1

Management Directive 715

Annual EEO Program Status Report

Fiscal Year 2020
2

Pension Benefit Guaranty Corporation

FY 2020 Annual EEO Program Status Report

Management Directive 715

Table of Contents

PART A: Department or Agency Identifying Information ...........................................................3

PART B: Total Employment......................................................................................................3

PART C: Agency Official(s) Responsible for Oversight of EEO Program(s)...........................3-4

PART D: List of subordinate components covered in this report............................................4-5

PART E: Executive Summary..............................................................................................6-19

PART F: Certification-Establishment of Continuing Equal Employment Opportunity...............20

PART G: Agency Self-Assessment Checklist Measuring Essential Elements....................21-45

PART H: Agency EEO Plan to Attain the Essential Elements of a Model EEO Program........46

PART I: EEO Plan to Eliminate Identified Barriers......................................................47-55

PART J: Special Program Plan for The Recruitment, Hiring, Advancement and 

Retention of Persons with Disabilities......................................................................56-72

APPENDIX:

Fiscal Year 2020 EEO Workforce Data Tables (Parts A&B) 

EEO Policy Statement

EEO Anti-Harassment Policy Statement

PBGC Organization Chart

 
3

MD-715 Parts A Through E

Part A - Department or Agency Identifying Information

Agency Second Level 

Component Address City State Zip Code 

Agency 

Code 

FIPS Code

Pension Benefit 

Guaranty 

Corporation

1200 K Street NW Washington, DC 20005 BG 11

Part B - Total Employment

Total Employment Permanent Workforce Temporary Workforce Total Workforce

Number of Employees 909 43 952

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

Agency Leadership Name Title

Head of Agency Gordon Hartogensis PBGC Director

Head of Agency Designee N/A

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

EEO Program Staff Name Title Occupational 

Series

Pay 

Plan 

and 

Grade

Phone 

Number Email Address

Principal EEO 

Director/Official

Brenecia 

Watson EEO Director 260 GS-15 202-229-6868 watson.brenecia@pbgc.gov

Affirmative 

Employment Program 

Manager

Hope 

Fuller 

Lead EEO 

Specialist 260 GS-14 202-229-3345 fuller.hope@pbgc.gov

Complaint Processing 

Program Manager

Dianne 

Wood

Attorney 

Advisor 905 GS-14 202-229-3307 wood.dianne@pbgc.gov

Diversity & Inclusion 

Officer

Karen 

Esser

Problem

Resolution 

Specialist

301 GS-14 202-229-3275 esser.karen@pbgc.gov

Hispanic Affirmative 

Employment

Committee Chair Kimberly 

Rodgers EEO Specialist 260 GS-11 202-229-3575 rodgers.kimberly@pbgc.gov
4

EEO Program Staff Name Title Occupational 

Series

Pay 

Plan 

and 

Grade

Phone 

Number Email Address

Women's Affirmative 

Employment 

Committee Chair

Beverley 

Hebron

Management 

Analyst 343 GS-13 202-229-6237 hebron.beverley@pbgc.gov

Disability Affirmative 

Employment 

Committee Chair 

Cynthia 

Searles EEO Specialist 260 GS-12 202-229-3405 searles.cynthia@pbgc.gov

Disability Program

Manager

Denorse 

Prince HR Specialist 201 GS-11 202-229-4026 Prince.denorse@pbgc.gov

Reasonable 

Accommodation 

Program Manager 

Donald 

Beasley HR Specialist 201 GS-13 202-229-3637 beasley.donald@pbgc.gov

Anti-Harassment 

Program Manager

Karen 

Esser

Problem 

Resolution 

Specialist

301 GS-14 202-229-3275 esser.karen@pbgc.gov

ADR Program 

Manager

Dianne 

Wood

Attorney 

Advisor 905 GS-14 202-229-3307

wood.dianne@pbgc.gov

Compliance Manager Dianne 

Wood

Attorney 

Advisor

905 GS-14 202-229-3307 wood.dianne@pbgc.gov

Principal MD-715 

Preparer

Hope 

Fuller 

Lead EEO 

Specialist 260 GS-14 202-229-3345 fuller.hope@pbgc.gov

Part D.1 – List of Subordinate Components Covered in this Report

Please identify the subordinate components within the agency (e.g., bureaus, regions, etc.). If the agency does not have any 

subordinate components, please check the box. 

Subordinate Component City State Country 

(Optional)

Agency 

Code

FIPS

Codes
5

Part D.2 – Mandatory and Optional Documents for this Report

In the table below, the agency must submit these documents with its MD-715 report.

Did the agency submit the following mandatory documents? Please respond Yes or 

No Comments

Organizational Chart YES

EEO Policy Statement YES

Strategic Plan YES

Anti-Harassment Policy and Procedures YES

Reasonable Accommodation Procedures YES

Personal Assistance Services Procedures YES

Alternative Dispute Resolution Procedures YES

In the table below, the agency may decide whether to submit these documents with its MD-715 report.

Did the agency submit the following optional documents? Please respond Yes or 

No Comments

Federal Equal Opportunity Recruitment Program (FEORP) Report YES

Disabled Veterans Affirmative Action Program (DVAAP) Report YES

Operational Plan for Increasing Employment of Individuals with Disabilities 

under Executive Order 13548 YES

Diversity and Inclusion Plan under Executive Order 13583 YES

Diversity Policy Statement YES

Human Capital Strategic Plan YES

EEO Strategic Plan YES

Results from most recent Federal Employee Viewpoint Survey or Annual 

Employee Survey YES
6

EEOC FORM

715-01 

PART E

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT

Pension Benefit Guaranty Corporation For period covering October 1, 2019 to September 30, 2020

EXECUTIVE SUMMARY

E.1: Mission

The Pension Benefit Guaranty Corporation (Agency) protects the retirement income of over 34 million American 

workers, retirees, and beneficiaries in both single-employer and multiemployer private sector pension plans. 

PBGC was created by the Employee Retirement Income Security Act of 1974 to encourage the continuation and 

maintenance of private sector defined benefit pension plans, provide timely and uninterrupted payment of 

pension benefits, and keep pension insurance premiums at a minimum. For over 45 years, the PBGC has 

protected the pension benefits of millions of America’s workers and retirees, and it is critical to our nation’s 

retirement security. During FY 2020, PBGC assumed responsibility for 69 single-employer plans that provided

benefits to nearly 57,000 participants in newly trusteed plans and paid over $6.1 billion to more than 984,000 

retirees. 

PBGC promotes full and fair opportunities for employment, career advancement and access to programs so that 

employees of PBGC are valued, respected and are free to develop their full potential in a culture aligned with 

the Corporation’s priorities. The Office of Equal Employment Opportunity (OEEO) manages the Agency’s Equal 

Employment Opportunity (EEO) program and follows the Equal Employment Opportunity Commission’s (EEOC) 

regulations and policy.

Management Directive 715 (MD-715) is the policy guidance which the EEOC provides to federal agencies for 

their use in establishing and maintaining effective programs of equal employment opportunity under Section 717 

of Title VII of the Civil Rights Act of 1964 (Title VII), as amended, and Section 501 of the Rehabilitation Act of 

1973 (Rehabilitation Act), as amended. 

MD-715 provides a roadmap for creating effective EEO programs for all federal employees as required by Title 

VII and the Rehabilitation Act. The stated objective of MD-715 is to ensure that all employees and applicants for 

employment enjoy equality of opportunity in the federal workplace, regardless of race, sex, national origin, color, 

religion, disability, or reprisal for engaging in prior protected activity. Additionally, the EEOC seeks to ensure the 

same opportunities to all groups regardless of age, genetic information, pregnancy, or other prohibited bases.

MD-715 requires agencies to take appropriate steps to ensure that all employment decisions are free from 

discrimination. It sets forth standards by which the Agency’s EEO programs will be reviewed by the EEOC, 

including, but not limited to, the requirement that agencies conduct periodic self-assessments and barrier 

analysis to identify and remove barriers which may preclude access to equal employment opportunities in the 

workplace.

As required by the EEOC, this report was completed utilizing data compiled at the end of FY 2020 and covers 

the period from October 1, 2019 through September 30, 2020. The workforce data utilized includes permanent 

employees and was extracted from IBC Datamart Portal through the Interior Business Center of the Department 

of the Interior.

PBGC’s noteworthy progress in FY 2020 in developing an equitable work environment and its plans for 

enhancing the EEO program are described in the remainder of the document.
7

The major occupations at PBGC during FY 2020 include Auditor (Series 0511), General Attorney (Series 0905), 

Actuary (Series 1510), Information Technology Specialist (Series 2210), Accountant (Series 0510), Employee 

Benefits Law Specialist (Series 0958), Financial Analyst (Series 1160), and Contract Specialist (Series 1102). 

These occupations represent a significant portion of the PBGC workforce. Planned affirmative employment and 

outreach efforts include collaborating with management and the Human Resources Department (HRD) on 

recruitment and retention in these major categories.

Results of the Agency’s Annual Self-Assessment

PBGC conducted its annual self-assessment of the Six Essential Elements as regulated by EEOC’s 

Management Directive 715 and continues to report steady progress towards model EEO program status. The 

following chart reflects the percentage met for each essential element of a model EEO program over the past 

three fiscal years:

E.2: Essential Elements A - F

Essential Element A: Demonstrated Commitment from Agency Leadership

• PBGC’s Strategic Plan includes objectives to employ a high performing workforce and to encourage 

and support a diverse and inclusive work environment that encourages employee engagement.

• The EEO Director met with the Agency Head, Senior Leadership and/or Department Directors to 

discuss EEO programs and initiatives throughout the year.

• The State of the Agency’s EEO Program briefing was delivered to the Agency Head and Senior 

Leadership. The presentation was posted to the OEEO’s intranet which is employee accessible.

• Each PBGC organization has created a working relationship with the OEEO by appointing a point of 

contact from its office to assist with their equal employment opportunity action plans.

Number of 

Deficiencies Percentage

Number of 

Deficiencies Percentage

Number of 

Deficiencies Percentage

A - Demonstrated Leadership Commitment 0 100% 0 100% 2 86%

B - Integration of EEO in Strategic Mission 0 100% 0 100% 0 100%

C - Management & Program Accountability 0 100% 0 100% 1 98%

D - Proactive Discrimination Prevention 0 100% 0 100% 0 100%

E - Efficiency 0 100% 1 97% 1 97%

F - Responsive & Legal Compliance 0 100% 0 100% 0 100%

Summary Score 100.0% 99.5% 97%

FY 2019 FY 2018

Element

FY 2020
8

Agency leadership supported the following:

• Posting of MD-715 and No FEAR Act Quarterly and Annual Reports on internal and external websites.

• Dissemination of information about PBGC’s EEO programs to employees in New Employee 

Orientations and on the Agency’s internal website.

• Dissemination of information about PBGC’s Diversity Council and Employee Resource Groups to 

employees during New Employee Orientation sessions conducted throughout the year.

• Equal opportunity, diversity, and inclusion by partnering with the PBGC Diversity Council to conduct a 

Senior Leader brown bag series on creating inclusion in a virtual work environment and supporting the 

various special emphasis observances held throughout the year.

• Agency staff participated in the various Affirmative Employment Committees.

• Establishing a new Employee Resource Group (ERG) for First Generation Professionals (FGPs), who 

are among the first in their families to attend college or work in a professional work environment and 

those who wish to support them.

Essential Element B: Integration of EEO into the Agency’s Strategic Mission

• PBGC enhanced collaborative departmental partnerships involving OEEO to support improved 

integration of EEO, diversity and inclusion principles throughout the Agency’s strategic operations in 

FY 2020.

• Collaboration with HRD in preparation of Federal Equal Opportunity Recruitment Program (FEORP)

and Disabled Veterans Affirmative Action Program (DVAAP) for FY 2020.

• PBGC continued barrier and trends analysis (BATA) on key human capital areas, e.g., recruitment and 

hiring, separations, promotions.

• The Agency developed, conducted, delivered, and participated in virtual trainings on EEO, diversity

and inclusion, anti-harassment, reasonable accommodation, and Section 508 Compliance, as well as 

educationally focused Special Emphasis Program and Disability Awareness observances.

Essential Element C: Management and Program Accountability

• PBGC managers and supervisors are evaluated on their commitment to PBGC’s affirmative 

employment principles, and EEO and Diversity goals.

• Agency policies, procedures, and practices were examined to identify if there were barriers to equal 

employment opportunity for employees and applicants. 

• PBGC has a policy discouraging offensive conduct before it rises to the level of discriminatory 

harassment. Employees are encouraged to report offensive, unwanted conduct. In FY 2020, the Office 

of the General Counsel and the Human Resources Department jointly evaluated 12 reports of potential 

harassment and conducted inquiries as appropriate through the Agency’s Harassment Inquiry 

Committee (HIC).

• PBGC has an annual mandatory reasonable accommodation and diversity and inclusion training 

requirement for all supervisors and managers and HRD delivered virtual training sessions in these areas 

in FY 2020. The Agency’s Reasonable Accommodations Coordinator briefed all new employees on 

reasonable accommodation procedures during New Employee Orientation and the Agency’s Section 508 

Compliance Team conducted training sessions throughout the year available to all employees
9

Essential Element D: Proactive Prevention of Unlawful Discrimination

• PBGC provided managers, supervisors, and employees with information regarding their rights and 

responsibilities under various anti-discrimination and anti-retaliation laws through posters, intranet 

content, all-employee emails, and policy statements.

• The Agency conducted virtual trainings for PBGC managers and staff in the areas of EEO, Diversity, 

Inclusion, anti-harassment, reasonable accommodation, and section 508 Compliance.

• Agency organizations supported the EEO program in identifying and/or correcting potential barriers to 

equal employment opportunity and supported EEO-related committees and projects.

•

Essential Element E: Efficiency

• The Agency offers early resolution of complaints with the use of alternative dispute resolution (ADR) as 

an option to its traditional administrative EEO process. The commitment to ADR is communicated to 

employees through the intranet, training, and during individual meetings with parties seeking assistance 

from OEEO.

• For FY 2020, ADR was offered to 1 individual and it was denied. Participation in ADR was impacted by 

the restrictions outlined in Executive Order 13839 issued May 2018. The Executive Order prohibited 

granting frequent remedies sought in mediation.

• PBGC received and processed 11 formal complaints alleging employment discrimination in FY 2020.

Essential Element F: Responsiveness and Legal Compliance

• Annual Federal EEO Statistical Report on Discrimination Complaints (EEOC Form 462) and Annual 

Notification and Federal Employee Antidiscrimination and Retaliation Act of 2002 (NO FEAR) report 

were submitted in advance of established timeframes.

• The Agency successfully processed 95 percent of informal complaints within regulatory time frames.

• The following reflects PBGC’s formal complaints activity in FY 2020:

• By the end of the fiscal year, the Agency had 23 formal complaints in inventory:

o 12 formal complaints were on hand from FY2019

o 11 formal complaints were filed in FY 2020

o 0 formal complaints were remanded from the EEOC

o 9 formal complaints were closed

• Of the 23 formal complaints on hand at the end of the fiscal year:

o 0 pending letter of acknowledgement

o 2 pending accept/dismiss

o 9 investigations completed within regulatory timeframes; average number of days to complete 

investigations was 112

o 1 investigation with amendment was completed in 217 days which is within the 181-360 day

regulatory timeframes for amendments.

o 10 cases pending hearing before EEOC

o 1 case pending investigation.

o 0 pending final agency decisions
10

E.4 – E.5: PBGC’s Accomplishments and Ongoing Commitment to a Model EEO Program

• PBGC’s senior leadership team, including its Director, demonstrates its commitment to moving the 

Agency to model EEO program status via support of barrier analysis and annual EEO training.

• OEEO offered Supervisory EEO training and EEO Employee training and will review and establish a 

schedule for ongoing EEO training courses for both current and new managers and supervisors.

• The Human Resources Department continued to offer a comprehensive leadership development training 

program for managers and supervisors with courses focused on diversity, inclusion, and unconscious 

bias, as well as a Leadership/Executive Coaching Program with International Coaching Federation (ICF) 

certified coaches available to employees at the SL, GS-15, and GS-14 grade levels.

• Agency senior leaders have provided continued support for barrier analysis by providing organizational 

points of contact to work with OEEO so that equal opportunity and diversity and inclusion are integrated 

into the Agency’s strategic operations. The goal is to be proactive in the prevention of discrimination.

• OEEO will continue to engage senior leaders, human resources staff and hiring officials to examine ways 

to improve recruitment and retention and discuss process improvement to determine whether the 

recruitment and selection process should be refined internally.

• OEEO continued its book club with discussions focused on topics that support equity, diversity, and 

inclusion to create a more engaged workforce.

• OEEO continued its YOUniversity bias awareness program.

• PBGC’s Affirmative Employment Committees assisted in barrier analysis program development to 

support equal employment opportunity.

• PBGC’s Diversity and Inclusion Council (D & I Council) provided “Be an Inclusion Agent” training to 

managers, supervisors, and employees.

• In FY 2020, the D & I Council formed a new employee resource group at PBGC for First Generation 

Professionals (FGPs).

• The D & I Council developed and sponsored a Senior leader “Brown Bag” Series on Creating Inclusion 

in A Virtual Work Environment where Senior Leaders shared strategies for creating inclusion and 

enhancing teamwork and collaboration in a virtual work environment.

• PBGC’s Section 508 Compliance Team continued to conduct multiple virtual “Acclimate to Section 508”

Learning Series courses throughout the year.

• Office of General Counsel (OGC) continued to focus its recruitment efforts on increasing the 

representation of minority attorneys in OGC. Targeted recruitment activities resulted in OGC hiring 15

new attorneys. Of that number, seven were Asian, Black, or Hispanic.

• Office of Policy and External Affairs (OPEA) began working to develop targeted recruitment strategies

for underrepresented groups.

• Office of Management and Administration (OMA) enhanced developmental opportunities by establishing 

career ladder positions at lower grade levels that are promotable to higher GS-levels.

• Office of Benefits Administration (OBA) continued to work with the HRD on a workforce planning strategy 

that will allow the recruitment of new hires at lower grades with career ladders to GS12 or GS13. 

Additionally, OBA continued to seek opportunities to expand the use of the Hispanic Association of 

Colleges and Universities (HACU) program to multiple semesters and to recruit students for permanent 

positions. 

• Office of Information Technology (OIT) worked with the Human Resources Department to develop

recruitment strategies targeted at underrepresented groups.
11

• Office of The Chief Financial Officer (OCFO) continued to work with the Human Resources Department 

(HRD) to hire persons with targeted disabilities through Schedule A appointing authority. 
12

E.3: Workforce Analysis
13

2020 Total Workforce - Review

During the reporting period PBGC had a total of 952 employees. Females represented 56% of the 

workforce and males represented 44%. The representation rates of both demographics remained 

consistent with the prior year percentages. 

When comparing groups by race and ethnicity to the Civilian Labor Force (CLF) benchmark, it should be 

noted that there is a lack of representation in PBGC for Native Hawaiian or Other Pacific Islanders. 

American Indian or Alaskan Natives are below representation and Two-or-More Races has increased since 

the previous year. Asian, Hispanic, and White representation has remained consistent, and Black 

representation has decreased but remains above the civilian labor force benchmark.
14

OEEO conducted its annual review to identify significant changes and/or inconsistencies in the 

representation rates by Race, Ethnicity and Gender of PBGC’s workforce in comparison to the Civilian 

Labor Force benchmark. While the workforce demographic remains consistent amongst most groups, it 

should be noted that both Hispanic and White representation rates are consistently below the civilian labor 

force benchmark. The changes are reflected on the table below.

The benchmark for grade representation is the total workforce. All demographics that are below the 

benchmark are reflected in red. When reviewing PBGC’s grade representation, we identified that Black 

males and Asian, Black, and Hispanic females are below the benchmark for their representation in grades 

GS-14 thru SL. Asian males are below the benchmark in SL representation, and Hispanic males are below 

the benchmark for grades GS-15 and SL. 

These rates are reflected in the following chart.

FY2020 Benchmark % GS-9 % GS-11 % GS-12 % GS-13 % GS-14 % GS-15 % SL %

Asian Male 5.78 8.70 4.55 5.88 7.08 5.52 5.52 2.50

Asian Female 6.51 4.35 6.82 8.24 7.96 5.84 6.21 2.50

Black/African American Male 12.08 8.70 11.36 15.29 14.16 11.69 8.97 7.50

Black/African American Female 29.31 43.48 47.73 44.71 37.17 21.43 15.86 10.00

Hispanic Male 16.70 0.00 2.27 2.35 2.21 1.62 1.38 0.00

Hispanic Female 2.00 4.35 4.55 5.88 2.65 1.30 2.07 0.00

White Male 23.42 8.33 6.82 7.02 16.52 30.97 33.33 46.34

White Female 16.70 20.83 6.82 10.59 9.38 20.65 27.08 31.71

In reviewing FY 2020 data to identify significant changes in occupation representation rates of PBGC’s 

eight major occupations by race, ethnicity, and gender, we noted that in comparison to the FY 2019 PBGC 

data regarding the Accounting 0510 Series, Hispanic males and females continue to be conspicuously 

Asian Male Asian Female Black Male Black Female Hispanic Male Hispanic

Female White Male White Female

CLF 1.97 1.93 5.49 6.53 5.17 4.79 38.33 34.03

2020 5.78 6.51 12.08 29.31 2 2.52 23.42 16.7

2019 5.91 5.91 11.6 29.64 2.11 2.43 23.63 17.3

1.97

1.93

5.49 6.53 5.17 4.79

38.33

34.03

5.78 6.51

12.08

29.31

2

2.52

23.42

5.91 16.7

5.91

11.6

29.64

2.11

2.43

23.63

17.3

PBGC Representation by Race, Ethnicity, & Gender

From FY 2019 to FY 2020
15

absent from the series. Asian male representation rates had a decrease and Black females had a increase.

It should be noted that both Asian males and Black females are above the Occupational Civilian Labor 

Force (OCLF) benchmark rate of representation. These changes are reflected in Table 1.

Table 1.

It should be noted that throughout this section of the report, if there is no reference made to a specific race, 

ethnicity, or gender, that demographic is either at or above parity with the benchmark. In the FY 2020 data 

for Auditing 0511 series, White males and females are below the OCLF, however both experienced an 

increase in representation rate. Black females also had a decrease in representation rate over the 2-year 

reporting period, however, remain above the OCLF. These changes are reflected in Table 2.

Table 2.

White Male White Female Black Female

OCLF Benchmark 31.79 44.23 5.66

FY 2020 12.3 12.3 35.25

FY 2019 11.11 9.4 39.32

31.79

44.23

5.66

12.3 12.3

35.25

11.11 9.4

39.32

Auditing Series - 0511 

Change in Percentage

Hispanic Male Hispanic Female Asian Male Black Females

OCLF Benchmark 2.19 3.93 3.06 5.66

FY 2020 0 0 12.28 32.76

FY 2019 0 0 16.07 28.57

2.19 3.93 3.06

5.66

0 0

12.28

32.76

0 0

16.07

28.57

Accounting Series - 0510

Change in Percentage
16

In FY 2020 PBGC’s General Attorney 0905 Series reflected that the representation rate of Hispanic males 

had decreased by 2.05% and that Asian and Black males continue to be absent from the series. These 

changes are also reflected in Table 3.

Table 3.

Employee Benefits Law 0958 Series reflects that the representation rates of White males had a decrease 

in representation, and Hispanic males, Hispanic and Asian female representation rates increased from 

previous years numbers. These changes are also reflected in Table 4.

Table 4.

Hispanic Male Hispanic

Female White Male White Female Black Male Black Female Asian Male Asian Female

OCLF Benchmark 2.52 1.85 59.68 26.68 2.13 2.6 1.82 1.74

FY 2020 1.08 1.08 37.63 40.86 0 10.75 0 8.6

FY 2019 3.13 2.08 38.54 41.67 0 8.33 0 6.25

2.52

1.85

59.68

26.68

2.13 2.6 1.82 1.74 1.08 1.08

37.63

40.86

0

10.75

0

8.6

3.13

2.08

38.54

41.67

0

8.33

0 6.25

General Attorney Series - 0905

Change in Percentage

Hispanic Male Hispanic Female White Male Asian Female

OCLF Benchmark 2.05 7.35 19.18 2.24

FY 2020 1.08 1.08 12 4

FY 2019 0 0 17.86 0

2.05

7.35

19.18

2.24

1.08 1.08

12

4

0 0

17.86

0

Employee Benefits Law Series - 0958

Change in Percentage
17

When reviewing the Contracting 1102 Series, it reflects that the representation rates of Hispanic males 

had a significant decrease, resulting in their lack of representation in the series. White males and White 

females remain below the OCLF, with White males experiencing a 4.21% decrease in representation in 

the series. Black male representation also had a 3.95% decrease and Black females had a 2.3% increase 

in representation for the series during reporting period. These changes are also reflected in Table 5. 

Table 5.

The Financial Analysis 1160 Series reflects that Hispanic males and females continue to be below the 

OCLF representation rate. It should be noted that Hispanic females are absent from this major 

occupation in PBGC and White females are .73% below the benchmark.

Table 6.

Hispanic Male White Male White Female Black Male Black Female

OCLF Benchmark 3.29 38.09 41.87 3.01 5.47

FY 2020 0.00 15.79 36.84 21.05 21.05

FY 2019 6.25 25.00 25.00 25.00 18.75

3.29

38.09

41.87

3.01 5.47

0.00

15.79

36.84

21.05 21.05

6.25

25.00 25.00 25.00

18.75

Contracting Series - 1102

Change in Percentage

OCLF Benchmark FY 2020 FY 2019

Hispanic Male 3.1 2.13 2.13

Hispanic Female 1.97 0 0

White Female 22.01 21.28 23.4

3.1

1.97 2.13 2.13

0 0

22.01 21.28

23.4

Financial Analysis Series - 1160

Change in Percentage
18

The Actuarial Science 1510 Series representation rates reflect that Hispanic females continue to be 

absent from the series and that White males and females continue to be below the rate of representation 

according to the series benchmark. Those changes are reflected in Table 7.

Table 7.

The representation rate for the IT Management 2210 Series reflects that Hispanic males and females 

and White males and females are below the OCLF benchmark. It should be noted that Hispanic females 

or conspicuoulsy absent from the series.

Table 8.

Hispanic Female White Male White Female

OCLF Benchmark 0.56 60.44 27.01

FY 2020 0 39.8 14.29

FY 2019 0 37.89 15.79

0.56

60.44

27.01

0

39.8

14.29

0

37.89

15.79

Acturarial Science Series - 1510 

Change in Percentage

Hispanic Male Hispanic Female White Male White Female

OCLF Benchmark 5.39 2.17 52.21 20.89

FY 2020 2.86 0 29.52 6.67

FY 2019 2.73 0 30 6.36

5.39

2.17

52.21

20.89

2.86

0

29.52

6.67

2.73

0

30

6.36

IT Management Series - 2210

Change in Percentage
19

During FY 2020, OEEO continued to conduct barrier analysis for the demographic groups that separated from 

PBGC’s workforce at a rate higher than their representation in the Agency. Hispanic males and females have been 

consistently below the rate of representation in PBGC and the federal government and their separation rate is above 

their occupation in PBGC’s workforce. Asian males and White females were also separating at a rate higher than 

their representation in the Agency. Those changes are reflected on Table 9.

Table 9.

It is the mission of the Office of Equal Employment Opportunity to continue to assist in the eradication of 

employment discrimination, improve diversity in the workplace, and create an environment where all PBGC 

employees are valued, respected, and free to develop and perform to their fullest potential. As such, we 

will continue to investigate any and all triggers to support the ongoing development of PBGC’s model EEO 

program.
20

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT

CERTIFICATION of ESTABLISHMENT of CONTINUING

EQUAL EMPLOYMENT OPPORTUNITY PROGRAMS

I, Brenecia Watson am the

(Insert name above) (Insert official

title/series/grade above)

Principal EEO Director/Official for Pension Benefit Guaranty Corporation

(Insert Agency/Component Name above)

The Agency has conducted an annual self-assessment of Section 717 and Section 501 programs against 

the essential elements as prescribed by EEO MD-715. If an essential element was not fully compliant with 

the standards of EEO MD-715, a further evaluation was conducted and, as appropriate, EEO Plans for 

Attaining the Essential Elements of a Model EEO Program, are included with this Federal Agency Annual 

EEO Program Status Report.

The Agency has also analyzed its work force profiles and conducted barrier analyses aimed at detecting 

whether any management or personnel policy, procedure or practice is operating to disadvantage any group 

based on race, national origin, gender or disability. EEO Plans to Eliminate Identified Barriers, as appropriate, 

are included with this Federal Agency Annual EEO Program Status Report.

I certify that proper documentation of this assessment is in place and is being maintained for EEOC review 

upon request.

April 20, 2021

Signature of Principal EEO Director/Official

Certifies that this Federal Agency Annual EEO Program Status Report is in 

compliance with EEO MD-715.

Date

April 20, 2021

Signature of Agency Head or Agency Head Designee Date
21

MD-715 - PART G

Agency Self-Assessment Checklist 

The Part G Self-Assessment Checklist is a series of questions designed to provide federal agencies with 

an effective means for conducting the annual self-assessment required in Part F of MD-715. This selfassessment permits EEO Directors to recognize, and to highlight for their senior staff, deficiencies in their 

EEO program that the agency must address to comply with MD-715's requirements. Nothing in Part G 

prevents agencies from establishing additional practices that exceed the requirements set forth in this 

checklist.

All agencies will be required to submit Part G to EEOC. Although agencies need not submit documentation 

to support their Part G responses, they must maintain such documentation on file and make it available to 

EEOC upon request.

The Part G checklist is organized to track the MD-715 essential elements. As a result, a single substantive 

matter may appear in several different sections, but in different contexts. For example, questions about 

establishing an anti-harassment policy fall within Element C (Management and Program Accountability), 

while questions about providing training under the anti-harassment policy are found in Element A 

(Demonstrated Commitment from Agency Leadership). 

For each MD-715 essential element, the Part G checklist provides a series of "compliance indicators." 

Each compliance indicator, in turn, contains a series of “yes/no” questions, called “measures.” To the right 

of the measures, there are two columns, one for the agency to answer the measure with "Yes", "No", or 

"NA;" and the second column for the agency to provide “comments”, if necessary. Agencies should briefly 

explain any “N/A” answer in the comments. For example, many of the sub-component agencies are not 

responsible for issuing final agency decisions (FADs) in the EEO complaint process, so it may answer 

questions about FAD timeliness with "NA" and explain in the comments column that the parent agency 

drafts all FADs.

A "No" response to any measure in Part G is a program deficiency. For each such "No" response, an 

agency will be required in Part H to identify a plan for correcting the identified deficiency. If one or more 

sub-components answer “No” to a particular question, the agency-wide/parent agency’s report should also 

include that “No” response.
22

MD-715 - PART G

Agency Self-Assessment Checklist

Essential Element A: DEMONSTRATED COMMITMENT FROM AGENCY LEADERSHIP

This element requires the agency head to communicate a commitment to equal employment 

opportunity and a discrimination-free workplace.

Compliance 

Indicator 

Measures

A.1 – The agency issues an 

effective, up-to-date EEO policy 

statement.

Measure 

Met?

(Yes/No/NA)

Comments Current 

Part G 

Questions

A.1.a Does the agency annually issue 

a signed and dated EEO policy 

statement on agency letterhead

that clearly communicates the 

agency’s commitment to EEO 

for all employees and 

applicants? If “yes”, please 

provide the annual issuance 

date in the comments column. 

[see MD-715, II(A)]

Yes July 8, 2020 A.1.a.2

A.1.b Does the EEO policy statement 

address all protected bases 

(age, color, disability, sex

(including pregnancy, sexual 

orientation and gender identity), 

genetic information, national 

origin, race, religion, and 

reprisal) contained in the laws 

EEOC enforces? [see 29 CFR § 

1614.101(a)] 

Yes

Compliance 

Indicator 

Measures

A.2 – The agency has 

communicated EEO policies and 

procedures to all employees.

Measure 

Met?

(Yes/No/NA)

Comments

A.2.a Does the agency disseminate 

the following policies and 

procedures to all employees:

A.2.a.1 Anti-harassment policy? [see 

MD 715, II(A)] 

Yes

A.2.a.2 Reasonable accommodation 

procedures? [see 29 C.F.R § 

1614.203(d)(3)]

Yes

A.2.b Does the agency prominently 

post the following information 

throughout the workplace and 

on its public website: 
23

A.2.b.1The business contact 

information for its EEO 

Counselors, EEO Officers, 

Special Emphasis Program 

Managers, and EEO Director? 

[see 29 C.F.R § 1614.102(b)(7)]

Yes

A.2.b.2Written materials concerning the 

EEO program, laws, policy 

statements, and the operation of 

the EEO complaint process? 

[see 29 C.F.R § 1614.102(b)(5)]

Yes A.2.c

A.2.b.3 Reasonable accommodation 

procedures? [see 29 C.F.R. § 

1614.203(d)(3)(i)] If so, please 

provide the internet address in 

the comments column.

Yes https://www.pbgc.gov/si

tes/default/files/pbgc-

procedures-for-

processing-requests-

for-reasonable-

accommodation.pdf

A.3.c

 A.2.c Does the agency inform its 

employees about the following 

topics: 

A.2.c.1 EEO complaint process? [see 

29 CFR §§ 1614.102(a)(12) and 

1614.102(b)(5)] If “yes”, please 

provide how often. 

Yes The complaint process is 

always posted on the intranet 

and in lounge areas. Classes 

are offered annually, and new 

employees are informed of 

the process during New 

Employee Orientation (NEO).

A.2.a

A.2.c.2 ADR process? [see MD-110, 

Ch. 3(II)(C)] If “yes”, please 

provide how often. 

Yes The ADR process is always 

posted on the intranet. 

Classes that include 

information on the ADR 

process are offered annually. 

New employees are also 

informed of the process 

during New Employee Orientation.

A.2.c.3 Reasonable accommodation 

program? [see 29 CFR § 

1614.203(d)(7)(ii)(C)] If “yes”, 

please provide how often. 

Yes The Reasonable 

Accommodation brochure is 

provided to all employees 

during New Employee 

Orientation and the PBGC 

Reasonable Accommodation 

Coordinator provides a 

briefing to all new employees 

during NEO on reasonable 

accommodation procedures. 

In addition, the information is 

available on the intranet.

A.2.c.4 Anti-harassment program? [see 

EEOC Enforcement Guidance

on Vicarious Employer Liability 

for Unlawful Harassment by 

Supervisors (1999), § V.C.1] If 

“yes”, please provide how often.

Yes HRD provides training 

regarding workplace 

behavior, Harassment Inquiry 

Committee (HIC), Agency 

policy, arbitration/mediation, and inappropriate 

behaviors/ethics in the 

workplace. During these 

sessions, employees are 

provided information tools 

such as the PBGC’s Anti-

harassment Policy brochure, 

the current OEEO Prevention 

of Workplace Harassment 

Policy Statement and the 

Equal Employment 

Opportunity Policy Statement 
24

to give notice to federal 

employees of inappropriate 

behaviors in the workplace 

and the potential result of 

such actions.

A.2.c.5 Behaviors that are inappropriate 

in the workplace and could

result in disciplinary action? [5 

CFR § 2635.101(b)] If “yes”, 

please provide how often.

Yes Notices are also 

publicly displayed in 

HRD’s front office and 

the Agency intranet 

site.

A.3.b

Compliance 

Indicator 

Measures

A.3 – The agency assesses and 

ensures EEO principles are part 

of its culture.

Measure 

Met?

(Yes/No/NA)

Comments

New Compliance 

Indicator

A.3.a Does the agency provide 

recognition to employees, 

supervisors, managers, and 

units demonstrating superior 

accomplishment in equal 

employment opportunity? [see 

29 CFR § 1614.102(a) (9)] If 

“yes”, provide one or two 

examples in the comments 

section.

Yes EEO Merit Award and 

Certificates.

A.3.b Does the agency utilize the 

Federal Employee Viewpoint 

Survey or other climate 

assessment tools to monitor the 

perception of EEO principles 

within the workforce? [see 5 

CFR Part 250]

Yes

Essential Element B: INTEGRATION OF EEO INTO THE AGENCY’S STRATEGIC MISSION

This element requires that the agency’s EEO programs are structured to maintain 

a workplace that is free from discrimination and support the agency’s strategic 

mission.

Compliance 

Indicator 

Measures

B.1 - The reporting structure for 

the EEO program provides the 

principal EEO official with 

appropriate authority and 

resources to effectively carry out 

a successful EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

B.1.a Is the agency head the 

immediate supervisor of the 

person (“EEO Director”) who 

has day-to-day control over the 

EEO office? [see 29 CFR 

§1614.102(b)(4)]

Yes B.1.a

B.1.a.1 If the EEO Director does not 

report to the agency head, does

the EEO Director report to the 

same agency head designee as 

NA
25

the mission-related 

programmatic offices? If “yes,” 

please provide the title of the 

agency head designee in the 

comments.

B.1.a.2 Does the agency’s 

organizational chart clearly 

define the reporting structure for

the EEO office? [see 29 CFR 

§1614.102(b)(4)]

Yes B.1.d

B.1.b Does the EEO Director have a 

regular and effective means of 

advising the agency head and 

other senior management 

officials of the effectiveness, 

efficiency and legal compliance 

of the agency’s EEO program?

[see 29 CFR §1614.102(c)(1); 

MD-715 Instructions, Sec. I] 

Yes B.2.a

B.1.c During this reporting period, did 

the EEO Director present to the 

head of the agency, and other 

senior management officials, the 

"State of the agency" briefing 

covering the six essential 

elements of the model EEO 

program and the status of the 

barrier analysis process? [see 

MD-715 Instructions, Sec. I] If 

“yes”, please provide the date of 

the briefing in the comment’s 

column. 

Yes July 13, 2020 B.2.b

B.1.d Does the EEO Director regularly 

participate in senior-level staff 

meetings concerning personnel, 

budget, technology, and other 

workforce issues? [see MD-715, 

II(B)]

Yes

Compliance 

Indicator

Measures

B.2 – The EEO Director controls 

all aspects of the EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

New Compliance 

Indicator

B.2.a Is the EEO Director responsible 

for the implementation of a 

continuing affirmative 

employment program to promote 

EEO and to identify and 

eliminate discriminatory policies, 

procedures, and practices? [see 

MD-110, Ch. 1(III)(A); 29 CFR 

§1614.102(c)] 

Yes B.3.a
26

B.2.b Is the EEO Director responsible 

for overseeing the completion of 

EEO counseling [see 29 CFR 

§1614.102(c)(4)]

Yes

B.2.c Is the EEO Director responsible 

for overseeing the fair and 

thorough investigation of EEO 

complaints? [see 29 CFR 

§1614.102(c)(5)] [This question 

may not be applicable for certain 

subordinate level components.]

Yes

B.2.d Is the EEO Director responsible 

for overseeing the timely 

issuance of final agency 

decisions? [see 29 CFR 

§1614.102(c)(5)] [This question 

may not be applicable for certain 

subordinate level components.]

Yes

B.2.e Is the EEO Director responsible 

for ensuring compliance with 

EEOC orders? [see 29 CFR §§ 

1614.102(e); 1614.502]

Yes F.3.b

B.2.f Is the EEO Director responsible 

for periodically evaluating the 

entire EEO program and 

providing recommendations for 

improvement to the agency 

head? [see 29 CFR 

§1614.102(c)(2)]

Yes

B.2.g If the agency has subordinate 

level components, does the 

EEO Director provide effective 

guidance and coordination for 

the components? [see 29 CFR 

§§ 1614.102(c)(2) and (c)(3)]

NA

Compliance 

Indicator 

Measures

B.3 - The EEO Director and other 

EEO professional staff are 

involved in, and consulted on, 

management/personnel actions.

Measure 

Met?

(Yes/No/NA)

Comments

B.3.a Does EEO program officials 

participate in agency meetings 

regarding workforce changes

that might impact EEO issues, 

including strategic planning, 

recruitment strategies, vacancy 

projections, succession 

planning, and selections for 

training/career development 

opportunities? [see MD-715, 

II(B)]

Yes B.2.c & 

B.2.d

B.3.b Does the agency’s current 

strategic plan reference EEO / 

diversity and inclusion 

Yes PBGC Strategic Goal 3: 

Maintain High Standards 

of Stewardship and 

Accountability: Encourage 
27

principles? [see MD-715, II(B)] 

If “yes”, please identify the EEO 

principles in the strategic plan in 

the comments column.

and support a diverse and 

inclusive work 

environment that 

encourages employee 

engagement; Foster a 

diverse, high-performing 

workforce; Foster a 

culture of inclusion that 

encourages collaboration, 

flexibility, and fairness.

Compliance 

Indicator 

Measures

B.4 - The agency has sufficient 

budget and staffing to support 

the success of its EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

B.4.a Pursuant to 29 CFR 

§1614.102(a)(1), has the agency 

allocated sufficient funding and 

qualified staffing to successfully 

implement the EEO program, for 

the following areas: 

B.4.a.1 to conduct a self-assessment of 

the agency for possible program 

deficiencies? [see MD-715, 

II(D)]

Yes B.3.b

B.4.a.2 to enable the agency to conduct 

a thorough barrier analysis of its 

workforce? [see MD-715, II(B)]

Yes B.4.a

B.4.a.3 to timely, thoroughly, and fairly 

process EEO complaints, 

including EEO counseling, 

investigations, final agency 

decisions, and legal sufficiency 

reviews? [see 29 CFR § 

1614.102(c)(5) & 1614.105(b) –

(f); MD-110, Ch. 1(IV)(D) & 

5(IV); MD-715, II(E)]

Yes E.5.b

B.4.a.4 to provide all supervisors and 

employees with training on the 

EEO program, including but not 

limited to retaliation, 

harassment, religious 

accommodations, disability 

accommodations, the EEO 

complaint process, and ADR?

[see MD-715, II(B) and III(C)] If 

not, please identify the type(s) of 

training with insufficient funding 

in the comments column. 

Yes B.4.f & 

B.4.g

B.4.a.5 to conduct thorough, accurate, 

and effective field audits of the 

EEO programs in components

and the field offices, if 

NA E.1.c
28

applicable? [see 29 CFR 

§1614.102(c)(2)]

B.4.a.6 to publish and distribute EEO 

materials (e.g. harassment 

policies, EEO posters, 

reasonable accommodations 

procedures)? [see MD-715, 

II(B)]

Yes B.4.c

B.4.a.7 to maintain accurate data 

collection and tracking systems 

for the following types of data: 

complaint tracking, workforce 

demographics, and applicant 

flow data? [see MD-715, II(E)]. 

If not, please identify the 

systems with insufficient funding 

in the comments section.

Yes

B.4.a.8 to effectively administer its 

special emphasis programs 

(such as, Federal Women’s 

Program, Hispanic Employment 

Program, and People with 

Disabilities Program Manager)?

[5 USC § 7201; 38 USC § 4214; 

5 CFR § 720.204; 5 CFR § 

213.3102(t) and (u); 5 CFR § 

315.709]

Yes B.3.c, 

B.3.c.1, 

B.3.c.2, & 

B.3.c.3

B.4.a.9 to effectively manage its anti-

harassment program? [see MD-

715 Instructions, Sec. I); EEOC 

Enforcement Guidance on 

Vicarious Employer Liability for 

Unlawful Harassment by 

Supervisors (1999), § V.C.1]

Yes

B.4.a.10 to effectively manage its 

reasonable accommodation 

program?[see 29 CFR § 

1614.203(d)(4)(ii)]

Yes B.4.d

B.4.a.11 to ensure timely and complete 

compliance with EEOC orders?

[see MD-715, II(E)]

Yes

B.4.b Does the EEO office have a 

budget that is separate from 

other offices within the agency? 

[see 29 CFR § 1614.102(a)(1)]

Yes

B.4.c Are the duties and 

responsibilities of EEO officials 

clearly defined? [see MD-110, 

Ch. 1(III)(A), 2(III), & 6(III)]

Yes B.1.b

B.4.d Does the agency ensure that all 

new counselors and 

investigators, including 

contractors and collateral duty 

employees, receive the required 

Yes E.2.d
29

32 hours of training, pursuant to 

Ch. 2(II)(A) of MD-110?

B.4.e Does the agency ensure that all 

experienced counselors and 

investigators, including 

contractors and collateral duty 

employees, receive the required 

8 hours of annual refresher 

training, pursuant to Ch. 2(II)(C) 

of MD-110?

Yes E.2.e

Compliance 

Indicator 

Measures

B.5 – The agency recruits, hires, 

develops, and retains 

supervisors and managers who 

have effective managerial, 

communications, and 

interpersonal skills.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

B.5.a Pursuant to 29 CFR § 

1614.102(a)(5), have all 

managers and supervisors 

received training on their 

responsibilities under the 

following areas under the 

agency EEO program:

B.5.a.1 EEO Complaint Process? [see 

MD-715(II)(B)]

Yes

B.5.a.2 Reasonable Accommodation 

Procedures? [see 29 C.F.R. § 

1614.102(d)(3)]

Yes A.3.d

B.5.a.3 Anti-Harassment Policy? [see 

MD-715(II)(B)]

Yes

B.5.a.4 Supervisory, managerial, 

communication, and 

interpersonal skills in order to 

supervise most effectively in a 

workplace with diverse 

employees and avoid disputes 

arising from ineffective 

communications? [see MD-715, 

II(B)]

Yes

B.5.a.5 ADR, with emphasis on the 

federal government’s interest in 

encouraging mutual resolution of 

disputes and the benefits 

associated with utilizing ADR?

[see MD-715(II)(E)]

Yes E.4.b

Compliance 

Indicator 

Measures

B.6 – The agency involves 

managers in the implementation 

of its EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator 

B.6.a Are senior managers involved in 

the implementation of Special 

Emphasis Programs? [see MD715 Instructions, Sec. I]

Yes
30

B.6.b Do senior managers participate 

in the barrier analysis process? 

[see MD-715 Instructions, Sec. I]

 

Yes D.1.a

B.6.c When barriers are identified, do 

senior managers assist in 

developing agency EEO action 

plans (Part I, Part J, or the 

Executive Summary)? [see MD715 Instructions, Sec. I]

Yes D.1.b

B.6.d Do senior managers 

successfully implement EEO 

Action Plans and incorporate the 

EEO Action Plan Objectives into 

agency strategic plans? [29 CFR 

§ 1614.102(a)(5)]

Yes During FY 2020, action 

plans were maintained 

and continued to be 

implemented. We will

continue to measure

results in 2021.

D.1.c

Essential Element C: MANAGEMENT AND PROGRAM ACCOUNTABILITY

This element requires the agency head to hold all managers, supervisors, and 

EEO officials responsible for the effective implementation of the agency’s EEO 

Program and Plan.

Compliance 

Indicator 

Measures

C.1 – The agency conducts 

regular internal audits of its 

component and field offices.

Measure 

Met?

(Yes/No/NA)

Comments

C.1.a Does the agency regularly 

assess its component and field 

offices for possible EEO 

program deficiencies? [see 29 

CFR §1614.102(c)(2)] If ”yes”, 

please provide the schedule for 

conducting audits in the 

comments section.

N/A PBGC does not have 

field offices

C.1.b Does the agency regularly 

assess its component and field 

offices on their efforts to remove 

barriers from the workplace? 

[see 29 CFR §1614.102(c)(2)] If 

”yes”, please provide the 

schedule for conducting audits 

in the comments section.

N/A PBGC does not have 

field offices

C.1.c Do the component and field 

offices make reasonable efforts 

to comply with the 

recommendations of the field 

audit? [see MD-715, II(C)] 

N/A PBGC does not have 

field offices

Compliance 

Indicator 

Measures

C.2 – The agency has established 

procedures to prevent all forms 

of EEO discrimination.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

C.2.a.1 Does the anti-harassment policy 

require corrective action to 

Yes
31

prevent or eliminate conduct 

before it rises to the level of 

unlawful harassment? [see 

EEOC Enforcement Guidance

on Vicarious Employer Liability 

for Unlawful Harassment by 

Supervisors (1999), § V.C.1]

C.2.a.2 Has the agency established a 

firewall between the Anti-

Harassment Coordinator and the 

EEO Director? [see EEOC 

Report, Model EEO Program 

Must Have an Effective Anti-

Harassment Program (2006]

Yes

C.2.a.3 Does the agency have a 

separate procedure (outside the 

EEO complaint process) to 

address harassment 

allegations? [see Enforcement 

Guidance on Vicarious 

Employer Liability for Unlawful 

Harassment by Supervisors

(Enforcement Guidance), EEOC 

No. 915.002, § V.C.1 (June 18, 

1999)]

Yes

C.2.a.4 Does the agency ensure that the 

EEO office informs the anti-

harassment program of all EEO 

counseling activity alleging 

harassment? [see Enforcement 

Guidance, V.C.]

Yes

C.2.a.5 Does the agency conduct a 

prompt inquiry(beginning within 

10 days of notification) of all 

harassment allegations, 

including those initially raised in 

the EEO complaint process?

[see Complainant v. Dep’t of 

Veterans Affairs, EEOC Appeal 

No. 0120123232 (May 21, 

2015); Complainant v. Dep’t of 

Defense (Defense Commissary 

Agency), EEOC Appeal No. 

0120130331 (May 29, 2015)] If 

“no”, please provide the 

percentage of timely-processed 

inquiries in the comments 

column.

Yes

C.2.a.6 Do the agency’s training 

materials on its anti-harassment 

policy include examples of 

Yes
32

disability-based harassment? 

[see 29 CFR 1614.203(d)(2)]

C.2.b Has the agency established 

disability reasonable 

accommodation procedures that 

comply with EEOC’s regulations 

and guidance? [see 29 CFR 

1614.203(d)(3)]

Yes

C.2.b.1 Is there a designated agency 

official or other mechanism in 

place to coordinate or assist with 

processing requests for disability 

accommodations throughout the 

agency? [see 29 CFR 

1614.203(d)(3)(D)]

Yes E.1.d

C.2.b.2 Has the agency established a 

firewall between the Reasonable 

Accommodation Program 

Manager and the EEO Director? 

[see MD-110, Ch. 1(IV)(A)]

Yes

C.2.b.3 Does the agency ensure that job 

applicants can request and 

receive reasonable 

accommodations during the 

application and placement 

processes? [see 29 CFR 

1614.203(d)(1)(ii)(B)]

Yes

C.2.b.4 Do the reasonable 

accommodation procedures 

clearly state that the agency 

should process the request 

within a maximum amount of 

time (e.g., 20 business days), as 

established by the agency in its 

affirmative action plan? [see 29 

CFR 1614.203(d)(3)(i)(M)]

Yes

C.2.b.5 Does the agency process all

accommodation requests within 

the time frame set forth in its 

reasonable accommodation 

procedures? [see MD-715, II(C)] 

If “no”, please provide the 

percentage of timely-processed 

requests in the comments 

column.

Yes E.1.e

C.2.c Has the agency established 

procedures for processing 

requests for personal assistance 

services that comply with 

EEOC’s regulations, 

enforcement guidance, and 

other applicable executive 

orders, guidance, and 

standards? [see 29 CFR 

1614.203(d)(6)]

Yes
33

C.2.c.1 Does the agency post its 

procedures for processing 

requests for Personal 

Assistance Services on its public 

website? [see 29 CFR § 

1614.203(d)(5)(v)] If “yes”, 

please provide the internet 

address in the comments 

column.

Yes https://www.pbgc.gov/si

tes/default/files/pbgcprocedures-forprocessing-requestsfor-reasonableaccommodation.pdf

Compliance 

Indicator 

Measures

C.3 - The agency evaluates 

managers and supervisors on 

their efforts to ensure equal 

employment opportunity.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

C.3.a Pursuant to 29 CFR 

§1614.102(a)(5), do all 

managers and supervisors have 

an element in their performance 

appraisal that evaluates their 

commitment to agency EEO 

policies and principles and their 

participation in the EEO 

program?

Yes

C.3.b Does the agency require rating 

officials to evaluate the 

performance of managers and 

supervisors based on the 

following activities:

C.3.b.1 Resolve EEO 

problems/disagreements/conflict

s, including the participation in 

ADR proceedings? [see MD110, Ch. 3.I]

Yes A.3.a.1

C.3.b.2 Ensure full cooperation of 

employees under his/her 

supervision with EEO officials, 

such as counselors and 

investigators? [see 29 CFR 

§1614.102(b)(6)]

Yes A.3.a.4

C.3.b.3 Ensure a workplace that is free 

from all forms of discrimination, 

including harassment and 

retaliation? [see MD-715, II(C)]

Yes A.3.a.5

C.3.b.4 Ensure that subordinate 

supervisors have effective 

managerial, communication, and 

interpersonal skills to supervise 

in a workplace with diverse 

employees? [see MD-715 

Instructions, Sec. I]

Yes A.3.a.6

C.3.b.5 Provide religious 

accommodations when such 

accommodations do not cause 

an undue hardship? [see 29 

CFR §1614.102(a)(7)]

Yes A.3.a.7
34

C.3.b.6 Provide disability 

accommodations when such 

accommodations do not cause 

an undue hardship? [ see 29 

CFR §1614.102(a)(8)]

Yes A.3.a.8

C.3.b.7 Support the EEO program in 

identifying and removing barriers 

to equal opportunity. [see MD715, II(C)]

Yes

C.3.b.8 Support the anti-harassment 

program in investigating and 

correcting harassing conduct.

[see Enforcement Guidance, 

V.C.2]

Yes A.3.a.2

C.3.b.9 Comply with settlement 

agreements and orders issued 

by the agency, EEOC, and 

EEO-related cases from the 

Merit Systems Protection Board, 

labor arbitrators, and the 

Federal Labor Relations 

Authority? [see MD-715, II(C)]

Yes

C.3.c Does the EEO Director 

recommend to the agency head 

improvements or corrections, 

including remedial or disciplinary 

actions, for managers and 

supervisors who have failed in 

their EEO responsibilities? [see 

29 CFR §1614.102(c)(2)]

Yes

C.3.d When the EEO Director 

recommends remedial or 

disciplinary actions, are the 

recommendations regularly 

implemented by the agency? 

[see 29 CFR §1614.102(c)(2)]

Yes

Compliance 

Indicator 

Measures

C.4 – The agency ensures 

effective coordination between its 

EEO programs and Human 

Resources (HR) program.

Measure 

Met?

(Yes/No/NA)

Comments

C.4.a

Do the HR Director and the EEO 

Director meet regularly to 

assess whether personnel 

programs, policies, and 

procedures conform to EEOC 

laws, instructions, and 

management directives? [see 29 

CFR §1614.102(a)(2)]

Yes

C.4.b Has the agency established 

timetables/schedules to review

at regular intervals its merit 

promotion program, employee 

recognition awards program, 

employee development/training 

Yes C.2.a, 

C.2.b, & 

C.2.c
35

programs, and 

management/personnel policies, 

procedures, and practices for 

systemic barriers that may be 

impeding full participation in the 

program by all EEO groups? 

[see MD-715 Instructions, Sec. I]

C.4.c Does the EEO office have timely 

access to accurate and 

complete data (e.g., 

demographic data for workforce, 

applicants, training programs, 

etc.) required to prepare the 

MD-715 workforce data tables? 

[see 29 CFR §1614.601(a)]

Yes

C.4.d Does the HR office timely 

provide the EEO office with

access to other data (e.g., exit 

interview data, climate 

assessment surveys, and 

grievance data), upon request? 

[see MD-715, II(C)]

Yes

C.4.e Pursuant to Section II(C) of MD715, does the EEO office 

collaborate with the HR office to:

C.4.e.1 Implement the Affirmative Action 

Plan for Individuals with 

Disabilities? [see 29 CFR 

§1614.203(d); MD-715, II(C)]

Yes

C.4.e.2 Develop and/or conduct 

outreach and recruiting 

initiatives? [see MD-715, II(C)]

Yes

C.4.e.3 Develop and/or provide training 

for managers and employees? 

[see MD-715, II(C)]

Yes

C.4.e.4 Identify and remove barriers to 

equal opportunity in the 

workplace? [see MD-715, II(C)]

Yes

C.4.e.5 Assist in preparing the MD-715 

report? [see MD-715, II(C)]

Yes

Compliance 

Indicator 

Measures

C.5 – Following a finding of 

discrimination, the agency 

explores whether it should take a 

disciplinary action.

Measure 

Met?

(Yes/No/NA)

Comments

C.5.a Does the agency have a 

disciplinary policy and/or table of 

penalties that covers 

discriminatory conduct? [see 29 

CFR § 1614.102(a)(6); see also 

Douglas v. Veterans 

Administration, 5 MSPR 280 

(1981)]

Yes C.3.a.
36

C.5.b When appropriate, does the 

agency discipline or sanction 

managers and employees for 

discriminatory conduct? [see 29 

CFR §1614.102(a)(6)] If “yes”, 

please state the number of 

disciplined/sanctioned 

individuals during this reporting 

period in the comments.

Yes There were no 

managers or 

supervisors 

disciplined/sanctioned 

for this fiscal year.

C.3.c

C.5.c If the agency has a finding of 

discrimination (or settles cases 

in which a finding was likely), 

does the agency inform 

managers and supervisors 

about the discriminatory 

conduct? [see MD-715, II(C)]

Yes

Compliance 

Indicator 

Measures

C.6 – The EEO office advises 

managers/supervisors on EEO 

matters.

Measure 

Met?

(Yes/No/NA)

Comments

C.6.a Does the EEO office provide 

management/supervisory 

officials with regular EEO 

updates on at least an annual 

basis, including EEO 

complaints, workforce 

demographics and data 

summaries, legal updates, 

barrier analysis plans, and 

special emphasis updates? [see 

MD-715 Instructions, Sec. I] If 

“yes”, please identify the 

frequency of the EEO updates in 

the comments column.

Yes EEO provides annual

updates to 

management and 

supervisors.

C.1.a

C.6.b Are EEO officials readily 

available to answer managers’ 

and supervisors’ questions or 

concerns? [see MD-715 

Instructions, Sec. I]

Yes

Essential Element D: PROACTIVE PREVENTION

This element requires that the agency head make early efforts to prevent 

discrimination and to identify and eliminate barriers to equal employment 

opportunity.

Compliance 

Indicator 

Measures

D.1 – The agency conducts a 

reasonable assessment to 

monitor progress towards 

achieving equal employment 

opportunity throughout the year.

Measure 

Met?

(Yes/No/NA)

Comments

D.1.a Does the agency have a 

process for identifying triggers in 

the workplace? [see MD-715 

Instructions, Sec. I]

Yes
37

D.1.b Does the agency regularly use 

the following sources of 

information for trigger 

identification: workforce data; 

complaint/grievance data; exit 

surveys; employee climate 

surveys; focus groups; affinity 

groups; union; program 

evaluations; special emphasis 

programs; reasonable 

accommodation program; antiharassment program; and/or 

external special interest groups? 

[see MD-715 Instructions, Sec. I]

Yes

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)]

Yes

Compliance 

Indicator 

Measures

D.2 – The agency identifies areas 

where barriers may exclude EEO 

groups (reasonable basis to act.)

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

D.2.a Does the agency have a 

process for analyzing the 

identified triggers to find 

possible barriers? [see MD-715, 

(II)(B)]

Yes

D.2.b Does the agency regularly 

examine the impact of 

management/personnel policies, 

procedures, and practices by 

race, national origin, sex, and 

disability? [see 29 CFR 

§1614.102(a)(3)]

Yes B.2.c.2

D.2.c Does the agency consider 

whether any group of employees 

or applicants might be 

negatively impacted prior to 

making human resource 

decisions, such as reorganizations and realignments?

[see 29 CFR §1614.102(a)(3)]

Yes B.2.c.1
38

D.2.d Does the agency regularly 

review the following sources of 

information to find barriers: 

complaint/grievance data, exit 

surveys, employee climate 

surveys, focus groups, affinity 

groups, union, program 

evaluations, anti-harassment 

program, special emphasis 

programs, reasonable 

accommodation program; antiharassment program; and/or 

external special interest groups?

[see MD-715 Instructions, Sec. I] 

If “yes”, please identify the data 

sources in the comments 

column.

Yes The EEO programs 

reviews workforce data. 

Agency HR and 

corporate strategic 

plans, complaints data, 

survey data, 

reasonable 

accommodations data 

and conducts focus 

groups and surveys to 

identify potential 

barriers.

Compliance 

Indicator 

Measures

D.3 – The agency establishes 

appropriate action plans to 

remove identified barriers.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

D.3.a. Does the agency effectively 

tailor action plans to address the 

identified barriers, in particular 

policies, procedures, or 

practices? [see 29 CFR 

§1614.102(a)(3)]

Yes No barriers have been 

identified

D.3.b If the agency identified one or 

more barriers during the 

reporting period, did the agency 

implement a plan in Part I, 

including meeting the target 

dates for the planned activities? 

[see MD-715, II(D)] 

Yes No barriers identified 

during reporting period;

however, triggers were 

investigated.

D.3.c Does the agency periodically 

review the effectiveness of the 

plans? [see MD-715, II(D)]

Yes

Compliance 

Indicator 

Measures

D.4 – The agency has an 

affirmative action plan for people 

with disabilities, including those 

with targeted disabilities.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

D.4.a

Does the agency post its 

affirmative action plan on its 

public website? [see 29 CFR 

1614.203(d)(4)] Please provide 

the internet address in the 

comments.

Yes https://www.pbgc.go

v/sites/default/files/fy

2019-md715-

report.pdf
39

D.4.b

Does the agency take specific 

steps to ensure qualified people 

with disabilities are aware of and 

encouraged to apply for job 

vacancies? [see 29 CFR 

1614.203(d)(1)(i)]

Yes

D.4.c

Does the agency ensure that 

disability-related questions from 

members of the public are 

answered promptly and 

correctly? [see 29 CFR 

1614.203(d)(1)(ii)(A)]

Yes

D.4.d

Has the agency taken specific 

steps that are reasonably 

designed to increase the 

number of persons with 

disabilities or targeted 

disabilities employed at the 

agency until it meets the goals? 

[see 29 CFR 1614.203(d)(7)(ii)]

Yes

Essential Element E: EFFICIENCY

This element requires the agency head to ensure that there are effective systems 

for evaluating the impact and effectiveness of the agency’s EEO programs and an 

efficient and fair dispute resolution process.

Compliance 

Indicator 

E.1 - The agency maintains an 

efficient, fair, and impartial 

complaint resolution process.

Measure 

Met?

(Yes/No/NA)

Comments

Measures

E.1.a Does the agency timely provide 

EEO counseling, pursuant to 29 

CFR §1614.105?

Yes E.3.a.1

E.1.b Does the agency provide written 

notification of rights and 

responsibilities in the EEO 

process during the initial 

counseling session, pursuant to

29 CFR §1614.105(b)(1)?

Yes E.3.a.2

E.1.c Does the agency issue 

acknowledgment letters 

immediately upon receipt of a 

formal complaint, pursuant to

MD-110, Ch. 5(I)?

Yes

E.1.d Does the agency issue 

acceptance letters/dismissal 

decisions within a reasonable 

time (e.g., 60 days) after receipt 

of the written EEO Counselor 

report, pursuant to MD-110, Ch. 

5(I)? If so, please provide the 

average processing time in the 

comments.

Yes Yes, the Agency issues 

acceptance

letter/dismissal 

decisions within a 

reasonable time. The 

internal office policy is 

to issue within 14 days 

of receipt of the formal 

complaint.
40

E.1.e Does the agency ensure all 

employees fully cooperate with

EEO counselors and EEO 

personnel in the EEO process, 

including granting routine 

access to personnel records 

related to an investigation, 

pursuant to 29 CFR 

§1614.102(b)(6)?

Yes

E.1.f Does the agency timely 

complete investigations, 

pursuant to 29 CFR §1614.108?

Yes E.3.a.3

E.1.g If the agency does not timely 

complete investigations, does 

the agency notify complainants 

of the date by which the 

investigation will be completed 

and of their right to request a 

hearing or file a lawsuit, 

pursuant to 29 CFR 

§1614.108(g)?

Yes

E.1.h When the complainant does not 

request a hearing, does the 

agency timely issue the final 

agency decision, pursuant to 29 

CFR §1614.110(b)?

Yes E.3.a.4

E.1.i Does the agency timely issue 

final actions following receipt of 

the hearing file and the 

administrative judge’s decision, 

pursuant to 29 CFR 

§1614.110(a)?

Yes E.3.a.7

E.1.j If the agency uses contractors to 

implement any stage of the EEO 

complaint process, does the 

agency hold them accountable 

for poor work product and/or 

delays? [See MD-110, Ch. 

5(V)(A)] If “yes”, please describe 

how in the comments column.

Yes Yes, the Agency uses 

contract investigators to 

conduct EEO 

discrimination 

investigations. The 

EEO attorney-advisor 

requires weekly 

progress reports from 

the contract 

investigators during an 

investigation. In 

addition, the EEO 

attorney-advisor, 

reviews the report of 

investigation for legal 

sufficiency before it is 

issued. If there are any 

identified problems, the 

contract investigator is 

required to fix the 

problem.

E.2.c
41

E.1.k If the agency uses employees to 

implement any stage of the EEO 

complaint process, does the 

agency hold them accountable 

for poor work product and/or 

delays during performance 

review? [See MD-110, Ch. 

5(V)(A)]

Yes

E.1.l Does the agency submit 

complaint files and other 

documents in the proper format 

to EEOC through the Federal 

Sector EEO Portal (FedSEP)? 

[See 29 CFR § 1614.403(g)]

Yes

Compliance 

Indicator 

Measures

E.2 – The agency has a neutral 

EEO process.

Measure 

Met?

(Yes/No/NA)

Comments

Revised Indicator

E.2.a Has the agency established a 

clear separation between its 

EEO complaint program and its 

defensive function? [see MD110, Ch. 1(IV)(D)] 

Yes

E.2.b When seeking legal sufficiency 

reviews, does the EEO office 

have access to sufficient legal 

resources separate from the 

agency representative? [see 

MD-110, Ch. 1(IV)(D)] If “yes”, 

please identify the 

source/location of the attorney 

who conducts the legal 

sufficiency review in the 

comments column. 

Yes The Equal Employment 

Opportunity Office has 

an attorney Advisor on 

staff to ensure legal 

sufficiency reviews are 

separate and apart 

from the agency 

representative.

E.6.a

E.2.c If the EEO office relies on the 

agency’s defensive function to 

conduct the legal sufficiency 

review, is there a firewall 

between the reviewing attorney 

and the agency representative?

[see MD-110, Ch. 1(IV)(D)]

Yes

E.2.d Does the agency ensure that its 

agency representative does not 

intrude upon EEO counseling, 

investigations, and final agency 

decisions? [see MD-110, Ch.

1(IV)(D)]

Yes E.6.b

E.2.e If applicable, are processing 

time frames incorporated for the 

legal counsel’s sufficiency 

review for timely processing of 

complaints? [see EEOC Report, 

Attaining a Model Agency 

Yes E.6.c
42

Program: Efficiency (Dec. 1, 

2004)]

Compliance 

Indicator 

Measures

E.3 - The agency has established 

and encouraged the widespread 

use of a fair alternative dispute 

resolution (ADR) program.

Measure 

Met?

(Yes/No/NA)

Comments

E.3.a Has the agency established an 

ADR program for use during 

both the pre-complaint and 

formal complaint stages of the 

EEO process? [see 29 CFR 

§1614.102(b)(2)]

Yes E.4.a

E.3.b Does the agency require 

managers and supervisors to 

participate in ADR once it has 

been offered? [see MD-715, 

II(A)(1)]

Yes E.4.c

E.3.c Does the agency encourage all 

employees to use ADR, where 

ADR is appropriate? [see MD110, Ch. 3(IV)(C)]

Yes D.2.a

E.3.d Does the agency ensure a 

management official with 

settlement authority is 

accessible during the dispute 

resolution process? [see MD110, Ch. 3(III)(A)(9)]

Yes

E.3.e Does the agency prohibit the 

responsible management official 

named in the dispute from 

having settlement authority? 

[see MD-110, Ch. 3(I)]

Yes E.4.d

E.3.f Does the agency annually 

evaluate the effectiveness of its 

ADR program? [see MD-110, 

Ch. 3(II)(D)]

Yes

Compliance 

Indicator 

Measures

E.4 – The agency has effective 

and accurate data collection 

systems in place to evaluate its 

EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

E.4.a Does the agency have systems

in place to accurately collect, 

monitor, and analyze the 

following data:

E.4.a.1 Complaint activity, including the 

issues and bases of the 

complaints, the aggrieved 

individuals/complainants, and 

the involved management

official? [see MD-715, II(E)]

Yes E.5.a
43

E.4.a.2 The race, national origin, sex, 

and disability status of agency 

employees? [see 29 CFR 

§1614.601(a)]

Yes E.5.c

E.4.a.3 Recruitment activities? [see MD715, II(E)]Yes E.5.f

E.4.a.4 External and internal applicant 

flow data concerning the 

applicants’ race, national origin, 

sex, and disability status? [see 

MD-715, II(E)]

Yes

E.4.a.5 The processing of requests for 

reasonable accommodation? [29 

CFR § 1614.203(d)(4)]

Yes

E.4.a.6 The processing of complaints for 

the anti-harassment program? 

[see EEOC Enforcement 

Guidance on Vicarious 

Employer Liability for Unlawful 

Harassment by Supervisors 

(1999), § V.C.2]

Yes

E.4.b Does the agency have a system 

in place to re-survey the 

workforce on a regular basis? 

[MD-715 Instructions, Sec. I]

Yes

Compliance 

Indicator 

Measures

E.5 – The agency identifies and 

disseminates significant trends 

and best practices in its EEO 

program.

Measure 

Met?

(Yes/No/NA)

Comments

E.5.a Does the agency monitor trends 

in its EEO program to determine 

whether the agency is meeting 

its obligations under the statutes 

EEOC enforces? [see MD-715, 

II(E)] If “yes”, provide an 

example in the comments.

Yes By conducting annual 

Barrier and Trend 

Analysis.

E.5.e

E.5.b Does the agency review other 

agencies’ best practices and 

adopt them, where appropriate, 

to improve the effectiveness of 

its EEO program? [see MD-715, 

II(E)] If “yes”, provide an 

example in the comments.

Yes PBGC remains current 

regarding industry best 

practices and 

researches EEOC’s 

website, meets with 

other federal agencies 

to identify their best 

practices, gathers 

information from public 

entities regarding their 

best practices and 

seeks to implement 

relevant best practices

when identified and 

appropriate. 

E.5.g
44

E.5.c Does the agency compare its 

performance in the EEO process 

to other federal agencies of 

similar size? [see MD-715, II(E)]

Yes E.3.a

Essential Element F: RESPONSIVENESS AND LEGAL COMPLIANCE

This element requires federal agencies to comply with EEO statutes and EEOC 

regulations, policy guidance, and other written instructions.

Compliance 

Indicator 

Measures

F.1 – The agency has processes 

in place to ensure timely and full 

compliance with EEOC Orders 

and settlement agreements.

Measure 

Met?

(Yes/No/NA)

Comments

F.1.a Does the agency have a system 

of management controls to 

ensure that its officials timely 

comply with EEOC 

orders/directives and final 

agency actions? [see 29 CFR 

§1614.102(e); MD-715, II(F)]

Yes F.1.a

F.1.b Does the agency have a system 

of management controls to 

ensure the timely, accurate, and 

complete compliance with 

resolutions/settlement 

agreements? [see MD-715, II(F)]

Yes E.3.a.6

F.1.c Are there procedures in place to 

ensure the timely and 

predictable processing of 

ordered monetary relief? [see 

MD-715, II(F)]

Yes F.2.a.1

F.1.d Are procedures in place to 

process other forms of ordered 

relief promptly? [see MD-715, 

II(F)]

Yes F.2.a.2

F.1.e When EEOC issues an order 

requiring compliance by the 

agency, does the agency hold 

its compliance officer(s) 

accountable for poor work 

product and/or delays during 

performance review? [see MD110, Ch. 9(IX)(H)]

Yes

F.3.a.

Compliance 

Indicator 

Measures

F.2 – The agency complies with 

the law, including EEOC 

regulations, management 

directives, orders, and other 

written instructions.

Measure 

Met?

(Yes/No/NA)

Comments

Indicator moved from EIII Revised

F.2.a Does the agency timely respond 

and fully comply with EEOC 

orders? [see 29 CFR 

§1614.502; MD-715, II(E)]

Yes C.3.d

F.2.a.1 When a complainant requests a 

hearing, does the agency timely 

Yes E.3.a.5
45

forward the investigative file to 

the appropriate EEOC hearing 

office? [see 29 CFR 

§1614.108(g)]

F.2.a.2 When there is a finding of 

discrimination that is not the 

subject of an appeal by the 

agency, does the agency ensure 

timely compliance with the 

orders of relief? [see 29 CFR 

§1614.501]

Yes E.3.a.7

F.2.a.3 When a complainant files an 

appeal, does the agency timely 

forward the investigative file to 

EEOC’s Office of Federal 

Operations? [see 29 CFR 

§1614.403(e)]

Yes

F.2.a.4 Pursuant to 29 CFR §1614.502, 

does the agency promptly 

provide EEOC with the required 

documentation for completing 

compliance?

Yes F.3.d (1 

to 9)

 Compliance 

Indicator

 Measures

F.3 - The agency reports to EEOC 

its program efforts and 

accomplishments.

Measure 

Met?

(Yes/No/NA)

Comments

F.3.a Does the agency timely submit 

to EEOC an accurate and 

complete No FEAR Act report? 

[Public Law 107-174 (May 15, 

2002), §203(a)]

Yes

F.3.b Does the agency timely post on 

its public webpage its quarterly 

No FEAR Act data? [see 29 

CFR §1614.703(d)]

Yes
46

MD-715 – Part H

Agency EEO Plan to Attain the Essential Elements of a Model EEO Program

Please describe the status of each plan that the agency has implemented to correct deficiencies in the 

EEO program.

X If the agency did not address any deficiencies during the reporting period, please check the box.

Statement of Model Program Essential Element Deficiency

Type of Program Deficiency Brief Description of Program Deficiency

Applicant Flow Data

The tables that PBGC receives from IBC fail to provide complete 

applicant flow data which is necessary to conduct an accurate data 

analysis. HRD manages OEEO’s access to IBC Datamart data and is 

responsible for managing PBGC’s Human Resources Information 

Systems (HRIS).

Objective(s) and Dates for EEO Plan

Date Initiated 

(mm/dd/yyyy) Objective Target Date (mm/dd/yyyy)

Modified Date 

(mm/dd/yyyy)

Date 

Completed 

(mm/dd/yyyy)

12/01/2020

To have access to data that includes 

complete and accurate applicant flow 

data.

09/30/2021 Ongoing

Responsible Official(s)

Title Name

Performance 

Standards Address 

the Plan?

(Yes or No)

Human Resources Director Arrie Etheridge No

Planned Activities Toward Completion of Objective

Target Date 

(mm/dd/yyyy) Planned Activities

Sufficient 

Funding & 

Staffing? 

(Yes or No)

Modified 

Date 

(mm/dd/yyyy)

Completion 

Date 

(mm/dd/yyyy)

09/30/2021

Identify if funding is necessary to enhance 

PBGC’s current HRIS to increase its capacity 

to provide data necessary for accurate barrier 

analysis. 

No Ongoing

Report of Accomplishments 

Fiscal Year Accomplishments

None
47

MD-715 – Part I

Agency EEO Plan to Eliminate Identified Barrier

Please describe the status of each plan that the agency implemented to identify possible barriers in 

policies, procedures, or practices for employees and applicants by race, ethnicity, and gender. 

 If the agency did not conduct barrier analysis during the reporting period, please check the box.

Statement of Condition That Was a Trigger for a Potential Barrier:

Source of the 

Trigger

Specific 

Workforce 

Data Table 

Narrative Description of Trigger

Hispanic 

representation 

in PBGC is 

below the 

CLF 

benchmark

All Data 

Tables

The Office of Equal Employment Opportunity continued to conduct its 

barrier analysis with the review of FY 2020 MD-715 workforce data 

tables. We reviewed all tables to identify how the data could impact the 

representation rates of Hispanics and to determine if triggers were 

identified through analysis of the data.

Compared to the National Civilian Labor Force (NCLF), Hispanic

employees have lower than anticipated representation in the PBGC 

workforce. The participation rates of Hispanic males and females in 

PBGC compared to the NCLF benchmark are as follows:

It should be noted, that during FY 2020, Hispanics males held 2, or 

1.08% of Grades GS-15 or above and Hispanic females held 3, or 

1.61% of Grades GS-15 or above. Both percentages are below the 

benchmark identified in the chart above.

Hispanics separated at a rate of 3.16% for both males and females; 

higher than their representation in PBGC’s workforce.

Males Females Total

PBGC 2.00% 2.52% 4.52%

NCLF 5.17% 4.79% 9.96%

EEO Group(s) Affected by Trigger

EEO Group

Hispanic or Latino Males - YES

Hispanic or Latino Females - YES
48

Barrier Analysis Process

Sources of Data

Source 

Reviewed?

(Yes or No)

Identify Information Collected

Workforce Data Tables Yes Hispanic representation in grades, in major occupations, 

applicant flow data, recruitment, and hiring. 

Complaint Data (Trends) Yes Complainant demographics, bases and Issues 

reported.

Grievance Data (Trends) No

Findings from Decisions 

(e.g., EEO) No

Climate Assessment Survey 

(e.g., FEVS)

Yes Responses to employee perceptions of the work 

environment as it relates to equal employment 

opportunity.

Exit Interview Data No

Focus Groups

Yes Perceptions of Hispanic females in PBGC’s workforce 

regarding career development, barriers to next grade 

level and promotional opportunities.

Interviews No

Reports (e.g., Congress, 

EEOC, MSPB, GAO, OPM)

Yes Industry practices / best practices. Federal government 

wide demographic reports.

Other (Recruitment & 

Retention Bonus) Yes Demographics of bonus recipients to recruit and retain employees.

Status of Barrier Analysis Process

Barrier Analysis Process Completed?

(Yes or No)

Barrier(s) Identified?

(Yes or No)

Efforts are ongoing No

Statement of Identified Barrier(s)

Description of Policy, Procedure, or Practice

The workforce data analysis suggests that barriers may exist for Hispanic employees in the 

hiring/selections processes of all PBGC’s mission-critical occupations and representation at the GS15 and SL grade level. When reviewing workforce data tables, Hispanics applied and were qualified 

for vacancies during FY 2020. However, a nexus between this red flag and organizational policies, 

procedures or practices could not be made.
49

Objective(s) and Dates for EEO Plan

Objective Date Initiated Target Date

Sufficient 

Funding & 

Staffing?

(Yes or No)

Modified Date Date Completed 

Increase the hiring of Hispanic 

males and females in PBGC 

by expanding the applicant 

pool for mission-critical 

occupations where Hispanics 

are below their benchmark’s 

representation. Work with 

management and staff to 

identify any barriers and 

develop effective strategies 

and action plans. Provide 

recommendations to 

organizational management to 

mitigate identified triggers and 

potential barriers.

October 1, 

2016

September 

30, 2023 Yes Ongoing

Responsible Official(s)

Title Name

Performance Standards 

Address the Plan? 

(Yes or No)

HRD Directors and Staff, PBGC, 

Department Directors and 

Management Team

Various Yes

OEEO Director Brenecia Watson Yes

Lead EEO Specialist Hope Fuller Yes

EEO Specialist Cynthia Searles Yes

EEO Specialist Kimberly Rodgers Yes

Management Analyst Beverley Hebron Yes

Planned Activities Toward Completion of Objective

Target Date Planned Activities Modified 

Date Completion Date 

September 30, 

2023

Continued review of the applicant pool data to 

identify trends/barriers in hiring and selection of 

Hispanic employees.

September 

30, 2020 Ongoing
50

Target Date Planned Activities Modified 

Date Completion Date 

September 30, 

2023

Continue to investigate data to identify causes 

that hinder Hispanic representation in 

comparison to the benchmark.

September 

30, 2020 Ongoing

September 30, 

2021

Continue to offer bias awareness training 

through OEEO’s YOUniversity program and the 

PBGC Diversity Council’s Inclusion Training 

program.

September 

30, 2020 Ongoing

September 30, 

2021

Hispanic Affirmative Employment Committee 

will sponsor a Brown Bag series regarding 

proactive career development.

September 

30, 2020 Ongoing

Report of Accomplishments 

Fiscal Year Accomplishments

FY 2020

OEEO presented “Daring Dialogues” series focused on discussions around 

race and ethnicity with the goal of this series to address the unseen issues 

that impact equal employment opportunity.

FY 2020

The Hispanic Affirmative Employment Committee’s commitment developed 

“The State of Hispanics in PBGC” report to identify issues that are of concern 

to PBGC’s Hispanic workforce. The report outlined perceived HR program 

deficiencies and recommendations to support equal employment opportunity 

for Hispanics.

FY 2020

OEEO presented workshops that provided career enhancing information that 

could be helpful to all demographic groups as they navigate the development 

of their careers,

FY 2020

HOLA, the Hispanic Affinity Group conducted activities to support the 

professional development of PBGC’s Hispanic workforce and to also create 

connections with the community in order to develop future interest and 

possible talent pipelines for employment at PBGC.

• HOLA-HACU Mentorship Program- Continued the HOLA-HACU 

mentorship program in which we paired the summer interns with 

HOLA members and Agency professionals based on their fields 

and career aspirations. Each HACU intern was assigned a mentor. 

For example, two interns expressed interest in pursuing law, so 

they were paired with two attorneys in OGC. In addition, a Hispanic 

Supervisory Financial Analyst also served as lead mentor for all 

interns. 

• Hispanic Legal Students Outreach – HOLA in partnership with 

Office of the General Counsel (OGC) participated in panels at 

different law schools in Puerto Rico. The panels focused on labor 

and employment law featuring local lawyers from the island as well 

as PBGC attorneys. This event was sponsored by the American 

Bar Association and PBGC.

• Leadership Speaker Series – HOLA implemented a Leadership 

Speaker Series in which Agency leaders meet with HOLA 

members to talk about career paths and share career advice.

• HOLA continues to sponsor their annual HOLA Café fundraiser 

event which served to raise cultural awareness.
51

• Annual Hispanic Heritage Month Observance event –– HOLA 

members partnered with HRD’s Special Emphasis Program to 

present a virtual program in recognition of Hispanic Heritage Month 

Program.

• HRD partnered with hiring managers to broaden targeted 

recruitment efforts to reach a diverse applicant pool.

FY 2020 Developed a survey focused on the perceptions of Hispanic women in 

PBGC workforce regarding career development opportunities.

FY 2020

Hosted a Brown Bag Flash Mentoring series focused on four of OPM’s 

Executive Core Qualifications to support women in the proactive and 

intentional development of their careers.

FY 2020

HRD continued its longstanding and robust partnership with the Hispanic 

Association of Colleges and Universities (HACU)/National Internship 

Program.

Notwithstanding the COVID-19 pandemic, PBGC continued to host HACU 

interns, virtually, throughout FY 2020, with one spring intern, six summer 

interns, and four fall interns. We have a dedicated HACU Program 

Coordinator, who coordinates a variety of developmental and enrichment 

activities for the HACU interns.

HRD continued to offer a comprehensive leadership development training 

program for managers and supervisors with courses focused on diversity, 

inclusion, and unconscious bias in the context of effective leadership 

practices.

The PBGC Diversity Council continued to offer “Be an Inclusion Agent” 

training presented during staff meetings to encourage dialogue on the 

impact of unconscious bias in the work unit.
52

MD-715 – Part I

Agency EEO Plan to Eliminate Identified Barrier

Please describe the status of each plan that the agency implemented to identify possible barriers in 

policies, procedures, or practices for employees and applicants by race, ethnicity, and gender. 

 If the agency did not conduct barrier analysis during the reporting period, please check the box.

Statement of Condition That Was a Trigger for a Potential Barrier:

Source of the 

Trigger

Specific 

Workforce 

Data Table 

Narrative Description of Trigger

Comparing grade 

representation to the

benchmarks.

A/B1

A/B3

A/B4-1

A/B4-2

PBGC’s workforce is comprised of females at a rate of 56% 

and males at a rate of 44%. In reviewing the breakdown of 

females by race and ethnicity, there is a significant decline in 

female representation for Blacks and Hispanics in grades 

GS-14, GS-15, and SL and grade SL for Asians in 

comparison to their representation rate in the total

workforce.

Benchmark GS-14 GS-15 SL

Asian 6.51% 5.81% 6.25% 2.44%

Black 29.31% 20.97% 15.97% 9.76%

Hispanic 2.52% 1.29% 2.08% 0%

White 16.70% 20.65 27.08% 31.71%

Rates for these same groups also show anomalies in senior 

and mid-level representation and are reflected in the 

following chart.

Benchmark

Executive/ 

Senior Level

Managers/MidLevel

Asian 6.51% 5.38% 4.88%

Black 29.31% 8.60% 19.51%

Hispanic 2.52% 1.61% 0%

White 16.70% 27.42% 14.63

It should also be noted that Black, White, and Hispanic

females are separating above their benchmarks at 29.47%,

20%, and 3.16% respectively.

EEO Group(s) Affected by Trigger

EEO Group

All Women –Yes. Specific attention to Asian, Black, and Hispanic females.
53

Barrier Analysis Process

Sources of Data

Source 

Reviewed?

(Yes or No)

Identify Information Collected

Workforce Data Tables Yes Female representation in grades, in major occupations,

and in manager/supervisory positions.

Complaint Data (Trends) Yes Complainant demographics, bases and Issues 

reported.

Grievance Data (Trends) No

Findings from Decisions 

(e.g., EEO) No

Climate Assessment Survey 

(e.g., FEVS) Yes

Responses to employee perceptions of the work

environment as it relates to equal employment 

opportunity.

Exit Interview Data No

Focus Groups Yes

Perceptions of females in PBGC’s workforce regarding 

career development, barriers to next grade level and 

promotional opportunities. 

Interviews No

Reports (e.g., Congress, 

EEOC, MSPB, GAO, OPM) Yes Industry practices / best practices

Other (Recruitment & 

Retention Bonus)

Yes Demographics of bonus recipients to recruit and retain 

employees.

Status of Barrier Analysis Process

Barrier Analysis Process Completed?

(Yes or No)

Barrier(s) Identified?

(Yes or No)

No, barrier analysis is ongoing. No

Statement of Identified Barrier(s)

Description of Policy, Procedure, or Practice

No barriers identified
54

Objective(s) and Dates for EEO Plan

Objective Date 

Initiated 

Target 

Date 

Sufficient 

Funding & 

Staffing?

(Yes or 

No)

Modified 

Date 

Date 

Completed 

Provide resources (trainings, 

workshops) that support women

in the proactive development of 

their careers.

06/01/2018 Ongoing Yes

Provide tools and resources to 

organizational leadership that

supports equal employment 

opportunity programs.

06/01/2018 Ongoing Yes

Advocate for career 

development programs that 

support professional 

development and growth.

05/01/2019 Ongoing Yes

Responsible Official(s)

Title Name

Performance Standards 

Address the Plan? 

(Yes or No)

HRD Directors and Staff, PBGC, 

Department Directors and 

Management Team

Various

Yes

OEEO Director Brenecia Watson Yes

Lead EEO Specialist Hope Fuller Yes

EEO Specialist Cynthia Searles Yes

EEO Specialist Kimberly Rodgers Yes

Management Analyst Beverley Hebron Yes

Planned Activities Toward Completion of Objective

Target Date Planned Activities Modified 

Date 

Completion 

Date 

April 2020

The Federal Women’s Affirmative Employment 

Committees began hosting a Brown Bag Flash 

Mentoring series focused on OPM’s Executive 

Core Qualifications to support women in the 

February 

2021.
55

Target Date Planned Activities Modified 

Date 

Completion 

Date 

proactive and intentional development of their 

careers.

September 

2021

The Federal Women’s Affirmative Employment 

Committees will sponsor a Brown Bag series 

regarding proactive career development.

Ongoing

Report of Accomplishments 

Fiscal Year Accomplishments

FY 2020

Conducted a series of focus group comprised of women in PBGC to 

gather anecdotal data and develop hypothesis on issues impacting 

women at all grade 

FY 2020

OEEO presented “Daring Dialogues” series focused on discussions 

around race and ethnicity with the goal of addressing the unseen 

issues that impact equal employment opportunity.

FY 2020

FEW members were able to attend webinars hosted by the FEW 

National Organization that included: Anatomy of the Greatest 

Collaborations, Transitioning from Manager to Leader, Building 

Influential Relationships to Propel Your Career, Coaching as a 

Management Tool and many more.

FY 2020 Developed a survey focused on the perceptions of women in PBGC 

workforce regarding career development opportunities.

FY 2020

Hosted a Brown Bag Flash Mentoring series focused on four of OPM’s 

Executive Core Qualifications to support women in the proactive and 

intentional development of their careers.

FY 2020

The PBGC Diversity Council sponsored a Senior Leader Brown Bag 

Series led by several women in Senior Leadership positions to foster 

dialogue on creating inclusion in a virtual work environment.
56

MD-715 – Part J

Special Program 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 plan will improve the recruitment, hiring, advancement, and retention of applicants and 

employees with disabilities. All agencies, regardless of size, must complete this Part of the MD-715 

report.

Please note: The triggers identified in this Part J are based solely on individual self-identification 

obtained through OPM’s Standard Form 256. We anticipate the total count of PWDs and PWTDs 

will increase and some triggers will be eliminated as additional individuals with disabilities are 

identified through the agency’s reasonable accommodations program and through appointments 

under hiring authorities that take disability into account.

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 0

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

Where there is representation in the cluster GS-01 to GS-10, PWD did not have a trigger and are reflected 

at or above the benchmark. However, in the cluster GS-11 to SL, representation rates were below the 12% 

benchmark for grades GS-13 thru SL and is reflected in the graph.

This graph shows that Persons with Disabilities are below the benchmark for representation.

PWD 12% Benchmark

GS-13 10.70%

GS-14 10.00%

GS-15 3.47%

SL 4.88%

2. Using the goal of 2% as the benchmark, does your agency have a trigger involving PWTD by 

grade level cluster in the permanent workforce? If “yes”, describe the trigger(s) in the text box.

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

b. Cluster GS-11 to SES (PWTD) Yes X No 0
57

Where there is representation, we have determined that there is not a trigger for grade level cluster 

GS-01 through GS-10. However, the triggers for grade level cluster GS-14 through SL are reflected in 

the following chart:

This graph shows that Persons with targeted Disabilities are below the benchmark for representation.

PWTD 2% Benchmark

GS-14 1.29%

GS-15 0.69%

SL 0.00%

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

recruiters.

Each year numerical goals are communicated to the Corporation’s Senior leaders at the state of the 

agency briefing. That information is also included in the annual MD-715 report which is available on 

PBGC’s intranet and the public internet.

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 the Disability Program

1. Has the agency designated sufficient qualified personnel to implement its disability program 

during the reporting period? If “no”, describe the agency’s plan to improve the staffing for the 

upcoming year.

Yes X No 0

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

Full (Name, Title, Office, Email)

Time

Part 

Time

Collateral 

Duty

Processing applications from PWD 

and PWTD 

7 0 0 Brandy Pelham, 

Supervisory HR Specialist

Answering questions from the public 

about hiring authorities that take 

disability into account

1 1 Donald Beasley

Selective Placement 

Program Coordinator HRD; 

Karen Esser Diversity and 

Inclusion Program 

Manager, HRD, 

esser.karen@pbgc.gov
58

Processing reasonable 

accommodation requests from 

applicants and employees

1 Donald Beasley

Reasonable 

Accommodation 

Coordinator

Section 508 Compliance Section 508 

Compliance 

Team, 

headed by 

the Office of 

Information 

Technology

Angela Watkins

IT Specialist and Section 

508 Compliance Team 

Chair

Architectural Barriers Act Compliance 1 Delilah LumHo

Manager, Facilities and 

Services Division

Disability Program Manager, Special 

Emphasis Program for PWD and 

PWTD

1 Denorse Prince

Special Emphasis Program 

Manager

3. Has the agency provided disability program staff with sufficient training to carry out their 

responsibilities during the reporting period? If “yes”, describe the training that disability program 

staff have received. If “no”, describe the training planned for the upcoming year.

Yes X No 0

One staff member attended NELI’s two-day training course on “ADA/COVID-19.”

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 X No 0

HRD manages a centralized budget set aside to purchase items needed as a reasonable 

accommodation. 

Section III: Plan to Recruit and Hire Individuals with Disabilities

Pursuant to 29 C.F.R. § 1614.203(d)(1)(i) and (ii), agencies must establish a plan to increase the 

recruitment and hiring of individuals with disabilities. The questions below are designed to identify 

outcomes of the agency’s recruitment program plan for PWD and PWTD. 

A. Plan to Identify Job Applicants with Disabilities

4. Describe the programs and resources the agency uses to identify job applicants with disabilities, 

including individuals with targeted disabilities. 

Selective Placement Program Coordinator (SPPC) receives inquiries from job applicants with 

disabilities, including individuals with targeted disabilities daily via email. Staffing Specialists in the 

Staffing and Classification Division receive applications from applicants with disabilities, including 

individuals with targeted disabilities, through the application process. The Staffing Specialists review 

the provided documentation and make a determination as to whether the applicant is eligible for 

veterans’ preference and/or the Schedule A hiring authority. The Staffing Specialists collaborate with 

the SPPC as necessary. 
59

5. 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. 

Selective Placement Program Coordinator (SPPC) receives inquiries from job applicants with 

disabilities, including individuals with targeted disabilities daily via email and forwards Schedule A 

letters and resumes to the agency’s Disability Program Staffing Specialist. The Staffing Specialist 

determines which hiring authorities the applicant is eligible for and whether the applicant is minimally 

qualified for the position. The Staffing Specialist then refers eligible and minimally qualified 

applicants to the Hiring Official with an explanation of how they should be considered.

6. 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. 

Selective Placement Program Coordinator (SPPC) receives inquiries from job applicants with 

disabilities, including individuals with targeted disabilities daily via email and forwards Schedule A 

letters and resumes to the agency’s Disability Program Staffing Specialist. The Staffing Specialist 

determines which hiring authorities the applicant is eligible for and whether the applicant is minimally 

qualified for the position. The Staffing Specialist then refers eligible and minimally qualified 

applicants to the Hiring Official with an explanation of how they should be considered.

7. 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 X No 0 N/A 0

Due to COVID-19, SPPC did not offer a separate training for PBGC Managers on the ABC’s of 

Schedule A Hiring as this training is typically conducted in-person. Instead, SPPC incorporated 

components from this training into a mandatory, on-line, supervisory training on Reasonable 

Accommodation. 

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. 

SPPC forwards PBGC vacancy announcements via email to numerous organizations that assist 

PWDs in securing and maintaining employment. The Staffing and Classification Division attends 

career fairs specifically targeted to disabled veterans, including veterans with targeted disabilities, to 

discuss hiring opportunities at the Agency as well as the application process and the various hiring 

authorities under which the attendees might be eligible., The Staffing and Classification Division 

accepted resumes from disabled veterans, including veterans with targeted disabilities, and 

determines which of them may be referred noncompetitively under one or more hiring authorities.

Beginning March 2020, staff did not attend in-person career fairs due to COVID-19.
60

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 0 No X

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

The sample size was limited as there were few hires in all the major occupations.

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 0 No X

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

The sample size was limited as there were few hires in all the major occupations.

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 0 No X

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

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 0 No X

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

There were no internal applications for any of the major occupations.

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

Pursuant to 29 C.F.R §1614.203(d)(1)(iii), agencies are required to provide sufficient advancement 

opportunities for employees with disabilities. Such activities might include specialized training and 

mentoring programs, career development opportunities, awards programs, promotions, and similar 

programs that address advancement. In this section, agencies should identify, and provide data on 

programs designed to ensure advancement opportunities for employees with disabilities.
61

A. Advancement Program Plan

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

advancement.

In order to increase the representation of disabled veterans in the PBGC Pathways (Student Intern) 

Program, the Staffing and Classification Division has established a hiring and retention plan for 

those individuals. 

B. Career Development Opportunities

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

employees. 

PBGC has a variety of career development programs that require supervisory approval but not 

competition, including: (1) Project Management Certification; (2) executive coaching; (3) conflict 

coaching; (4) detail opportunities; (5) Pathways and HACU internships; (6) multiple training 

opportunities for employees at all grade levels; (7) training program for new supervisors. 

The Agency has a Veterans Integration Program (VIP) that is designed to equip Federal employees 

who will be working with newly-hired veterans with the tools and skills needed to assist veterans

with their transition the federal workforce (through instructor-led and web-based training). PBGC 

continues to use career ladder promotions as a recruitment strategy to hire at the entry level with 

development, growth, and promotion potential.

9. In the table below, please provide the data for career development opportunities that require 

competition and/or supervisory recommendation/approval to participate. [Collection begins with 

the FY 2018 MD-715 report, which is due on February 28, 2019.]

Career Development 

Opportunities

Total Participants PWD PWTD

Applicants 

(#)

Selectees 

(#)

Applicants 

(%)

Selectees 

(%)

Applicants 

(%)

Selectees

(%)

Internship Programs N/A N/A N/A

Fellowship Programs N/A N/A N/A

Mentoring Programs N/A N/A N/A

Coaching Programs N/A N/A N/A

Training Programs N/A N/A N/A

Detail Programs N/A N/A N/A

Other Career 

Development Programs

N/A N/A N/A
62

Do triggers exist for PWD among the applicants and/or selectees for any of the career development 

programs? (The appropriate benchmarks are the relevant applicant pool for the applicants and the 

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

a. Applicants (PWD) Yes 0 No X

b. Selections (PWD) Yes 0 No X

Not applicable. The Agency does not have career development programs that require competition. 

10. 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 0 No X

b. Selections (PWTD) Yes 0 No X

Not applicable. The Agency does not have career development programs that require competition.

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 0 No X

2. Using the inclusion rate as the benchmark, does your agency have a trigger involving PWD 

and/or PWTD for quality step increases or performance-based pay increases? If “yes”, please 

describe the trigger(s) in the text box.

a. Pay Increases (PWD) Yes 0 No X

b. Pay Increases (PWTD) Yes 0 No X

3. If the agency has other types of employee recognition programs, are PWD and/or PWTD 

recognized disproportionately less than employees without disabilities? (The appropriate 

benchmark is the inclusion rate.) If “yes”, describe the employee recognition program and 

relevant data in the text box.

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

b. Other Types of Recognition (PWTD) Yes 0 No X
63

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 0 No X

ii. Internal Selections (PWD) Yes 0 No X

c. Grade GS-14 

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

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
64

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 0 No X

d. Grade GS-13 

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

ii. Internal Selections (PWTD) Yes 0 No X

3. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving 

PWD among the new hires to the senior grade levels? For non-GS pay plans, please use the 

approximate senior grade levels. If “yes”, describe the trigger(s) in the text box.

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 0 No X

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

4. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving 

PWTD among the new hires to the senior grade levels? For non-GS pay plans, please use the 

approximate senior grade levels. If “yes”, describe the trigger(s) in the text box.

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 0 No X

d. New Hires to GS-13 (PWTD) Yes 0 No X
65

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 0 No X

ii. Internal Selections (PWD) Yes 0 No X

b. Managers

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

ii. Internal Selections (PWD) Yes 0 No X

c. Supervisors 

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

ii. Internal Selections (PWD) Yes 0 No X

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 0 No X

ii. Internal Selections (PWTD) Yes 0 No X

b. Managers

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

ii. Internal Selections (PWTD) Yes 0 No X

c. Supervisors 

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

ii. Internal Selections (PWTD) Yes 0 No X
66

7. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving 

PWD among the selectees for new hires to supervisory positions? If “yes”, describe the trigger(s) 

in the text box.

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

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

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

8. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving 

PWTD among the selectees for new hires to supervisory positions? If “yes”, describe the 

trigger(s) in the text box.

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

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

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

Section V: 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 X No 0 N/A 0

The Agency did convert all Schedule A employees into the competitive service.

2. Using the inclusion rate as the benchmark, did the percentage of PWD among voluntary and 

involuntary separations exceed that of persons without disabilities? If “yes”, describe the trigger 

below.

a. Voluntary Separations (PWD) Yes 0 No X

b. Involuntary Separations (PWD) Yes 0 No X
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3. Using the inclusion rate as the benchmark, did the percentage of PWTD among voluntary and 

involuntary separations exceed that of persons without targeted disabilities? If “yes”, describe 

the trigger below.

Voluntary Separations (PWTD) Yes 0 No X

Involuntary Separations (PWTD) Yes 0 No X

4. If a trigger exists involving the separation rate of PWD and/or PWTD, please explain why they 

left the agency using exit interview results and other data sources.

Not Applicable

B. Accessibility of Technology and Facilities

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

employees of their rights under Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. § 794(b), 

concerning the accessibility of agency technology, and the Architectural Barriers Act of 1968 (42 U.S.C. 

§ 4151-4157), concerning the accessibility of agency facilities. In addition, agencies are required to 

inform individuals where to file complaints if other agencies are responsible for a violation. 

1. Please provide the internet address on the agency’s public website for its notice explaining 

employees’ and applicants’ rights under Section 508 of the Rehabilitation Act, including a 

description of how to file a complaint. 

Anyone with an accessibility issue related to navigating the pbgc.gov site should contact 

the webmaster@pbgc.gov (per The PBGC Website Policies and Procedures and the 

Accessibility section).

In compliance with Section 508 of the Rehabilitation Act (link is external), PBGC is 

committed to providing access to its Web pages to all people-disabled or not-seeking 

information about PBGC. According to its policies for accessibility (link is external), 

the agency shall take appropriate steps to ensure effective communication with 

applicants, participants, personnel of other Federal entities, and members of the 

public.

If you use assistive technology (such as a Braille reader, a screen reader, or TTY) 

and the format of any material on this Web site interferes with your ability to access 

information, please contact the PBGC Webmaster atwebmaster@pbgc.gov (link 

sends e-mail) or 202-326-4343. To enable us to respond in a manner most helpful to 

you, please indicate the nature of your accessibility problem, the preferred format in 

which to receive the material, the Web address of the requested material, and your 

contact information. Users who need accessibility assistance can also contact us by 

phone through the Federal Information Relay Service at 1-800-400-7242 for 

TTY/Voice communication.
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2. Please provide the internet address on the agency’s public website for its notice explaining 

employees’ and applicants’ rights under the Architectural Barriers Act, including a description of 

how to file a complaint.

https://www.pbgc.gov/about/pg/footer/aba

3. Describe any programs, policies, or practices that the agency has undertaken, or plans on 

undertaking over the next fiscal year, designed to improve accessibility of agency facilities 

and/or technology.

PBGC continues ensure access to the building for people with disabilities.

In FY20, the Agency’s Section 508 Compliance Team conducted training sessions across the Agency 

to raise awareness of Section 508 responsibilities and also introduced a new “Acclimate to Section 

508 Learning Series” that provided hands-on instruction on how to make Word documents accessible 

to People with Disabilities. This series will continue in FY 2021. 

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.)

30 days

2. Describe the effectiveness of the policies, procedures, or practices to implement the agency’s 

reasonable accommodation program. Some examples of an effective program include timely 

processing requests, timely providing approved accommodations, conducting training for 

managers and supervisors, and monitoring accommodation requests for trends.

(1) PBGC effectively operates a Reasonable Accommodation Program for qualified individuals with 

disabilities, including having a centralized reasonable accommodation fund and designated 

Reasonable Accommodation Coordinator; 

(2) During FY 2020, PBGC received and timely processed 54 reasonable accommodation requests.

(3) PBGC actively collaborates with the Computer/Electronic Accommodations Program (CAP) and 

the Job Accommodations Network (JAN); 

(4) PBGC ensures easy access and availability of interpreter services for applicants and employees 

who are deaf or hard of hearing through continued operation of its Interpreter Services Program; 

(5) PBGC highlights disability topics through a Disability Awareness Series, with speakers, 

information and articles in the PBGC newsletter; 

(6) PBGC includes information about the Workforce Recruitment Program, Diversity and Inclusion, 

Special Emphasis Observances, and the Reasonable Accommodation Program on its HRD intranet 

webpage; 
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(7) PBGC maintains a videophone in its lobby to accommodate deaf and hard of hearing visitors; 

(8) PBGC has an annual mandatory reasonable accommodation and Diversity & Inclusion training 

requirement for all supervisors and managers and hosted and delivered multiple training sessions in 

these areas; 

(9) The HRD Reasonable Accommodation brochure is provided to all employees during New 

Employee Orientation (NEO) and the PBGC Reasonable Accommodation Coordinator provides a 

briefing to all new employees during NEO on reasonable accommodation procedures. In addition, 

the information is available on the intranet via the Employee and Labor Relations Management 

Division (ELRMD) link entitled “Reasonable Accommodations” at:

http://intranet/human_resources/emp_labor_relations/accommodations.cfm

and on the internet at:

http://www.pbgc.gov/documents/reasonable_accom.pdf

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

Pursuant to 29 C.F.R. § 1614.203(d)(5), federal agencies, as an aspect of affirmative action, are 

required to provide personal assistance services (PAS) to employees who need them because of a 

targeted disability, unless doing so would impose an undue hardship on the agency. 

Describe the effectiveness of the policies, procedures, or practices to implement the PAS 

requirement. Some examples of an effective program include timely processing requests for PAS, 

timely providing approved services, conducting training for managers and supervisors, and 

monitoring PAS requests for trends.

The PAS policy is included in the Reasonable Accommodations Policy. Both were approved by 

EEOC in FY 19 and are posted on PBGC’s Intranet. PAS training will be incorporated into the 

mandatory RA training for supervisors beginning in FY21.

Section VI: 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 0 No X N/A 0

3. If the agency had one or more findings of discrimination alleging harassment based on disability 

status during the last fiscal year, please describe the corrective measures taken by the agency.

Not Applicable due to no findings.
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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 X N/A 0

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 0 No X N/A 0

3. If the agency had one or more findings of discrimination involving the failure to provide a 

reasonable accommodation during the last fiscal year, please describe the corrective measures 

taken by the agency.

Not Applicable due to no findings.

Section VII: Identification and Removal of Barriers

Element D of MD-715 requires agencies to conduct a barrier analysis when a trigger suggests that a 

policy, procedure, or practice may be impeding the employment opportunities of a protected EEO group.

1. Has the agency identified any barriers (policies, procedures, and/or practices) that affect 

employment opportunities for PWD and/or PWTD? 

Yes 0 No X

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

Yes 0 No 0 N/A X

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

While there may be a trigger in terms of representation, most of the sample sizes are 

too small to determine if there were barriers. However, as we continue to conduct 

barrier analysis, we will continue to look for issues that limit equal employment 

opportunity for PWD and PWTD.

Barrier(s) Not Identified

Objective(s) To increase representation in PBGC of PWDs and PWTDs. 

Responsible Official(s)

Performance Standards Address the 

Plan?

(Yes or No)

HRD, OEEO, Agency leadership No

Barrier Analysis Process Completed?

(Yes or No)

Barrier(s) Identified?

(Yes or No)

Ongoing No

Sources of Data

Sources 

Reviewed?

(Yes or No)

Identify Information Collected
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Workforce Data Tables Yes Representation Rates of PWD and PWTD in 

major occupations and grades.

Complaint Data (Trends) Yes Complainant demographics, bases and 

Issues reported.

Grievance Data (Trends) No

Findings from Decisions (e.g., EEO, 

Grievance, MSPB, Anti-Harassment 

Processes) 

No

Climate Assessment Survey (e.g., FEVS) Yes Employee Perceptions

Exit Interview Data No

Focus Groups Yes

Perceptions of females with disabilities in 

PBGC’s workforce regarding career 

development, barriers to next grade level 

and promotional opportunities

Interviews No

Reports (e.g., Congress, EEOC, MSPB, 

GAO, OPM) Yes EEOC data on disability findings, OPM, andindustry practices / best practices.

Other (Please Describe)

Target Date Planned Activities Sufficient 

Staffing & 

Funding

(Yes or No)

Modified 

Date

Completion 

Date

Ongoing HRD will continue to train and educate 

on disability topics, including mandatory 

RA training for managers and 

supervisors. 

Yes

Ongoing The agency will continue to operate a 

robust inter-departmental Section 508 

Compliance Team and offer hands-on 

Section 508 accessibility training to all 

employees.

Yes

FY 2022 OEEO will explore how it can also 

provide programs for PWD and PWTD.

Yes 09/30/20 Efforts are 

ongoing

Fiscal Year Accomplishments

FY 2020 The disability functions are managed by the Human Resources Department (HRD) and 

it continues to provide relevant trainings on topics that enhance equal employment 

opportunity for Persons with Disabilities and Targeted Disabilities. HRD maintains a 

robust Disabled Veterans Affirmative Action program (DVAAP) and in FY 2020, the 

agency hired more disabled veterans in any single fiscal year since FY 2011, when this 

data started being tracked. As of the end of FY 2020, disabled veterans represented 

3.3% of the agency’s FTE workforce.

FY 2020 The Office of Equal Employment Opportunity’s (OEEO) Disability Affirmative 

Employment Committee (DAEC) continued to support efforts that promote the equal 

employment opportunity of persons with disabilities and persons with targeted 

disabilities.

FY 2020 The Disability Affirmative Employment Committee developed a report on the Status of 

persons With Disabilities in PBGC. The report will be briefed to the Agency head in FY 

2021.
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4. Please explain the factor(s) that prevented the agency from timely completing any of the 

planned activities.

The Agency has not identified any barriers. However, because barrier analysis is ongoing, the 

specific task identified was extended.

5. For the planned activities that were completed, please describe the actual impact of those 

activities toward eliminating the barrier(s).

DAEC has created a strategic plan that supports the Agency’s goal of retaining and recruiting PWDs 

and PWTDs. Planned activities include collaborating with HRD to participate in university recruitment 

fairs and leveraging current career enhancing programs, such as WRP.

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. 

Activities to improve ongoing efforts include collaboration with Disability Program Manager.
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Appendix