planned Activity(s).
(1) The Objective is to provide a diverse pool of candidates to selecting
officials for the 0855 series. One of the Planned Activities is to revise the recruitment
schedule to add additional sources that are expected to result in a more diverse pool ofcandidates.
(2) After implementing recruitment efforts to meet this Objective, ananalysis of the applicant pool indicate that the Objective of a diverse pool of candidates
has been achieved.
(3) A further analysis to determine whether or not a more diverse pool ofcandidates positively impacted selection rates in the 0855 series indicated that the desired
result had not been achieved.
(4) A further analysis to determine the possible reason(s) why the desired
result was not achieved led to the discovery that approximately one-half of the candidates
in this more diverse pool of applicants were not appointable.
(5) As a result of this finding, new Planned Activities such as the addition ofrecruitment sources that are likely to produce appointable candidates or publicizing therequirements for appointment to potential candidates may be added to thecommand’s/activity’s Plan.
c. In some cases, additional information obtained during the continuing
assessment and/or analysis process may require a modification to the Objective and/or theStatement of Identified Barrier. As soon as it is determined that an adjustment isnecessary, the command/activity’s explanation of the modification(s) and new actions
should be documented in the applicable sections of Part I.
3. If a Plan is completed before the end of the reporting period, the activity’slisting of identified potential barriers should be reviewed, a new Plan developed andadded to the command/activity’s annual assessment plan, if applicable. A new Part I
should be identified as such and an explanation provided for its addition.
B. DON EEO Plans: All commands/activities should become familiar with the DON
EEO Plans and Objectives. The DON Plans are developed based on a review of all the
major command Annual EEO Program Status Report submissions. The barriers
identified at the DON level reflect the most common, significant problem areas within the
DON. Therefore, it is anticipated that at least one or more of the DON Plans will be
relevant to each command/activity.

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1. Barrier Analysis: The information needed to conduct in-depth analyses and theability to eliminate the identified barrier(s), in almost all cases, is only available andpossible at the command/activity level. For example, the examination of specificemployment practices, policies, procedures, and stakeholder input can only occur at thecommand/activity level. Likewise, the elimination of identified barriers is a line
management responsibility at the command/activity levels as employment-related
decisions are typically made at this level, e.g., who is hired, receives training,
promotions, etc. Accordingly, the development of accurate DON Barrier Elimination
Plans is dependent upon the accomplishment of focused, methodical and thorough barrier
analyses efforts at the command/activity levels.
2. Accomplishment Reports: All commands/activities must become familiar withand submit an Accomplishment Report for each DON EEO Plan that is applicable at theirrespective level. Accomplishment reports should include a concise, complete descriptionof their continuing barrier analysis efforts, noteworthy activities, problems/issues
encountered, accomplishments toward the completion of the stated objective, and anyother relevant information for DON review and reporting purposes.
III. PURPOSE OF EEO PLANS
Remember, the purpose of developing EEO Plans is not to simply fulfill a requirement tosubmit a written report at the end of each year. Rather, it is to attain DON’s goal toeliminate identified barriers to equal participation at all levels of the DON workforce andthe achievement of a Model EEO Program.

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BARRIER ANALYSIS MANUALSECTION 5
THE ROLE/RESPONSIBILITIES OF SPECIAL EMPHASIS PROGRAM (SEP)
MANAGERS IN BARRIER ANALYSIS
I. Special Emphasis Programs (SEP):
A. Definition: Per reference (d), SEPs are defined as programs established as integral
parts of the overall EEO program to enhance the employment, training, and advancementof a particular minority group, women, or disabled individuals, e.g., Federal Women’s
Program, Hispanic Employment Program, People with Disabilities Program, etc.
B. Program Management: SEP Managers are responsible for establishing andmaintaining programs that promote the recruitment, hiring, development and training,
promotion, award recognition, and retention of a particular group(s). An effective SEP
Program will consist of the elements identified below and paragraph II. The recognition
of Special Emphasis Program events, e.g., luncheons or cultural events, without theserequired elements, does not represent a program that is compliant with DON policy andreferences (d) and (e). Program manager responsibilities include:
1. Developing, coordinating, implementing, and recommending to managers,
other officials and covered groups the policy, guidance, information and activities
necessary to attain the objectives of the command/activity and the overall DON Civilian
EEO Program.
2. Communicating the goals and objectives of the program to enable them toobtain the understanding, support, and commitment of managers and other officials at alllevels within the organization.
3. Ensuring program compliance with references (d) and (e)4. Assisting in the development, implementation, and evaluation of the annual
assessment report to ensure inclusion of objectives, as applicable, directed toward therecruitment, employment and advancement of targeted groups.
5. Advising the CDEEOO or DEEOO on matters affecting the employment andadvancement of targeted groups.
6. Initiating and maintaining positive contacts with other government agencies
and private organizations, such as professional groups, colleges, and universities that areconcerned with or have an interest in the employment and career advancement of targetedgroups.
7. Preparing and submitting required reports and/or present briefs.

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8. Assisting in the counseling of members of targeted groups about career
opportunities and encouraging them to participate in self-development and continuing
education.
9. Encouraging management to use the Upward Mobility Program and to
restructure positions to provide opportunities for employees who are in lower grades ordead-end positions to progress to their highest potential.
10. Increasing management’s awareness of the economic advantages of fullyusing the talents of all employees.
11. Monitoring, evaluating and assisting in the efforts to identify any barriers to
the employment of targeted groups.
12. Assisting in the identification, modification or elimination of inappropriate
selection criteria that may have an adverse impact on targeted groups.
13. Establishing and maintaining a working committee to collect and disseminate
information, sponsor workshops, seminars, and organize and participate in special events
for the SEP.
II. Role/Responsibilities of SEP Manager in Barrier Analysis The SEP Manager canserve as a valuable source of information and an additional resource in conducting a morein-depth barrier analysis. The role/responsibility of a SEP Manager in the barrier analysis
process includes, but is not limited to:
A. SEP Managers should assist in compiling the data, relevant to their assigned
group, that is required as part of the barrier analysis process. SEP Managers may also
assist in the review and analysis of data collected (i.e., workforce demographic data,
review of employment processes, etc). The collection and review process will enable the
SEP Manager to become knowledgeable on the workforce representation of and any
employment issues/concerns pertinent to their assigned group.
B. SEP Managers may also be in the unique position of possessing information that
may assist in the identification of triggers for potential barriers. Any information thatwill assist in the identification and elimination of any barriers to equal employment
opportunity for a targeted group should be shared with individuals responsible for barrier
analysis.
C. Some of the employment issues affecting a particular targeted group may not besignificant enough, at an overall organizational level, to warrant the development of an
EEO Plan (Part I). In these cases, the SEP Manager should take the following actions:
1. Implement planned activities to ensure the situation does not worsen.

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2. Track and monitor the employment issue to determine whether or not thesituation worsens to the point a plan objective may be required in a future report.
D. SEP Managers should become familiar with any government reports, local or
national news reports, studies, etc., that may provide some insight into any employment
issues affecting their assigned group.
E. SEP Managers should become familiar with, track progress of, assess
effectiveness of, and/or take the action to complete or assist in the completion of planned
activities developed for any applicable plans/objectives (at the activity, command and
DON levels) for their assigned group.
F. SEP Managers are responsible for reporting accomplishments, noteworthy
activities, and/or submitting recommendations to modify and/or amend any applicableplans/objectives to the assigned Responsible Official for incorporation into the annual
assessment report.
G. SEP Managers should work collaboratively with the individuals responsible for
conducting barrier analysis.

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BARRIER ANALYSIS MANUALAPPENDIX A
DEFINITIONSApplicant Flow Data: Information reflecting characteristics of the pool of individuals
applying for an employment opportunity.
Barrier: A policy, practice or procedure that limits or tends to limit employment
opportunities for members of a particular race, gender, ethnic background or because of adisability.
Barrier Analysis: A process that examines relevant data, trends and benchmarks to
identify a policy, practice or procedure that limits or tends to limit employment
opportunities.
Civilian Labor Force (CLF): Data collected and compiled by the U.S. Census Bureau forpersons 16 years of age and over, except those in the armed forces, who are employed or
are unemployed and seeking work. This information is to be used as the benchmark tocompare and analyze the command/activity workforce as part of the barrier analysis
process.
DART: The DON Affirmative Employment Reporting Tool that provides DON
workforce demographics, as required by MD-715, in an automated format.
Employment Decision: Any decision affecting the terms and conditions of anindividual’s employment, including but not limited to hiring, promotion, demotion,
disciplinary action and termination.
EEO Plans (Part I): An EEOC MD-715 form utilized as part of the annual assessment
process to report an agency’s plan to eliminate identified barriers.
Major Occupations: Agency occupations that are mission related and heavily populated,
relative to other populations within the agency.
Relevant Civilian Labor Force (RCLF): The source from which an agency draws or
Recruits applicants for employment or an internal selection such as a promotion will
determine a more precise benchmark to use to compare the command/activity workforce.
The identification and use of the correct RCLF is critical to performing an accurate
analysis of workforce data, e.g., for major occupations the command/activity must utilizea series specific CLF.
Special Emphasis Program: Programs established as integral parts of the overall EEO
program to enhance the employment, training, and advancement of a particular minority
group, women, or disabled individuals, e.g., Federal Women’s Program, Hispanic

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Employment Program, Program for People with Disabilities, Asian/Pacific Islander
Employment Program, American Indian/Alaskan Native Employment Program, Black
Employment Program.
Trigger: A situation or a ‘red flag’ that indicates the possible existence of a barrier toequal opportunity, e.g., low participation rates identified in the command’s/activity’s
workforce demographic profiles (i.e., overall workforce, grade levels, awards, etc.), an
unusually high number or recurring complaints that identify concern/issues with a
specific employment process (e.g., selections, performance evaluations, etc.).

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