1

Management Directive 715

Annual EEO Program Status Report

Fiscal Year 2021
2 

Pension Benefit Guaranty Corporation

FY 2021 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 ................................................................................................. 6-8 

Workforce Analysis..............................................................................................9-16

PART F: Certification-Establishment of Continuing Equal Employment Opportunity............... 17

PART G: Agency Self-Assessment Checklist Measuring Essential Elements. ................... 18-42

PBGC Annual Assessment...................................................................................43-45

PART I: EEO Plan to Eliminate Identified Barriers......................................................46-55 

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

Retention of Persons with Disabilities......................................................................56-71 

APPENDIX:

Fiscal Year 2021 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 901 48 949

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

Denorse 

Prince 

Human 

Resources

Specialist

201 GS-11 202-229-4026 prince.denorse@pbgc.gov 
4

EEO Program Staff Name Title Occupational 

Series

Pay 

Plan 

and 

Grade

Phone 

Number Email Address

Hispanic Affirmative 

Employment

Committee Chair

Kimberly 

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

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-13 202-229-3405 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

Wendy 

Lawrence

Employee and 

Labor 

Relations 

Specialist

201 GS-14 202-229-3142 Lawrence.Avious@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 No Not Required

Disabled Veterans Affirmative Action Program (DVAAP) Report No Not Required

Operational Plan for Increasing Employment of Individuals with Disabilities 

under Executive Order 13548 No Not Required

Diversity and Inclusion Plan under Executive Order 13583 No Not Required

Diversity Policy Statement No Not Required

Human Capital Strategic Plan No Not Required

EEO Strategic Plan No Not Required

Results from most recent Federal Employee Viewpoint Survey or Annual 

Employee Survey No Not Required
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, 2020 to September 30, 2021

EXECUTIVE SUMMARY

E.1: Mission

The Pension Benefit Guaranty Corporation (PBGC or Agency) protects the retirement income of over 33 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 2021, PBGC assumed responsibility for 47 single-employer plans that provided benefits to nearly 34,000 

participants in newly trusteed plans and paid over $6.4 billion to nearly 970,000 retirees. More than 40,000 retirees 

continued to receive benefits without interruption from PBGC. In FY 2021, PBGC provided $230 million in financial 

assistance to 109 multiemployer plans covering 80,786 participants receiving guaranteed benefits.

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 fiscal year FY 2021 and 

covers the period from October 1, 2020, through September 30, 2021. 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 2021 in developing an equitable work environment and its plans for enhancing 

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

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 Equity Inclusion and Accessibility Council sponsored a Community Day titled “Pension 

Hidden Figures. 

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

Learning Series courses throughout the year.

• In FY 2021, Office of Policy and External Affairs (OPEA) continued targeted recruitment outreach for 

underrepresented groups by establishing contacts w/ PBGC’s affinity groups (i.e. FEW, BIG etc.) and 

other external organizations that target underrepresented communities in order to advertise vacancy 

announcements and develop strategic communications for the relevant organizations/publications for 

relevant positions and potential applicants. In its regular work, COLA supports all Special Emphasis 

Program activities and handles special recruiting initiatives in collaboration with the Human Resources 

Department through LinkedIn.

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

career ladder position which is promotable to GS-13 grade level.

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

that will allow recruitment of recent graduates at the GS-07/09 grade level with career ladders to GS-13. 

Additionally, OBA continued to work with HRD to recruit and hire 3 schedule A candidates for career ladder 

positions. 

• Office of Negotiations and Restructuring (ONR) enhanced developmental opportunities by offering technical 

skills training to develop performance of staff, and soft skills training to enhance communication skills. In 

addition, actuaries continued to have extensive professional education opportunities including webinars 

conducted by the Society of Actuaries, the Conference of Consulting Actuaries, and the American Academy 

of Actuaries. In FY 2021, ONR onboarded 1 Hispanic female and 3 Black male external hires as well as one 

special appointing authority individual.
8

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

recruitment strategies targeted at underrepresented groups.

• Office of The Chief Financial Officer (OCFO) continued to work with HRD to hire persons with targeted 

disabilities through Schedule A appointing authority. 

• In FY 2021, the Office of the General counsel (OGC) diversity outreach efforts included recruitment of four 

females for the summer law clerk program. All four accepted offers of permanent employment at the end of 

the program. In addition, OGC made eight hires in FY 2021. Of these hires, sixty-six percent were Women, 

thirty-eight percent were Black or African American and twenty-five percent were disabled veterans. OGC 

enhanced developmental opportunities by promoting a Mexican American to Assistant General Counsel.

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. 
9 

Workforce Analysis

During the FY 2021 reporting period, PBGC had a total of 949 temporary and permanent employees, a net 

change of -0.32% from the 952 employees during the previous year. The total female workforce

representation was 56.38% which is above the CLF representation rate of 48.16%. Male employees 

represented 43.62% of the total workforce, below the CLF representation rate of 51.84%. The total 

representation rates for male and female employees remained consistent over the previous 3-year 

percentage rates. While there were modest increases and decreased in demographic groups, 

representation remained relatively close to FY 2020 representation rates.

Graph 1.

Graph 2. 

Representation by Gender

Male

Employees

Female

Employees

6.01%

11.91%

0.11% 1.90% 0.00%

23.29%

0.42%

6.85%

28.98%

0.11%

2.32%

0.00%

16.86%

1.26%

Asian AA/Black AIAN Hispanic NHPI White Two+

Representation by Race, Ethnicity, & Gender

Male Female
10 

MAJOR OCCUPATION CATEGORIES

PBGC’s major occupations include Accountant (Series 0510), Auditor (Series 0511), General Attorney 

(Series 0905), Employee Benefits Law Specialist (Series 0958), Contract Specialist (Series 1102), 

Financial Analyst (Series 1160), Actuary (Series 1510), and Information Technology Specialist (Series 

2210). These occupations represent a significant portion of the PBGC workforce and also indicate 

occupations that typically lead to senior level occupational categories and grade representation. The 

following graphs represent PBGC’s workforce demographics that occupy the major occupations. The data 

in red text indicate that the demographic is below the benchmark’s rate of representation. It may also 

indicate a glass wall effect, when people within a specific demographic group are unable to obtain 

employment in major occupations within the agency. It should also be noted that a specific demographics

under representation does not always mean that a barrier may exist. Likewise, specific demographics over 

representation does not always mean that equal employment opportunity exists at all levels. 

Asian Male Major Occupation Representation 

Major Occupation FY21 OCLF 

Benchmark

FY 2021 PBGC 

Representation

FY20 OCLF 

Benchmark

FY 2020 PBGC 

Representation

Accounting (0510) 3.70% 8.77% 3.06% 12.07%

Auditing (0511) 3.70% 7.38% 3.06% 7.38%

General Attorney (0905) 2.10% 1.06% 1.82% 0.00%

Employee Benefit Law Specialist (0958) 1.30% 4.17% 1.64% 4.00%

Contract Specialist (1102) 2.40% 0.00% 1.38% 0.00%

Financial Analyst (1160) 7.70% 2.13% 6.14% 4.26%

Actuary Science (1510) 7.10% 11.70% 4.06% 11.22%

Information Technology Specialist 

(2210) 10.80% 17.27% 5.14% 17.14%

Asian Female Major Occupation Representation

Major Occupation FY21 OCLF 

Benchmark

FY 2021 PBGC 

Representation

FY20 OCLF 

Benchmark

FY 2020 PBGC 

Representation

Accounting (0510) 7.10% 10.53% 5.49% 8.62%

Auditing (0511) 7.10% 9.84% 5.49% 9.02%

General Attorney (0905) 2.40% 8.51% 1.74% 8.60%

Employee Benefit Law Specialist (0958) 2.60% 4.17% 2.24% 4.00%

Contract Specialist (1102) 3.10% 5.26% 1.77% 0.00%

Financial Analyst (1160) 6.80% 4.26% 4.40% 4.26%

Actuary Science (1510) 7.50% 10.64% 3.91% 10.20%

Information Technology Specialist 

(2210) 3.30% 7.27% 1.55% 7.62%
11

Black or African American Male Major Occupation Representation

Black or African American Female Major Occupation Representation

Major Occupation FY21 OCLF 

Benchmark

FY 2021 PBGC 

Representation

FY20 OCLF 

Benchmark

FY 2020 

PBGC 

Representati

on

Accounting (0510) 5.70% 33.00% 5.7% 33.00%

Auditing (0511) 5.70% 33.60% 5.7% 35.80%

General Attorney (0905) 3.00% 10.60% 2.6% 10.60%

Employee Benefit Law Specialist (0958) 6.50% 58.00% 7.4% 56.00%

Contract Specialist (1102) 5.10% 21.05% 5.5% 22.00%

Financial Analyst (1160) 4.00% 12.80% 4.0% 10.60%

Actuary Science (1510) 5.40% 8.50% 1.2% 9.00%

Information Technology Specialist 

(2210) 2.30% 20.90% 4.5% 21.50%

Hispanic or Latino Male Major Occupation Representation

Major Occupation FY21 OCLF 

Benchmark

FY 2021 PBGC 

Representation

FY20 OCLF 

Benchmark

FY 2020 PBGC 

Representation

Accounting (0510) 2.90% 0.00% 2.19% 0.00%

Auditing (0511) 2.90% 0.00% 2.19% 0.00%

General Attorney (0905) 3.20% 1.06% 2.52% 1.06%

Employee Benefit Law Specialist 

(0958) 3.00% 0.00% 2.05% 0.00%

Contract Specialist (1102) 4.70% 5.26% 3.29% 0.00%

Financial Analyst (1160) 3.90% 2.13% 3.10% 2.13%

Actuary Science (1510) 3.50% 4.26% 1.30% 5.00%

Information Technology Specialist 

(2210) 4.70% 2.73% 5.39% 2.80%

Hispanic or Latino Female Major Occupation Representation

Major Occupation FY21 OCLF 

Benchmark

FY 2021 PBGC 

Representation

FY20 OCLF 

Benchmark

FY 2020 PBGC 

Representation

Accounting (0510) 2.8% 15.8% 2.5% 15.8%

Auditing (0511) 2.8% 17.2% 2.5% 17.5%

General Attorney (0905) 2.3% 1.1% 2.1% 0.0%

Employee Benefit Law Specialist 

(0958) 1.9% 20.8% 2.7% 20.0%

Contract Specialist (1102) 3.3% 5.3% 3.0% 22.2%

Financial Analyst (1160) 3.5% 25.5% 3.6% 21.3%

Actuary Science (1510) 3.8% 9.6% 1.2% 10.0%

Information Technology 

Specialist (2210) 3.4% 12.7% 6.6% 12.1%
12 

Major Occupation FY21 OCLF 

Benchmark

FY 2021 PBGC 

Representation

FY20 OCLF 

Benchmark

FY 2020 PBGC 

Representation

Accounting (0510) 5.30% 0.00% 3.93% 0.00%

Auditing (0511) 5.30% 4.92% 3.93% 5.00%

General Attorney (0905) 2.60% 1.06% 1.85% 1.06%

Employee Benefit Law Specialist 

(0958) 11.20% 0.00% 7.35% 0.00%

Contract Specialist (1102) 4.90% 0.00% 3.80% 0.00%

Financial Analyst (1160) 3.40% 0.00% 1.97% 0.00%

Actuary Science (1510) 3.40% 0.00% 56.00% 0.00%

Information Technology Specialist 

(2210) 1.60% 0.00% 2.17% 0.00%

 

White Male Major Occupation Representation

Major Occupation FY21 OCLF 

Benchmark

FY 2021 PBGC 

Representation

FY20 OCLF 

Benchmark

FY 2020 PBGC 

Representation

Accounting (0510) 28.80% 21.05% 31.79% 21.05%

Auditing (0511) 28.80% 13.93% 31.79% 12.50%

General Attorney (0905) 54.10% 37.23% 59.68% 39.36%

Employee Benefit Law Specialist 

(0958) 12.90% 12.50% 19.18% 12.00%

Contract Specialist (1102) 36.10% 15.79% 38.09% 15.79%

Financial Analyst (1160) 43.80% 34.04% 53.98% 36.17%

Actuary Science (1510) 37.80% 41.49% 60.44% 39.80%

Information Technology Specialist 

(2210) 51.40% 29.09% 52.21% 29.52%

White Female Major Occupation Representation

Major Occupation FY21 OCLF 

Benchmark

FY 2021 PBGC 

Representation

FY20 OCLF 

Benchmark

FY 2020 PBGC 

Representation

Accounting (0510) 41.50% 8.77% 44.23% 8.77%

Auditing (0511) 41.50% 10.7% 44.23% 11.67%

General Attorney (0905) 28.30% 39.4% 26.68% 39.36%

Employee Benefit Law Specialist 

(0958) 57.80% 0.00% 55.67% 4.00%

Contract Specialist (1102) 38.30% 42.1% 41.87% 38.89%

Financial Analyst (1160) 24.80% 19.2% 22.01% 21.28%

Actuary Science (1510) 28.70% 13.83 27.01% 14.00%

Information Technology Specialist 

(2210) 20.20% 8.18% 20.89% 7.48% 

Workforce demographics not reflected in a chart are at or above parity with the benchmark. The Office of 

Equal Employment Opportunity will continue to collaborate with PBGC’s department leaders, Human 

Resources, and other stakeholders to develop programs that support equal employment opportunity. 

OCCUPATIONAL CATEGORIES
13 

Total Officials and Managers Representation

The Officials and Managers occupational categories, includes Executives, Managers, and Supervisors. 

These are the employees who may either create or implement strategies and plans for a department, a 

division, or the entire organization. According to current EEOC guidelines, executives comprise grades 

GS-15 to Senior Leader (SL) positions. Managers are typically GS-13 and GS-14, while supervisors would 

be GS-12 and below. The benchmark for this category is PBGC’s permanent workforce. An analysis of 

PBGC’s workforce demographics data was conducted and confirmed that a glass ceiling effect - when 

specific demographics encounter potential barriers reaching executive level leadership positions, despite 

their presence in positions that comprise the feeder pool for this category, does exist.

Graph 3 

Total Professional Representation

The Professionals occupational category typically requires either college graduation or experience of 

such kind and amount as to provide a comparable background. This category includes roles like, 

accountants, actuaries, auditors, attorneys, and personnel and labor relations specialists. The benchmark 

for this category is PBGC’s permanent workforce. An analysis of PBGC’s workforce demographics data 

was conducted and confirmed that a blocked pipeline effect – when specific demographics are in 

upwardly mobile occupations but fail to reach the senior grade levels within those occupations, does exist.

Graph 4.

Total Administrative Support Workers Representation

12.86%

40.89%

0.22%

4.22%

0.00%

40.15%

1.68%

10.13%

25.55%

0.00% 2.20%

0.00%

61.67%

0.44%

Asian AA or Black AIAN Hispanic or

Latino

NHPI White Two+

Total Officials and Managers

Occupational Category Representation By Race/Ethnicity

Total Workforce E-M-S Occupational Category

12.29%

41.39%

0.22% 4.52%

0.00%

40.12%

1.68%

13.98%

44.05%

0.32%

4.82% 0.00%

35.05%

1.77%

Asian AA or Black AIAN Hispanic or

Latino

NHPI White Two +

Total Workforce & Professional 

Occupational Category Representation By Race/Ethnicity

Total Workforce Professional Occupational Category
14 

The Administrative Support Workers occupational category includes all clerical-type work regard-less 

of level of difficulty. This category includes roles like, administrative officers and employee benefits law 

specialist. The benchmark for this category is PBGC’s permanent workforce. An analysis of PBGC’s 

workforce demographics data was conducted to assess notable data in this occupational category by race

and ethnicity.

Graph 5.

The following charts identify the specific demographic by race, ethnicity, and gender. Changes to the 

workforce over a two-year period are also reflected. Workforce demographics not reflected in a chart are 

at or above parity with the benchmark.

Asian Male Occupational Category FY2021 FY2020

Officials & Managers 3.96% 4.88%

Professionals 6.75% 6.43%

Administrative Support 4.08% 3.57%

Asian Female Occupational Category FY2021 FY2020

Officials & Managers 6.17% 4.88%

Professionals 7.23% 7.23%

Administrative Support 6.12% 5.36%

12.29%

41.39%

0.22%

4.52%

0.00%

40.12%

10.20% 1.68%

77.55%

0.00% 2.04%

0.00% 10.20%

0.00%

Asian AA or Black AIAN Hispanic or

Latino

NHPI White Two+

Total Workforce & Administrative Support 

Occupational Category Representation By Race/Ethnicity

Total Workforce Administrative Support
15 

Black or African American Male

Occupational Category FY2021 FY2020

Officials & Managers 10% 19.51%

Professionals 12.54% 11.74%

Administrative Support 16.3% 12.5%

Black or African American Female

Occupational Category FY2021 FY2020

Officials & Managers 15.4% 19.51%

Professionals 31.5% 32%

Administrative Support 61.2% 55.4%

Hispanic Male Occupational Category FY2021 FY2020

Officials & Managers 1% 1.08%

Professionals 2.09% 2.09%

Administrative Support 2.04% 1.79%

Hispanic Female Occupational Category FY2021 FY2020

Officials & Managers 1.32% 1.61%

Professionals 2.73% 2.9%

Administrative Support 0% 0%

White Male Occupational Category FY2021 FY2020

Officials & Managers 35.7% 34.15%

Professionals 20.42% 20.42%

Administrative Support 6.12% 12.50%

White Female Occupational Category FY2021 FY2020

Officials & Managers 26% 14.63%

Professionals 14.63% 14.95%

Administrative Support 4.08% 5.36%

It should be noted that there was a decrease of 51% for Black or African American males in the Official & 

Managers category. The Office of Equal Employment Opportunity will continue to conduct analysis to 

identify policies, practices, and procedures that may impact such significant demographic changes. OEEO 

will also continue to collaborate with PBGC’s department leaders, Human Resources, and other 

stakeholders to develop programs that support equal employment opportunity.

GS-13 THRU SL GRADE REPRESENTATION
16 

Grade representation continues to be an area for continue focus. Gaps in participation rates for specific

demographics at GS-14 thru SL grade levels require ongoing analysis to identify whether, or to what 

extent barriers may exist at the various grade levels.

Asian Male & Female

Grade Representation

Asian Males 

2021

Asian Males 

2020

Asian Females 

2021

Asian Females 

2020

PBGC Benchmark 1.97% 1.97% 1.93% 1.93%

SL 2.70% 2.44% 2.70% 2.44%

GS-15 4.05% 4.86% 7.43% 6.25%

GS-14 5.86% 5.81% 6.19% 5.81%

GS-13 7.42% 7.14% 6.55% 8.04%

Black or African American 

Grade Representation 

Black or AA 

Males 2021

Black or AA 

Males 2020

Black or AA 

Females 2021

Black or AA 

Females 2020

PBGC Benchmark 11.9% 12.1% 29.0% 29.3%

SL 8.1% 7.3% 8.1% 16.0%

GS-15 7.4% 9.0% 15.5% 16.0%

GS-14 12.4% 11.6% 20.2% 21.0%

GS-13 15.7% 13.8% 39.7% 37.5%

Hispanic Grade Representation Hispanic Male 

2021

Hispanic Male 

2020

Hispanic 

Female 2021

Hispanic Female 

2020

PBGC Benchmark 1.9% 2.0% 2.3% 2.5%

SL 0.0% 0.0% 0.0% 0.0%

GS-15 1.4% 1.4% 2.0% 2.1%

GS-14 2.0% 1.6% 1.0% 1.3%

GS-13 1.8% 2.2% 3.5% 2.7%

White Male & Female 

Grade Representation

White Males 

2021

White Males 

2020

White Females 

2021

White Females 

2020

PBGC Benchmark 23.29% 23.42% 16.86% 16.7%

SL 45.95% 46.34% 32.43% 31.71%

GS-15 35.14% 33.33% 27.03% 27.08%

GS-14 30.29% 30.97% 20.85% 20.65% 

GS-13 15.72% 16.52% 7.42% 9.38%
17 

EEOC FORM

715-01 

PART F

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.

Brenecia Watson 05/20/2022

Signature of Principal EEO Director/Official

Certifies that this Federal Agency Annual EEO Program Status Report 

is in compliance with EEO MD-715.

Date

5/31/2022

Signature of Agency Head or Agency Head Designee Date
18

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.
19 

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)

July 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, 2021 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: 
20 

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 Antiharassment Policy brochure, 

the current OEEO Prevention 

of Workplace Harassment 

Policy Statement and the 

Equal Employment 

Opportunity Policy Statement 
21 

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 on 

HRD’s 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
22 

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 June 30, 2021 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
23 

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)]

No These tasks are 

conducted at the 

organization level. The 

EEO Director does not 

participate in 

recruitment strategies, 

vacancy projections, 

succession planning, 

and selections for 

training/career 

development 

opportunities for the 

organizations.

B.2.c & 

B.2.d
24 

B.3.b Does the agency’s current 

strategic plan reference EEO / 

diversity and inclusion 

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

If “yes”, please identify the EEO 

principles in the strategic plan in 

the comments column.

Yes PBGC Strategic Goal 3: 

Maintain High Standards

of Stewardship and 

Accountability: Encourage 

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 

NA E.1.c
25 

EEO programs in components

and the field offices, if 

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 

Yes E.2.d
26 

employees, receive the required 

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
27 

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 2021, action 

plans were maintained 

and continued to be 

implemented. We will

continue to measure 

results in 2022. 

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
28 

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. Dept of 

Veterans Affairs, EEOC Appeal 

No. 0120123232 (May 21, 

2015); Complainant v. Dept 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
29 

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
30 

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
31 

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
32 

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.
33 

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
34 

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
35 

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

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

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.gov

/sites/default/files/fy2

020-md715-

report.pdf
36 

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.
37 

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
38 

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)]

NA

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 OEEO has an 

attorney Advisor on 

staff. 

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)]

NA

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 

NA E.6.c
39 

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
40 

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, gathers 

information from public 

entities regarding their 

best practices and 

seeks to implement 

relevant best practices

when identified and 

appropriate. 

E.5.g

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
41 

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 

forward the investigative file to 

the appropriate EEOC hearing 

office? [see 29 CFR 

§1614.108(g)]

Yes E.3.a.5
42 

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
43 

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. The following chart reflects the percentage met for each 

essential element of a model EEO program over the past three fiscal years:

Element

FY 2021 FY 2020 FY 2019

Number of 

Deficiencies Percentage

Number of 

Deficiencies Percentage

Number of 

Deficiencies Percentage

A - Demonstrated Leadership 

Commitment 0 100% 0 100% 0 100%

B - Integration of EEO in 

Strategic Mission 1 97% 0 100% 0 100%

C - Management & Program 

Accountability 0 100% 0 100% 0 100%

D - Proactive Discrimination 

Prevention 0 100% 0 100% 0 100%

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

F - Responsive & Legal 

Compliance 0 100% 0 100% 0 100%

Summary Score 99.5% 100.0% 99.5%

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.

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.
44 

• Dissemination of information about PBGC’s Diversity Equity Inclusion and Accessibility 

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 Equity 

Inclusion and Accessibility Council to sponsor a Community Day titled Pension Hidden 

Figures.

• Agency staff participated in the various Affirmative Employment Committees.

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 2021.

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

recruitment, hiring, separations, and 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 

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 2021, the Office of the General Counsel and the Human Resources 

Department jointly evaluated 7 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. HRD delivered virtual training 

sessions in these areas in FY 2021. 

• The Agency’s Reasonable Accommodations Coordinator briefed all new employees on 

reasonable accommodation procedures during New Employee Orientation. 

• The Agency’s Section 508 Compliance Team conducted training sessions throughout 

the year available to all employees.

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, intranet content, all PBGC emails, and policy statements. 
45 

• 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 by participating in programs that 

support equal employment opportunity.

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 2021, ADR was offered 16 times to 9 individuals and rejected 12 times by 7 

individuals.

• PBGC received and processed 9 formal complaints alleging employment discrimination 

in FY 2021.

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.

• For FY 2021 PBGC received and processed 9 formal complaints alleging employment 

discrimination

• The Agency successfully processed 18 informal complaints within regulatory 

timeframes (including ADR and written extensions)

• The following reflects PBGC’s formal complaint activity in FY 2021. 

o 9 formal complaints were filed in FY 2021. 

o 14 Complaints were closed during FY 2021. 

o Agency issued all FADs timely.

o Investigations were completed within a completion time of 136 days; well below 

the 180-day requirement. 
46 

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 2021 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 2021, Hispanics males continued to

occupy 2, or 1.35% of Grades GS-15 or above, and Hispanic females 

continued to occupy 3, or 2.03% of Grades GS-15 or above. Both 

percentages are below the benchmark identified in the chart above.

Hispanics had a total separation rate of 3.26% for males, which is 

higher than their representation in the agency. Females separated at 

a total rate 2.17% , which is at parity with their representation in 

PBGC’s workforce.

Males Females Total

PBGC 1.90% 2.32% 4.22%

NCLF 6.8% 6.2% 13%

 
47

EEO Group(s) Affected by Trigger

EEO Group

Hispanic or Latino Males - YES

Hispanic or Latino Females - YES

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) Yes

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)

No. Efforts are ongoing. No
48

Statement of Identified Barrier(s)

Description of Policy, Procedure, or Practice

A workforce data analysis has not identified a PBGC policy, practice, procedure, or condition that 

identifies any barrier that exist for Hispanic employees in the hiring/selections processes of all

PBGC’s mission-critical occupations and representation at the GS-15 and SL grade level. When 

reviewing workforce data tables, Hispanics applied and were qualified for vacancies during FY 2021.

However, a nexus between this red flag and organizational policies, procedures or practices could not 

be made.

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 

for occupational categories, 

mission-critical occupations, 

and GS-15-SL grade

representation where 

Hispanics are below their 

benchmark’s representation.

Work with management and 

staff to investigate red flags 

and develop effective 

strategies and action plans. 

Provide recommendations to 

organizational management to 

mitigate identified red flags

before they become barriers.

October 1, 

2016

September 

30, 2025

Yes October 1, 

2021

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

Complaint Processing Program Manager Dianne Wood Yes
49

Planned Activities Toward Completion of Objective

Target Date Planned Activities Modified 

Date Completion Date 

September 30, 

2025

Continued review of the applicant pool data to 

identify trends/barriers in hiring and selection of 

Hispanic employees and continue to investigate 

data to identify causes that hinder Hispanic 

representation in comparison to the benchmark.

September 

30, 2021 Ongoing

September 30, 

2025

PBGC’s HR Department, Learning & 

Development Division, Affinity Groups, and 

OEEO continue to be a source for information 

career enhancement for all of PBGC’s 

workforce.

September 

30, 2021 Ongoing

September 30, 

2025

Continue to offer bias awareness training 

through OEEO’s YOUniversity program and the 

PBGC Diversity Council’s Inclusion Training 

program.

September 

30, 2021 Ongoing

September 30, 

2025

OEEO’s Affirmative Employment Committees

will continue to sponsor workshops regarding 

proactive career development.

September 

30, 2020 Ongoing

Report of Accomplishments 

Fiscal Year Accomplishments

FY 2021

OEEO presented workshops focused on discussions around race and 

ethnicity with the goal of this series to address the unseen issues that 

impact equal employment opportunity.

FY 2021

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. A briefing was conducted with the agency head regarding the 

report and the recommendations developed by the committee.

FY 2021

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 2021

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.

FY 2021 Implemented a second survey focused on the perceptions of Hispanic 

women in PBGC workforce regarding career development opportunities.

FY 2021

Completed a Brown Bag Flash Mentoring series focused on the fifth OPM 

Executive Core Qualifications to support the proactive and intentional 

development of careers of Hispanics and all of PBGC’s workforce.

FY 2021

HRD continued its longstanding and robust partnership with the Hispanic 

Association of Colleges and Universities (HACU)/National Internship 

Program with a dedicated HACU Program Coordinator
50

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.

FY 2021

PBGC’s Learning and Development Division continues to create and 

implement adult learning and development to help facilitate professional 

development through its high-quality learning opportunities.
51

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 56.38% and males at 

a rate of 43.62%. In reviewing the FY21 breakdown of females by race and 

ethnicity, and in comparison to their representation rate in the total 

workforce, there is a decline in female representation for Black and Hispanic

females in grades GS-14, GS-15, and SL; and GS-14 and SL for Asian

females. White females are represented at a rate above the benchmark for 

grades GS-14 thru SL.

Benchmark GS-14 GS-15 SL

Asian 6.85% 6.19% 7.43% 2.70%

Black 28.98% 20.20% 15.54% 8.11%

Hispanic 2.32% .98% 2.03% 0%

White 16.86% 20.85 27.03% 32.43%

It should be noted that from FY 2020 to FY 2021, there was a decrease in 

representation of Black and Hispanic females in grades GS-14, GS-15, and 

SL. There was an increase in these same grades for Asian and White 

females. The rates are represented in the following graphs. 

6.19%

20.20%

0.98%

20.85%

5.81%

20.97%

1.29%

20.65%

Asian Black Hispanic White

GS-14 by Race & Ethnicity

2021 2020
52

Source of the 

Trigger

Specific 

Workforce 

Data 

Table 

Narrative Description of Trigger

EEO Group(s) Affected by Trigger

EEO Group

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

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 Occupational categories.

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

reported.

7.43%

15.54%

2.03%

27.03%

6.25% 15.97%

2.08%

27.08%

Asian Black Hispanic White

GS-15 by Race & Ethnicity

2021 2020

2.70%

8.11%

0.00%

32.43%

2.44%

9.76%

0.00%

31.71%

Asian Black Hispanic White

SL by Race & Ethnicity

2021 2020
53

Sources of Data

Source 

Reviewed?

(Yes or No)

Identify Information Collected

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

Complaint Processing Program Manager Dianne Wood Yes

Planned Activities Toward Completion of Objective

Target Date Planned Activities Modified 

Date 

Completion 

Date 

February 

2021

The Federal Women’s Affirmative Employment 

Committees will complete the Brown Bag Flash 

Mentoring series focused on OPM’s Executive 

Core Qualifications to support women in the 

proactive and intentional development of their 

careers.

April 2021.

September 

2021

The Federal Women’s Affirmative Employment 

Committees will sponsor a Brown Bag series 

regarding proactive career development.

September 

30, 2025 Ongoing
55

Report of Accomplishments 

Fiscal Year Accomplishments

FY 2021

OEEO presented workshops focused on discussions around race and 

ethnicity with the goal of this series to address the unseen issues that 

impact equal employment opportunity.

FY 2021

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. A briefing was conducted 

with the agency head regarding the report and the recommendations 

developed by the committee.

FY 2021

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 2021

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.

FY 2021

Implemented a second survey focused on the perceptions of Hispanic 

women in PBGC workforce regarding career development 

opportunities.

FY 2021

Completed a Brown Bag Flash Mentoring series focused on the fifth 

OPM Executive Core Qualifications to support the proactive and 

intentional development of careers of Hispanics and all of PBGC’s 

workforce.

FY 2021 

PBGC’s affinity groups continued to offer professional development 

support to their members. PBGC’s affinity groups include:

• Blacks in Government (BIG)

• Caribbean Connection

• Federally Employed Women (FEW)

• Federal Asian Pacific American Council (FAPAC)

• Hispanic Organization for Leadership and Advancement 

(HOLA)

• First Generation Professional (FGP)

In addition, PBGC offers Veterans programs to support the 

employment of US veterans.

The diversity council continues to present diversity day and other 

educational programs that support diversity, equity, inclusion, and 

accessibility.
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 X 

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 

above the benchmark. However, in the cluster GS-11 to SL, the representation for PWD was 8.63%. 

For each specific grade GS-13 through SL, the 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 10.04%

GS-14 9.77%

GS-15 2.70%

SL 5.41%

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 X 

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

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

GS-01 through GS-10 which has a representation of 9.09% and grade level cluster GS-11 though SL

which has a representation rate of 2.48%

However, the representation for each specific grade GS-13 through SL does identify triggers for GS15 and SL positions as there is underrepresentation according to the benchmark. The rates are 

reflected in the following chart: 

PWTD 2% Benchmark

GS-13 3.06%

GS-14 2.28%

GS-15 0.68%

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 Belinda Thomas-Blackwell, 

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

Beasley.donald@pbgc.gov; 

Denorse Prince Diversity 

and Inclusion Program 
58 

Manager, HRD, 

prince.denorse@pbgc.gov

Processing reasonable 

accommodation requests from 

applicants and employees

1 Donald Beasley

Reasonable 

Accommodation 

Coordinator

Section 508 Compliance Section 508 

Compliance 

Team (9), 

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

Special Emphasis Program for PWD 

and PWTD

1 1 Denorse Prince

Special Emphasis Program 

Manager and Kierra Evans

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 specialists review the 

provided documentation and make a determination as to whether the applicant is eligible for veterans’ 
59

preference and/or the Schedule A hiring authority. The specialists collaborate with the SPPC as 

necessary. 

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

SPPC incorporated Schedule A Hiring Authority into the PBGC managers and supervisors training. 

The SPPC made this a mandatory component of the “refresher” online reasonable accommodation 

training. 

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 DVAAP has established a partnership 

with The Veteran Affairs (Veterans Readiness Employment VRE) for the Staffing and Classification 

Division to accepts resumes from disabled veterans, including veterans with targeted disabilities and 

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

Continuing throughout FY 2021, staff was not able to 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

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 2021 MD-715 report, which is due on February 28, 2021.]

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

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
64 

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 

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 
65 

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 

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.
66 

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 

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. 
67 

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 at webmaster@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.

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
68 

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 2021, PBGC received and timely processed 42 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; 

(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.
69

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.

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.

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.

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. 
70

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

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
71

FY 2022 OEEO will continue to explore how it 

can enhance programs for PWD and 

PWTD.

Yes 09/30/20 Efforts are 

ongoing

Fiscal Year Accomplishments

FY 2021 The disability functions are managed by the Human Resources Department (HRD) and 

it continues to provide relevant trainings on topics on disability awareness

FY 2021 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 2021 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.

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

planned activities.

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 programs that support PWD/PWTD will continue and requires ongoing 

commitment from PBGC’s human resources, departmental leadership and the Office of Equal 

Employment Opportunity office.
72 

Appendix