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Pension Benefit Guaranty Corporation FY 2022

Affirmative Action Plan

for the Recruitment, Hiring, Advancement, and

Retention of Persons with Disabilities

To capture agencies’ affirmative action plan for persons with disabilities (PWD) and persons with targeted disabilities (PWTD), 

EEOC regulations (29 C.F.R. § 1614.203(e)) and MD-715 require agencies to describe how their affirmative action plan will 

improve the recruitment, hiring, advancement, and retention of applicants and employees with disabilities.

Section I: Efforts to Reach Regulatory Goals

EEOC regulations (29 CFR §1614.203(d)(7)) require agencies to establish specific numerical goals for increasing the participation 

of persons with disabilities and persons with 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) Answer No

b. Cluster GS-11 to SES (PWD) Answer No

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

the cluster GS-11 to SL, grades GS-11 thru GS-14 were also at or above the benchmark. However, grades GS-15 and SL were 

below the benchmark and are reflected in the chart below: PWD 12% Benchmark GS-15 5.26% SL 5.41% This graph shows that 

Persons with Disabilities are below the benchmark for representation.

*For GS employees, please use two clusters: GS-1 to GS-10 and GS-11 to SES, as set forth in 29 C.F.R. § 1614.203(d)(7). For all 

other pay plans, please use the approximate grade clusters that are above or below GS-11 Step 1 in the Washington, DC 

metropolitan region.

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) Answer No

b. Cluster GS-11 to SES (PWTD) Answer No

Where there is representation, we have determined that there is not a trigger for grade level cluster GS-01 through GS-10. In the 

cluster GS-11 to SL, grades GS-11 thru GS-14 were also at or above the benchmark. However, grades GS-15 and SL were below 

the benchmark and are reflected in the chart below: PWTD 2% Benchmark GS-15 0.66% SL 0.00% This graph shows that Persons 

with targeted Disabilities are below the benchmark for representation.

Grade Level Cluster(GS or Alternate Pay 

Planb)

Total Reportable Disability Targeted Disability

# # % # %

Numarical Goal -- 12% 2%

Grades GS-1 to GS-10 44 15 34.09 5 11.36

Grades GS-11 to SES 874 104 11.90 22 2.52

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
Pension Benefit Guaranty Corporation FY 2022

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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.

Answer Yes

2. Identify all staff responsible for implementing the agency's disability employment program by the office, staff 

employment status, and responsible official.

Disability Program Task

# of FTE Staff By Employment Status Responsible Official 

(Name, Title, Office 

Full Time Part Time Collateral Duty Email)

Processing applications from PWD and PWTD 7 0 0 Belinda ThomasBlackwell, Supervisory 

HR Specialist, thomasblackwell.belinda@pbgc.gov

Answering questions from the public about 

hiring authorities that take disability into 

account

1 0 1 Donald Beasley Selective 

Placement Program 

Coordinator HRD, 

beasley.donald@pbgc.gov

Denorse Prince DEIA 

Program Manager, HRD, 

prince.denorse@pbgc.gov

Architectural Barriers Act Compliance 1 0 0 Delilah LumHo Manager, 

Facilities and Services 

Division

Processing reasonable accommodation requests 

from applicants and employees

1 0 0 Donald Beasley, 

Reasonable 

Accommodation 

Coordinator, 

beasley.donald@pbgc.gov

Section 508 Compliance 0 0 9 Angela Watkins IT 

Specialist and Section 508 

Compliance Team Chair, 

Watkins.Angela@pbgc.gov

Special Emphasis Program for PWD and 

PWTD

1 1 0 Denorse Prince Special 

Emphasis Program 

Manager

Kierra Evans, Pathways 

Intern 

evans.kierra@pbgc.gov

3.
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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.

Answer Yes

Staff members attended The Department of Veterans Affairs-VRE training courses on: Multi-Generational Workforce, Taking the 

Emotion Out of Emotional Disabilities, and VA Benefits (part II).

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.

Answer Yes

PBGC’s Human Resources Department manages a centralized budget set aside to purchase items needed as a reasonable 

accommodation.

Section III: Program Deficiencies In The Disability Program

Section IV: Plan to Recruit and Hire Individuals with Disabilities

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

individuals with disabilities. The questions below are designed to identify outcomes of the agency’s recruitment program plan for 

PWD and PWTD

A. PLAN TO IDENTIFY JOB APPLICATIONS WITH DISABILITIES

1. 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’ preference and/or the 

Schedule A hiring authority. The specialists collaborate with the SPPC as necessary.

2. Pursuant to 29 C.F.R. §1614.203(a)(3), describe the agency’s use of hiring authorities that take disability into account 

(e.g., Schedule A) to recruit PWD and PWTD for positions in the permanent workforce

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.

3. When individuals apply for a position under a hiring authority that takes disability into account (e.g., Schedule A), explain 

how the agency (1) determines if the individual is eligible for appointment under such authority; and, (2) forwards the 

individual's application to the relevant hiring officials with an explanation of how and when the individual may be 

appointed.
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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.

4. Has the agency provided training to all hiring managers on the use of hiring authorities that take disability into account 

(e.g., Schedule A)? If “yes”, describe the type(s) of training and frequency. If “no”, describe the agency’s plan to provide 

this training.

Answer Yes

SPPC incorporated Schedule A Hiring Authority into the PBGC managers and supervisors training. The SPPC made this a 

mandatory component of the “refresher” virtual 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.

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) Answer No

b. New Hires for Permanent Workforce (PWTD) Answer No

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

New Hires Total

Reportable Disability Targeted Disability

Permanent 

Workforce

Temporary 

Workforce

Permanent 

Workforce

Temporary 

Workforce

(#) (%) (%) (%) (%)

130 91.54 0.00 48.46 0.00

55 85.45 0.00 40.00 0.00

1 100.00 0.00 100.00 0.00

% of Total 

Applicants

% of Qualified 

Applicants

% of New Hires

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. Select “n/a” if the applicant data 

is not available for your agency, and describe your plan to provide the data in the text box.
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a. New Hires for MCO (PWD) Answer No

b. New Hires for MCO (PWTD) Answer No

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

New Hires to Mission-Critical Occupations

Total

Reportable Disability Targetable Disability

New Hires New Hires

(#) (%) (%)

Numerical Goal -- 12% 2%

0510 ACCOUNTING 0 0.00 0.00

0511 AUDITING 1 100.00 100.00

0905 GENERAL ATTORNEY 0 0.00 0.00

0958 EMPLOYEE LAW BENEFIT 

SPECIALIST

0 0.00 0.00

1102 CONTRACT SPECIALIST 0 0.00 0.00

1160 FINANCIAL ANALYST 0 0.00 0.00

1160 FINANCIAL ANALYST 0 0.00 0.00

1510 ACTUARY SCIENCE 0 0.00 0.00

2210 INFORMATION TECHNOLOGY 

SPECIALIST

0 0.00 0.00

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. Select “n/a” if 

the applicant data is not available for your agency, and describe your plan to provide the data in the text box.

a. Qualified Applicants for MCO (PWD) Answer No

b. Qualified Applicants for MCO (PWTD) Answer No

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

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. Select “n/a” if the 

applicant data is not available for your agency, and describe your plan to provide the data in the text box.

a. Promotions for MCO (PWD) Answer No

b. Promotions for MCO (PWTD) Answer No

Section V: Plan to Ensure Advancement Opportunities for Employees with 

Disabilities

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

with disabilities. Such activities might include specialized training and mentoring programs, career development opportunities, 

awards programs, promotions, and similar programs that address advancement. In this section, agencies should identify, and provide 

data on programs designed to ensure advancement opportunities for employees with disabilities.

A. ADVANCEMENT PROGRAM PLAN

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

1. 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 established 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 webbased training). PBGC continues to use career ladder promotions as a recruitment strategy to hire at the entry level with 

development, growth, and promotion potential.

2. In the table below, please provide the data for career development opportunities that require competition and/or 

supervisory recommendation/ approval to participate.

Career Development 

Opportunities

Total Participants PWD PWTD

Applicants (#) Selectees (#)

 Applicants 

(%) Selectees (%)

 Applicants 

(%) Selectees (%)

Fellowship Programs N/A N/A N/A N/A N/A N/A

Detail Programs N/A N/A N/A N/A N/A N/A

Mentoring Programs N/A N/A N/A N/A N/A N/A

Other Career Development 

Programs

N/A N/A N/A N/A N/A N/A

Coaching Programs N/A N/A N/A N/A N/A N/A

Training Programs N/A N/A N/A N/A N/A N/A

Internship Programs 1054 29 N/A N/A N/A N/A

3. 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. Select “n/a” if the applicant data is not available for your agency, and describe your 

plan to provide the data in the text box.

a. Applicants (PWD) Answer No

b. Selections (PWD) Answer No

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

4. Do triggers exist for PWTD 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. Select “n/a” if the applicant data is not available for your agency, and describe your 

plan to provide the data in the text box.

a. Applicants (PWTD) Answer No

b. Selections (PWTD) Answer No

Not applicable. The Agency does not have career development programs that require competition.
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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) Answer No

b. Awards, Bonuses, & Incentives (PWTD) Answer No

Time-Off Awards Total (#)

Reportable 

Disability %

Without Reportable 

Disability %

Targeted Disability 

%

Without Targeted 

Disability %

Time-Off Awards 1 - 10 hours: 

Awards Given

11 0.00 14.52 0.00 0.00

Time-Off Awards 1 - 10 Hours: 

Total Hours

675 0.00 954.84 0.00 0.00

Time-Off Awards 1 - 10 Hours: 

Average Hours

61.36 0.00 106.10 0.00 0.00

Time-Off Awards 11 - 20 hours: 

Awards Given

58 0.95 79.03 7.41 0.70

Time-Off Awards 11 - 20 Hours: 

Total Hours

3136 51.02 4335.48 503.70 33.80

Time-Off Awards 11 - 20 Hours: 

Average Hours

54.07 7.29 88.48 251.85 -2.01

Time-Off Awards 21 - 30 hours: 

Awards Given

29 0.54 38.71 3.70 0.42

Time-Off Awards 21 - 30 Hours: 

Total Hours

1483 27.14 2012.90 0.00 28.17

Time-Off Awards 21 - 30 Hours: 

Average Hours

51.14 6.78 83.87 0.00 7.04

Time-Off Awards 31 - 40 hours: 

Awards Given

838 15.20 1077.42 96.30 12.11

Time-Off Awards 31 - 40 Hours: 

Total Hours

38757 686.02 49543.55 0.00 712.11

Time-Off Awards 31 - 40 Hours: 

Average Hours

46.25 6.12 74.16 0.00 6.36

Time-Off Awards 41 or more 

Hours: Awards Given

1 0.00 1.61 0.00 0.00

Time-Off Awards 41 or more 

Hours: Total Hours

120 0.00 193.55 0.00 0.00

Time-Off Awards 41 or more 

Hours: Average Hours

120 0.00 193.55 0.00 0.00

Cash Awards Total (#)

Reportable 

Disability %

Without Reportable 

Disability %

Targeted Disability 

%

Without Targeted 

Disability %

Cash Awards: $501 - $999: Awards 

Given

185 3.12 232.26 33.33 1.97

Cash Awards: $501 - $999: Total 

Amount

628420 9147.76 823408.06 102777.78 5587.18

Cash Awards: $501 - $999: 

Average Amount

3396.86 397.73 5718.11 11419.74 -21.42

Cash Awards: $1000 - $1999: 

Awards Given

502 9.77 625.81 74.07 7.32

Cash Awards: $1000 - $1999: Total 

Amount

1778087 27886.57 2320259.68 0.00 28947.04

Cash Awards: $1000 - $1999: 

Average Amount

3542.01 387.31 5980.05 0.00 402.04
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Cash Awards Total (#)

Reportable 

Disability %

Without Reportable 

Disability %

Targeted Disability 

%

Without Targeted 

Disability %

Cash Awards: $2000 - $2999: 

Awards Given

602 10.31 800.00 59.26 8.45

Cash Awards: $2000 - $2999: Total 

Amount

2294171 37699.46 3080712.90 0.00 39133.10

Cash Awards: $2000 - $2999: 

Average Amount

3810.92 496.05 6211.11 0.00 514.91

Cash Awards: $3000 - $3999: 

Awards Given

168 1.36 241.94 3.70 1.27

Cash Awards: $3000 - $3999: Total 

Amount

852321 6847.90 1231616.13 0.00 7108.31

Cash Awards: $3000 - $3999: 

Average Amount

5073.34 684.79 8210.77 0.00 710.83

Cash Awards: $4000 - $4999: 

Awards Given

4 0.14 4.84 0.00 0.14

Cash Awards: $4000 - $4999: Total 

Amount

28300 1031.21 33387.10 0.00 1070.42

Cash Awards: $4000 - $4999: 

Average Amount

7075 1031.21 11129.03 0.00 1070.42

Cash Awards: $5000 or more: 

Awards Given

59 0.54 82.26 0.00 0.56

Cash Awards: $5000 or more: Total 

Amount

881600 9497.96 1212258.06 0.00 9859.15

Cash Awards: $5000 or more: 

Average Amount

14942.37 2374.49 23769.76 0.00 2464.79

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) Answer No

b. Pay Increases (PWTD) Answer No

Other Awards Total (#)

Reportable 

Disability %

Without Reportable 

Disability %

Targeted Disability 

%

Without Targeted 

Disability %

Total Performance Based Pay 

Increases Awarded

36 0.27 51.61 0.00 0.28

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) Answer No

b. Other Types of Recognition (PWTD) Answer No

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. Select “n/a” if the applicant data is not available for your agency, and describe your 

plan to provide the data in the text box.

a. SES
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i. Qualified Internal Applicants (PWD) Answer No

ii. Internal Selections (PWD) Answer No

b. Grade GS-15

i. Qualified Internal Applicants (PWD) Answer No

ii. Internal Selections (PWD) Answer No

c. Grade GS-14

i. Qualified Internal Applicants (PWD) Answer No

ii. Internal Selections (PWD) Answer No

d. Grade GS-13

i. Qualified Internal Applicants (PWD) Answer No

ii. Internal Selections (PWD) Answer No

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. Select “n/a” if the applicant data is not available for your agency, and 

describe your plan to provide the data in the text box.

a. SES

i. Qualified Internal Applicants (PWTD) Answer No

ii. Internal Selections (PWTD) Answer No

b. Grade GS-15

i. Qualified Internal Applicants (PWTD) Answer No

ii. Internal Selections (PWTD) Answer No

c. Grade GS-14

i. Qualified Internal Applicants (PWTD) Answer No

ii. Internal Selections (PWTD) Answer No

d. Grade GS-13

i. Qualified Internal Applicants (PWTD) Answer No

ii. Internal Selections (PWTD) Answer No

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. Select “n/a” if the applicant data is not available for your agency, and describe your plan to 

provide the data in the text box.

a. New Hires to SES (PWD) Answer No
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b. New Hires to GS-15 (PWD) Answer No

c. New Hires to GS-14 (PWD) Answer No

d. New Hires to GS-13 (PWD) Answer No

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. Select “n/a” if the applicant data is not available for your agency, and describe your plan to 

provide the data in the text box.

a. New Hires to SES (PWTD) Answer No

b. New Hires to GS-15 (PWTD) Answer No

c. New Hires to GS-14 (PWTD) Answer No

d. New Hires to GS-13 (PWTD) Answer No

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. Select “n/a” if the applicant data is not 

available for your agency, and describe your plan to provide the data in the text box.

a. Executives

i. Qualified Internal Applicants (PWD) Answer No

ii. Internal Selections (PWD) Answer No

b. Managers

i. Qualified Internal Applicants (PWD) Answer No

ii. Internal Selections (PWD) Answer No

c. Supervisors

i. Qualified Internal Applicants (PWD) Answer No

ii. Internal Selections (PWD) Answer No

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. Select “n/a” if the applicant data 

is not available for your agency, and describe your plan to provide the data in the text box.

a. Executives

i. Qualified Internal Applicants (PWTD) Answer No

ii. Internal Selections (PWTD) Answer No

b. Managers
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i. Qualified Internal Applicants (PWTD) Answer No

ii. Internal Selections (PWTD) Answer No

c. Supervisors

i. Qualified Internal Applicants (PWTD) Answer No

ii. Internal Selections (PWTD) Answer No

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. Select “n/a” if the applicant data is 

not available for your agency, and describe your plan to provide the data in the text box.

a. New Hires for Executives (PWD) Answer No

b. New Hires for Managers (PWD) Answer No

c. New Hires for Supervisors (PWD) Answer No

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. Select “n/a” if the 

applicant data is not available for your agency, and describe your plan to provide the data in the text box.

a. New Hires for Executives (PWTD) Answer No

b. New Hires for Managers (PWTD) Answer No

c. New Hires for Supervisors (PWTD) Answer No

Section VI: Plan to Improve Retention of Persons with Disabilities

To be 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 assistance services.

A. VOLUNTARY AND INVOLUNTARY SEPARATIONS

1. In this reporting period, did the agency convert all eligible Schedule A employees with a disability into the competitive 

service after two years of satisfactory service (5 C.F.R. § 213.3102(u)(6)(i))? If “no”, please explain why the agency did 

not convert all eligible Schedule A employees.

Answer Yes

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) Answer No

b.Involuntary Separations (PWD) Answer No
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Seperations Total # Reportable Disabilities %

Without Reportable 

Disabilities %

Permanent Workforce: Reduction in Force 0 0.00 0.00

Permanent Workforce: Removal 4 0.00 0.48

Permanent Workforce: Resignation 22 1.59 2.39

Permanent Workforce: Retirement 32 3.97 3.22

Permanent Workforce: Other Separations 23 1.59 2.51

Permanent Workforce: Total Separations 81 7.14 8.59

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.

a.Voluntary Separations (PWTD) Answer No

b.Involuntary Separations (PWTD) Answer No

Seperations Total # Targeted Disabilities %

Without Targeted Disabilities 

%

Permanent Workforce: Reduction in Force 0 0.00 0.00

Permanent Workforce: Removal 4 0.00 0.43

Permanent Workforce: Resignation 22 6.25 2.15

Permanent Workforce: Retirement 32 0.00 3.43

Permanent Workforce: Other Separations 23 3.13 2.36

Permanent Workforce: Total Separations 81 9.38 8.37

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 CFR §1614.203(d)(4), federal agencies are required to inform applicants and employees of their rights under Section 

508 of the Rehabilitation Act of 1973 (29 U.S.C. § 794(b), concerning the accessibility of agency technology, and the Architectural 

Barriers Act of 1968 (42 U.S.C. § 4151-4157), concerning the accessibility of agency facilities. In addition, agencies are required to 

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

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

rights under Section 508 of the Rehabilitation Act, including a description of how to file a complaint.

Anyone with an accessibility issue related to navigating the pbgc.gov site should contact the webmaster@pbgc.gov (per The PBGC 

Website Policies and Procedures and the Accessibility section). In compliance with Section 508 of the Rehabilitation Act (link is 

external), PBGC is committed to providing access to its Web pages to all people-disabled or not-seeking information about PBGC. 

According to its policies for accessibility (link is external), the agency shall take appropriate steps to ensure effective 

communication with applicants, participants, personnel of other Federal entities, and members of the public. If you use assistive 

technology (such as a Braille reader, a screen reader, or TTY) and the format of any material on this Web site interferes with your 

ability to access information, please contact the PBGC Webmaster 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.
Pension Benefit Guaranty Corporation FY 2022

Page 13

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. The agency’s Section 508 Compliance Team conducts 

training sessions across the agency to raise awareness of Section 508 responsibilities and continues to promote their “Acclimate to 

Section 508 Learning Series” – promoting with Technology meets Usability. In addition to providing hands-on instruction on how 

to make accessible documents, via Word, PowerPoint, and PDF, they are educating stakeholders in what to look for when procuring 

technology. The Section 508 Compliance Team also has monthly Q&A Sessions. This Fiscal Year they have incorporated Monthly 

Tips to help educate PBGC employees. These practices will continue throughout this fiscal year. In preparation for the return to 

office on January 30, 2023, PBGC is working closely with GSA to ensure that our new headquarters building is accessible and 

addresses the needs of the PBGC employees and visitors.

C. REASONABLE ACCOMMODATION PROGRAM

Pursuant to 29 C.F.R. § 1614.203(d)(3), agencies must adopt, post on their public website, and make available to all job applicants 

and employees, reasonable accommodation procedures.

1. Please provide the average time frame for processing initial requests for reasonable accommodations during the reporting 

period. (Please do not include previously approved requests with repetitive accommodations, such as interpreting services.)

30 days

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

program. Some examples of an effective program include timely processing requests, timely providing approved 

accommodations, conducting training for managers and supervisors, and monitoring accommodation requests for trends.

(1) PBGC effectively operates a Reasonable Accommodation Program for qualified individuals with disabilities, including having a 

centralized reasonable accommodation fund and designated Reasonable Accommodation Coordinator. (2) During FY 2022, PBGC 

received and timely processed 27 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 CFR §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.
Pension Benefit Guaranty Corporation FY 2022

Page 14

Describe the effectiveness of the policies, procedures, or practices to implement the PAS requirement. Some examples of 

an effective program include timely processing requests for PAS, timely providing approved services, conducting training 

for managers and supervisors, and monitoring PAS requests for trends.

The PAS policy is included in the Reasonable Accommodations Policy. Both were approved by EEOC in FY19 and are posted on 

PBGC’s Intranet. PAS training was incorporated into the FY22 mandatory RA training for supervisors.

Section VII: EEO Complaint and Findings Data

A. EEO COMPLAINT DATA INVOLVING HARASSMENT

1. During the last fiscal year, did a higher percentage of PWD file a formal EEO complaint alleging harassment, as compared 

to the governmentwide average?

Answer No

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?

Answer No

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?

Answer No

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?

Answer No

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 VIII: Identification and Removal of Barriers

Element D of MD-715 requires agencies to conduct a barrier analysis when a trigger suggests that a policy, procedure, or practice 

may be impeding the employment opportunities of a protected EEO group.

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

PWD and/or PWTD?

Answer No

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

Answer N/A

3. Identify each trigger and plan to remove the barrier(s), including the identified barrier(s), objective(s), responsible 
Pension Benefit Guaranty Corporation FY 2022

Page 15

official(s), planned activities, and, where applicable, accomplishments
Pension Benefit Guaranty Corporation FY 2022

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STATEMENT OF 

CONDITION THAT WAS 

A TRIGGER FOR A 

POTENTIAL BARRIER:

Provide a brief narrative 

describing the condition at 

issue.

How was the condition 

recognized as a potential 

barrier?

Workforce Data (if so identify the table)

Workforce Data Table - B1

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.

N

N

STATEMENT OF 

BARRIER GROUPS:

STATEMENT OF 

IDENTIFIED BARRIER:

Provide a succinct statement 

of the agency policy, 

procedure

or practice that has been 

determined to be the barrier 

of the 

undesired condition.

Barrier Group

People with Disabilities

People with Targeted Disabilities

Source of the Trigger:

Specific Workforce Data 

Table:

Barrier Analysis Process 

Completed?:

Barrier(s) Identified?:

Barrier Name Description of Policy, Procedure, or Practice

Objective(s) and Dates for EEO Plan

Date 

Initiated

Target Date Sufficient 

Funding / 

Staffing?

Date 

Modified

Date 

Completed

Objective Description

10/01/2020 10/01/2025 Yes To increase representation in PBGC of PWDs and 

PWTDs.

Responsible Official(s)

Title Name Standards Address The Plan?

OEEO Director Brenecia Watson Yes

Agency Leadership Various Individuals Yes

HRD HRD Yes

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

10/01/2030 HRD will continue to train and educate on disability 

topics, including mandatory RA training for managers 

and supervisors.

Yes
Pension Benefit Guaranty Corporation FY 2022

Page 17

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

10/01/2030 The agency will continue to operate a robust interdepartmental Section 508 Compliance Team and offer 

hands-on Section 508 accessibility training to all 

employees.

Yes

Report of Accomplishments

Fiscal Year Accomplishment

2021 The disability functions are managed by the Human Resources Department (HRD) and it continues to provide 

relevant trainings on topics on disability awareness

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.

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.
Pension Benefit Guaranty Corporation FY 2022

Page 18

STATEMENT OF 

CONDITION THAT WAS 

A TRIGGER FOR A 

POTENTIAL BARRIER:

Provide a brief narrative 

describing the condition at 

issue.

How was the condition 

recognized as a potential 

barrier?

Workforce Data (if so identify the table)

Workforce Data Table - B1

PBGC’s sample sizes were 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.

Y

N

STATEMENT OF 

BARRIER GROUPS:

STATEMENT OF 

IDENTIFIED BARRIER:

Provide a succinct statement 

of the agency policy, 

procedure

or practice that has been 

determined to be the barrier 

of the 

undesired condition.

Barrier Group

People with Disabilities

People with Targeted Disabilities

Source of the Trigger:

Specific Workforce Data 

Table:

Barrier Analysis Process 

Completed?:

Barrier(s) Identified?:

Barrier Name Description of Policy, Procedure, or Practice

Objective(s) and Dates for EEO Plan

Date 

Initiated

Target Date Sufficient 

Funding / 

Staffing?

Date 

Modified

Date 

Completed

Objective Description

09/30/2022 09/30/2025 Yes 09/30/2022 09/30/2025 To increase representation in PBGC of PWDs and 

PWTDs.

Responsible Official(s)

Title Name Standards Address The Plan?

HRD Arrie Etheridge No

OEEO Director Brenecia Watson No

Leadership Agency Leadership No

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

09/30/2025 HRD will continue to train and educate on disability 

topics, including mandatory RA training for managers 

and supervisors.

Yes 09/30/2022 09/30/2025
Pension Benefit Guaranty Corporation FY 2022

Page 19

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

09/30/2025 OEEO will continue to explore how it can enhance 

programs for PWD and PWTD.

Yes 09/30/2022 09/30/2025

09/30/2025 The agency will continue to operate a robust interdepartmental Section 508 Compliance Team and offer 

hands-on Section 508 accessibility training and 

awareness to all employees.

Yes 09/30/2022 09/30/2025

Report of Accomplishments

Fiscal Year Accomplishment

2022 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.

2022 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.

2022 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.

2022 PBGC’s Learning and Development Division continued to create and implement adult learning and 

development to help facilitate professional development through its high-quality learning opportunities.

2022 The disability functions are managed by HRD, and it provides training on topics that include disability 

awareness, reasonable accommodations.

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

N/A. PBGC did complete planned activities. However, the effort to increase representation of PWD/PWTD happens incrementally 

and the efforts started, will continue.

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

barrier(s).

PBGC has a Disability Program that leverages special hiring authorities, veteran’s programs, and other diversity, equity, inclusion, 

and accessibility efforts that have increase the representation of persons with targeted disabilities to 3.3% which is about the 

EEOC’s goal of 2% representation for this same demographic.

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.

PBGC’s Human Resources and DEIA Program, Learning Development Division, departmental leadership, and the Office of Equal 

Employment Opportunity will continue to offer training to support career development, and workshops to understand and mitigate 

bias.