1

Management Directive 715

Annual EEO Program Status Report

Fiscal Year 2022
2

Pension Benefit Guaranty Corporation

FY 2022 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.1 - Head of Agency and Head of Agency Designee..........................................................................................3

Part C.2 - Agency Official(s) Responsible for Oversight of EEO Program(s)...............................................................3

Part D.1 – List of Subordinate Components Covered in this Report ............................................................................4

Part D.2 – Mandatory and Optional Documents for this Report ...................................................................................5

Part E – Executive Summary........................................................................................................................................6

Workforce Analysis .......................................................................................................................................................9

MD-715 - PART G Agency Self-Assessment Checklist..............................................................................................19

MD-715 – Part H .........................................................................................................................................................50

Agency EEO Plan to Attain the Essential Elements of a Model EEO Program..........................................................50

MD-715 – Part I...........................................................................................................................................................52

Agency EEO Plan to Eliminate Identified Barrier........................................................................................................52

MD-715 – Part J..........................................................................................................................................................61

Special Program Plan for the Recruitment, Hiring, Advancement, and Retention of Persons with Disabilities..........61

Section I: Efforts to Reach Regulatory Goals .............................................................................................................61

Section II: Model Disability Program...........................................................................................................................62

Section III: Plan to Recruit and Hire Individuals with Disabilities................................................................................63

Section IV: Plan to Ensure Advancement Opportunities for Employees with Disabilities ..........................................65

Section V: Plan to Improve Retention of Persons with Disabilities.............................................................................70

Section VI: EEO Complaint and Findings Data ..........................................................................................................73

Section VII: Identification and Removal of Barriers ....................................................................................................74

APPENDIX:

Fiscal Year 2022 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

445 12th Street SW Washington, DC 20024 BG 11

Part B - Total Employment

Total Employment Permanent Workforce Temporary Workforce Total Workforce

Number of Employees 918 46 964

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

Arrie 

Etheridge

HR Director /

CDO

201 SL 202-229-3728 etheridge.arrie@pbgc.gov

Hispanic Affirmative 

Employment

Committee Chair

Kimberly 

Rodgers

EEO 

Specialist

260 GS-12 202-229-3575 rodgers.kimberly@pbgc.gov
4

EEO Program Staff Name Title Occupational 

Series

Pay 

Plan 

and 

Grade

Phone 

Number Email Address

Women's Affirmative 

Employment 

Committee Chair 

Beverley 

Hebron

Management 

Analyst

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

Disability Affirmative 

Employment 

Committee Chair 

Hope 

Fuller

Lead EEO 

Specialist

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

Disability Program 

Manager

Denorse 

Prince

HR Specialist 201 GS-13 202-229-4026 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 

Lawrenc

e

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

Part E – Executive Summary 

EXECUTIVE SUMMARY

E.1: Mission

The Pension Benefit Guaranty Corporation (PBGC or Agency) protects the retirement security of over 33 million 

American workers, retirees, and beneficiaries in both single-employer and multi-employer private-sector pension 

plans. PBGC was created by the Employee Retirement Income Security Act of 1974 (ERISA) 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. The Agency continues to 

diligently administer two separate insurance programs that are operationally and financially independent.

PBGC’s Single-Employer Program covers defined benefit pension plans that generally are sponsored by a single 

employer. This program is financed by insurance premiums paid by companies that sponsor defined benefit 

pension plans, investment income from plan assets trusteed by PBGC, and recoveries from companies formerly 

responsible for the plans. PBGC’s Multiemployer Program covers defined benefit pension plans that are 

maintained through one or more collective bargaining agreements between employers and one or more employee 

organizations or unions. This program is financed by premiums set by Congress and paid by insured plans, and 

investment income. 

In addition, the American Rescue Plan (ARP) Act of 2021 (P.L. 117-2) established the Special Financial 

Assistance (SFA) Program for financially troubled multiemployer pension plans. The law addresses the solvency 

of the Multiemployer Program, which was projected to become insolvent in 2026. The SFA Program provides 

funding assistance to severely underfunded multiemployer pension plans. The SFA payments are derived from 

appropriated funds and financed by general revenues of the U.S. Department of the Treasury. 

Since the enactment of ERISA, PBGC has strengthened retirement security by preserving plans and protecting 

participants and their families. In FY 2022, PBGC made benefit payments of over $7.0 billion to more than 

960,000 participants. During this fiscal year period, PBGC also provided $217 million in traditional financial 

assistance to 115 multi-employer plans covering 93,525 participants receiving guaranteed benefits and a final 

payment of $9 million in financial assistance as part of PBGC’s first facilitated merger of two multiemployer plans 

under the Multiemployer Pension Reform Act of 2014 (MPRA). PBGC continues to work in ways that maintain the 

trust of its customers and the public; and remains committed to the highest standards of service, professionalism, 

accountability, and ethics. 

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. EEOC evaluates the operation of PBGC’s equal employment opportunity programs and 

reviews PBGC’s employment data, policies, and practices to ensure compliance and annual reporting of the 

required Management Directive 715 (MD-715) Report. 

MD-715 is the policy guidance provided by EEOC to federal agencies to establish and maintain 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

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, 2021, to September 30, 2022
7

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. 

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 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 EEOC, this report was completed utilizing data compiled at the end of fiscal year 2022 and covers 

the period from October 1, 2021, through September 30, 2022. 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 during FY 2022 in developing an equitable work environment and its plans for 

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

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 (HRD) 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, GS-14, and newly added GS-13 grade levels. 

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

points of contact to work with OEEO so that equal employment opportunity and diversity, equity, inclusion, and 

accessibility 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 sponsored a two-day managers training: Mitigating Bias in Talent Management.

• OEEO provided several series under the Education & Enrichment Program: The Real Talk series on 

various topics: (Neurodiversity Inclusiveness in the Workplace; LGBTQ+ Inclusiveness in The Workplace; Allyship 

in the Workplace and Social Mobility); Book Club 3-Part Discussions: The Sum of Us: What Racism Costs 

Everyone And How We Can Prosper Together and Affinity Chats, facilitated discussions for all races, ethnicities, 

and genders.

• PBGC’s Diversity Equity Inclusion and Accessibility Council sponsored the FY22 Community Day titled 

“Viewing Diversity Through Various Lenses.”

• PBGC’s Section 508 Compliance Team continued to raise awareness by conducting multiple virtual 

“Acclimate to Section 508” Learning Series courses throughout the year. The Office of Policy and External Affairs 

(OPEA) continued targeted recruitment outreach for underrepresented groups to include the International 

Association of Black Actuaries and The Organization of Latino Actuaries. PRAD successfully hired four minority 

women economists and actuaries; and COLA hired a minority female with Veterans’ preference in management. 

• The Office of Management and Administration (OMA) continued to enhance developmental opportunities 

by establishing career ladder positions which are promotable to GS-13 grade level. In FY22, there were nine 

career ladder promotions: two Hispanic females, two White females, one White male, three Black or African 

American females, and one identified as Two or more races. 

• The Office of Benefits Administration (OBA) introduced the Building a Better You Through Professional 

Development training series. The series last over a six-month period and offered seven courses that allowed 

employees to learn, reflect, improve, and practice in different areas of their growth and professional development. 

OBA also expanded its mentoring program and provided one-on-one coaching, mentoring, and training; as a 
8

result,16 employees reached their full performance level (FPL). Of the 16 OBA employees that earned career 

ladder promotions, there were nine males (8.33%) and seven females (4.54%). There were six (4.55%) Black or 

African Americans of 132 Black or African Americans in OBA’s workforce which is 2.29% of OBA’s 262 total 

workforce; three (25%) Asians of 12 Asians in OBA’s workforce which is 1.14% of OBA’s 262 total workforce; 4 

(5.06%) White or Caucasian American of 79 in OBA’s workforce which is 1.52% of OBA’s 262 total workforce; two 

(16.6%) Hispanic or Latino of 12 Hispanic or Latino in OBA’s workforce which is 0.76% of OBA’s 262 total 

workforce and one (100%) Not specified of one Not specified in OBA’s workforce which is 0.38% of OBA’s 262 

total workforce. Additionally, OBA continued to work with HRD to recruit and hire 1 schedule A candidate for a 

career ladder position.

• The Office of Negotiations and Restructuring (ONR) onboarded 11 external hires. Of the 11 hires, six were 

female and five were male. The newly hired employees identified as one Black or African American and two Asian 

employees. 

• The Office of Information Technology (OIT) continued to work directly with HRD to create career ladder 

opportunities that lead to several hires whose career paths increased to higher grade levels than the previously 

occupied positions. Those hires included: one White male, two White females; three Black or African American 

females; three Asian males, one Asian female, one identified as Two or more races and one Targeted Disability. 

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

disabilities through Schedule A appointing authority. FOD hired two employees under the Schedule A Program. 

The OCFO continued to identify career path opportunities to develop career ladders, allowing hiring at lower grade 

levels to support succession planning and building a talent pipeline. OCFO reported that currently 95% of the 

organization’s positions are career ladder positions starting at the lower grade levels. 

• The Office of the General Counsel (OGC) continues diversity outreach efforts by successfully hiring 20 

attorneys and other professionals, with diverse backgrounds. OGC reported that of the new hires, 65% percent 

were women. Of the 65%, 30% identified as Black or African American, and 15% identified as Asian. In addition, 

OGC also conducted outreach to law school graduates, interviewed at DC area schools and as a result, 

onboarded four female law school graduates. Of the four, two identified as Asian and one identified as Black or 

African American. OGC also participated in the Southeast Minority Job Fair and the Northeast Black Law 

Students Association Job Fair. OGC participated in interview programs from several multi-state consortiums, 

including the Law Consortium, the Midwest-California-Georgia Consortium, and the National Law School 

Consortium.
9

Workforce Analysis

During the FY 2022 reporting period, PBGC had a total workforce of 964 employees, a net change of

1.58% from the 949 employees during the previous year. The total female workforce representation was 

56.50% which is above the Civilian Labor Force (CLF) representation rate of 46.80%. Male employees 

represented 43.50% of the total workforce and was below the CLF representation rate of 53.20%. The total 

representation rates for male and female employees, and by race and ethnicity remained consistent over 

the previous year. 

Graph 1-Table A1

Graph 2-Table A1

Asian Black/AA AIAN Hispanic NHPI White Two +

Male 6.0% 12.2% 0.1% 1.8% 0.0% 22.9% 0.1%

Female 7.3% 28.5% 0.1% 2.6% 0.0% 16.8% 0.8%

6.0%

12.2%

0.1% 1.8%

0.0%

22.9%

0.1%

7.3%

28.5%

0.1% 2.6%

0.0%

16.8%

0.8%

Total Representation by Race, Ethnicity, and 

Gender 
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, i.e., 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 demographic

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. Tables A6/A7

Asian Male Major Occupation 

Representation 

Major Occupation

FY22 OCLF 

Benchmark

FY 2022 PBGC 

Representation

FY21 OCLF 

Benchmark

FY 2021 PBGC 

Representation

Accounting (0510) 3.10% 8.62% 3.70% 8.77%

Auditing (0511) 3.10% 7.56% 3.70% 7.38%

General Attorney (0905) 1.90% 2.08% 2.10% 1.06%

Employee Benefit Law Specialist (0958) 1.10% 4.55% 1.30% 4.17%

Contract Specialist (1102) 1.90% 0.00% 2.40% 0.00%

Financial Analyst (1160) 5.90% 2.22% 7.70% 2.13%

Actuary Science (1510) 4.80% 10.31% 7.10% 11.70%

Information Technology Specialist (2210) 7.00% 16.52% 10.80% 17.27%

Asian Female Major Occupation 

Representation

Major Occupation

FY22 OCLF 

Benchmark

FY 2022 PBGC 

Representation

FY21 OCLF 

Benchmark

FY 2021 PBGC 

Representation

Accounting (0510) 5.70% 12.07% 7.10% 10.53%

Auditing (0511) 5.70% 10.92% 7.10% 9.84%

General Attorney (0905) 2.10% 6.25% 2.40% 8.51%

Employee Benefit Law Specialist (0958) 2.20% 4.55% 2.60% 4.17%

Contract Specialist (1102) 2.40% 13.64% 3.10% 5.26%

Financial Analyst (1160) 5.30% 8.89% 6.80% 4.26%

Actuary Science (1510) 5.00% 10.31% 7.50% 10.64%

Information Technology Specialist (2210) 2.60% 6.96% 3.30% 7.27%
11

Black or African American Male Major 

Occupation Representation

Major Occupation

FY22 OCLF 

Benchmark

FY 2022 

PBGC 

Representati

on

FY21 OCLF 

Benchmark

FY 2021 PBGC 

Representation

Accounting (0510) 2.70% 17.24% 2.80% 15.80%

Auditing (0511) 2.70% 18.49% 2.80% 17.20%

General Attorney (0905) 2.20% 1.04% 2.30% 1.10%

Employee Benefit Law Specialist (0958) 1.90% 13.64% 1.90% 20.80%

Contract Specialist (1102) 3.30% 4.55% 3.30% 5.30%

Financial Analyst (1160) 3.50% 24.44% 3.50% 25.50%

Actuary Science (1510) 3.80% 8.25% 3.80% 9.60%

Information Technology Specialist (2210) 3.60% 13.04% 3.40% 12.70%

Black or African American Female 

Major Occupation Representation

Major Occupation

FY22 OCLF 

Benchmark

FY 2022 PBGC 

Representation

FY21 OCLF 

Benchmark

FY 2021 PBGC 

Representation

Accounting (0510) 5.70% 36.21% 5.70% 33.00%

Auditing (0511) 5.70% 34.45% 5.70% 33.60%

General Attorney (0905) 3.00% 9.38% 3.00% 10.60%

Employee Benefit Law Specialist (0958) 6.50% 63.64% 6.50% 58.00%

Contract Specialist (1102) 5.20% 13.64% 5.10% 21.05%

Financial Analyst (1160) 4.10% 13.33% 4.00% 12.80%

Actuary Science (1510) 5.70% 7.22% 5.40% 8.50%

Information Technology Specialist (2210) 2.50% 19.13% 2.30% 20.90%

Hispanic or Latino Male Major 

Occupation Representation

Major Occupation

FY22 OCLF 

Benchmark

FY 2022 PBGC 

Representation

FY21 OCLF 

Benchmark

FY 2021 PBGC 

Representation

Accounting (0510) 2.70% 0.00% 2.90% 0.00%

Auditing (0511) 2.70% 0.00% 2.90% 0.00%

General Attorney (0905) 3.10% 1.04% 3.20% 1.06%

Employee Benefit Law Specialist (0958) 2.70% 0.00% 3.00% 0.00%

Contract Specialist (1102) 4.30% 4.55% 4.70% 5.26%

Financial Analyst (1160) 3.60% 2.22% 3.90% 2.13%

Actuary Science (1510) 3.60% 4.12% 3.50% 4.26%

Information Technology Specialist (2210) 4.50% 2.61% 4.70% 2.73%
12

White Male Major Occupation 

Representation

Major Occupation

FY22 OCLF 

Benchmark

FY 2022 PBGC 

Representation

FY21 OCLF 

Benchmark

FY 2021 PBGC 

Representation

Accounting (0510) 29.70% 15.52% 28.80% 21.05%

Auditing (0511) 29.70% 11.76% 28.80% 13.93%

General Attorney (0905) 54.70% 37.50% 54.10% 37.23%

Employee Benefit Law Specialist (0958) 13.20% 13.64% 12.90% 12.50%

Contract Specialist (1102) 37.00% 13.64% 36.10% 15.79%

Financial Analyst (1160) 46.00% 31.11% 43.80% 34.04%

Actuary Science (1510) 40.20% 42.27% 37.80% 41.49%

Information Technology Specialist (2210) 54.30% 29.57% 51.40% 29.09%

Workforce demographics not reflected in a chart are at or above parity with the benchmark. OEEO will 

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

develop programs that support equal employment opportunity.

Hispanic or Latino Female Major 

Occupation Representation

Major Occupation

FY22 OCLF 

Benchmark

FY 2022 PBGC 

Representation

FY21 OCLF 

Benchmark

FY 2021 PBGC 

Representation

Accounting (0510) 5.10% 0.00% 5.30% 0.00%

Auditing (0511) 5.10% 4.20% 5.30% 4.92%

General Attorney (0905) 2.50% 2.08% 2.60% 1.06%

Employee Benefit Law Specialist (0958) 10.70% 0.00% 11.20% 0.00%

Contract Specialist (1102) 4.60% 0.00% 4.90% 0.00%

Financial Analyst (1160) 3.30% 0.00% 3.40% 0.00%

Actuary Science (1510) 3.5% 1.03% 3.40% 0.00%

Information Technology Specialist (2210) 1.60% 0.00% 1.60% 0.00%

White Female Major Occupation 

Representation

Major Occupation

FY22 OCLF 

Benchmark

FY 2022 PBGC 

Representation

FY21 OCLF 

Benchmark

FY 2021 PBGC 

Representation

Accounting (0510) 42.90% 8.62% 41.50% 8.77%

Auditing (0511) 42.90% 10.08% 41.50% 10.70%

General Attorney (0905) 28.50% 40.63% 28.30% 39.40%

Employee Benefit Law Specialist (0958) 58.90% 0.00% 57.80% 0.00%

Contract Specialist (1102) 39.20% 45.45% 38.30% 42.10%

Financial Analyst (1160) 26.20% 17.78% 24.80% 19.20%

Actuary Science (1510) 30.60% 16.49% 28.70% 13.83%

Information Technology Specialist (2210) 21.60% 10.43% 20.20% 8.18%
13

OCCUPATIONAL CATEGORIES

a. Total Executive and Senior Level Representation

The Executive and Senior Level occupational categories include Executives and Senior level officials. 

These are the individuals that plan, direct, and formulate policies, set strategy, and provide the overall 

direction of agency for the development and implementation of services to accomplish the mission. 

According to current EEOC guidelines, executives comprise grades GS-15 to Senior Leader (SL) positions. 

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

demographic data was conducted and confirmed that there is a glass ceiling effect because specific 

demographics encounter barriers when being promoted to executive-level positions, despite their presence 

in positions that comprise the feeder pool for this category. 

Graph 3. (data from A1 and A3 tables)

b. Total Managers and Mid-Level Representation

The Managers and Mid-level occupational categories include 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, 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 demographic data was conducted and confirmed that there is a glass 

ceiling effect because specific demographics encounter barriers when being promoted to managerial and 

supervisory-level positions, despite their presence in positions that comprise the feeder pool for this 

category. 

Graph 4. (data from A1 and A3 tables)

c. Total Professional Representation

13.30%

40.70%

0.20% 4.40% 0.20%

39.70%

0.00

10.58% 21.69%

0.00% 2.12% 0.00%

65.61%

0.00%

Asian AA or Black AIAN Hispanic or

Latino

NHPI White Two+

Total Executive and Senior Level 

Occupational Category Representation

Total Workforce E-S Occupational Category

13.30%

40.70%

0.20% 4.40% 0.00%

39.70%

0.90%

16.28%

39.53%

0.00% 0.00% 0.00%

41.86%

2.33%

Asian AA or Black AIAN Hispanic or

Latino

NHPI White Two+

Total Officials and Managers 

Occupational Category Representation

Total Workforce M Occupational Category
14

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 5. (data from A1 and A3 tables)

d. Total Administrative Support Workers Representation

The Administrative Support Workers occupational category includes all clerical-type work regardless 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 and confirmed that a glass wall – when specific demographics are unable to obtain 

employment in major occupations with upward mobility - exists. 

Graph 6. (data from A1 and A3 tables)

13.30%

40.70%

0.20% 4.40% 0.00%

39.70%

0.90% 14.04%

44.30%

0.32% 5.31%

0.00%

34.16%

1.88%

Asian AA or Black AIAN Hispanic or

Latino

NHPI White Two +

Total Workforce & Professional 

Occupational Category Representation

Total Workforce Professional Occupational Category

13.30%

40.70%

0.20% 4.40% 0.00%

39.70%

6.98% 0.90%

83.72%

0.00% 2.33% 0.00%

6.98%

0.00%

Asian AA or Black AIAN Hispanic or

Latino

NHPI White Two+

Total Workforce & Administrative Support 

Occupational Category Representation

Total Workforce Administrative Support
15

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

Benchmark 6%

FY2022 FY2021

Officials & Managers 9.30% 3.96%

Professionals 6.55% 6.75%

Administrative Support 4.65% 4.08%

Asian Female Occupational Category

Benchmark 7.3%

FY2022 FY2021

Officials & Managers 6.98% 6.17%

Professionals 7.49% 7.23%

Administrative Support 2.33% 6.12%

Black or African American Male

Occupational Category

Benchmark 12.2%

FY2022 FY2021

Officials & Managers 18.60% 10.00%

Professionals 12.79% 12.54%

Administrative Support 18.60% 16.3%

Black or African American Female 

Occupational Category

Benchmark 28.5%

FY2022 FY2021

Officials & Managers 20.93% 15.40%

Professionals 31.51% 31.50%

Administrative Support 65.12% 61.20%

Hispanic Male Occupational Category

Benchmark 1.8%

FY2022 FY2021

Officials & Managers 0.00% 1.00%

Professionals 1.72% 2.09%

Administrative Support 2.33% 2.04%

Hispanic Female Occupational Category

Benchmark 2.6%

FY2022 FY2021

Officials & Managers 0.00% 1.32%

Professionals 3.59% 2.73%

Administrative Support 0.00% 0.00%
16

White Male Occupational Category

Benchmark 22.9%

FY2022 FY2021

Officials & Managers 23.26% 35.7%

Professionals 19.81% 20.42%

Administrative Support 4.65% 6.12%

White Female Occupational Category

Benchmark 16.8%

FY2022 FY2021

Officials & Managers 18.60% 26.00%

Professionals 14.35% 14.63%

Administrative Support 2.33 4.08%

OEEO 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, HRD, and other stakeholders to develop programs that support equal employment opportunity.
17

GS-13 THRU SL GRADE REPRESENTATION

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

demographics at GS-14 through 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 2022 Asian Males 2021 Asian Females 

2022

Asian Females 

2021

PBGC Benchmark 6.01% 6.01% 7.30% 6.85%

SL 2.70% 2.70% 2.70% 2.70%

GS-15 3.95% 4.05% 7.89% 7.43%

GS-14 7.53% 5.86% 6.33% 6.19%

GS-13 6.61% 7.42% 7.49% 6.55%

Black or African 

American Grade 

Representation 

Black or AA Males 

2022

Black or AA Males 

2021

Black or AA 

Females 2022

Black or AA 

Females 2021

PBGC Benchmark 12.20% 11.90% 28.50% 29.00%

SL 8.11% 8.10% 8.11% 8.10%

GS-15 9.21% 7.40% 13.82% 15.50%

GS-14 11.45% 12.40% 21.08% 20.20%

GS-13 15.42% 15.70% 38.77% 39.70%

Hispanic Male & Female 

Grade Representation

Hispanic Male 

2022

Hispanic Male 2021 Hispanic Female 

2022

Hispanic Female 

2021

PBGC Benchmark 1.80% 1.90% 2.60% 2.30%

SL 0.00% 0.00% 0.00% 0.00%

GS-15 1.32% 1.40% 1.32% 2.00%

GS-14 1.81% 2.00% 1.51% 1.00%

GS-13 1.32% 1.80% 4.85% 3.50%

White Male & Female 

Grade Representation

White Males 2022 White Males 2021 White Females 

2022

White Females 

2021

PBGC Benchmark 22.90% 23.29% 16.80% 16.86%

SL 43.24% 45.95% 35.14% 32.43%

GS-15 35.53% 35.14% 26.97% 27.03%

GS-14 29.22% 30.29% 19.58% 20.85%

GS-13 14.54% 15.72% 8.81% 7.42%
18
19

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 "N/A" 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.
20

MD-715 - PART G

Agency Self-Assessment Checklist

Essential Element A: DEMONSTRATED COMMITMENT FROM AGENCY LEADERSHIP

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

and a discrimination-free workplace.

Compliance 

Indicator 

Measures

A.1 – The agency issues an effective, 

up-to-date EEO policy statement.

Measure 

Met?

(Yes/No/NA)

Comments Current Part G 

Questions

A.1.a Does the agency annually issue a 

signed and dated EEO policy 

statement on agency letterhead that 

clearly communicates the agency’s 

commitment to EEO for all 

employees and applicants? If “yes,”

please provide the annual issuance 

date in the comments column. [see 

MD-715, II(A)]

Yes May 16, 2022 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 C.F.R. § 

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 Current Part G 

Questions

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: 

A.2.b.1 The business contact information for 

its EEO Counselors, EEO Officers, 

Yes
21

Compliance 

Indicator 

Measures

A.2 – The agency has communicated 

EEO policies and procedures to all 

employees.

Measure 

Met?

(Yes/No/NA)

Comments Current Part G 

Questions

Special Emphasis Program 

Managers, and EEO Director? [see 

29 C.F.R § 1614.102(b)(7)]

A.2.b.2 Written 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/sites/default/fil

es/pbgcprocedures-forprocessingrequests-forreasonableaccommodation.p

df

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 

C.F.R. §§ 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. 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 C.F.R. § 

1614.203(d)(7)(ii)(C)] If “yes,” please 

provide how often. 

Yes The Reasonable 

Accommodation 

brochure is provided to 

all employees during 

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.

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

EEOC Enforcement Guidance on 

Vicarious Employer Liability for 

Unlawful Harassment by Supervisors 

Yes HRD provides training 

regarding workplace 

behavior, Harassment 

Inquiry Committee 

(HIC), Agency policy, 
22

Compliance 

Indicator 

Measures

A.2 – The agency has communicated 

EEO policies and procedures to all 

employees.

Measure 

Met?

(Yes/No/NA)

Comments Current Part G 

Questions

(1999), § V.C.1] If “yes.” please 

provide how often.

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 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 C.F.R. § 

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

Current Part G 

Questions

A.3.a Does the agency provide recognition 

to employees, supervisors, 

managers, and units demonstrating 

superior accomplishment in equal 

employment opportunity? [see 29 

C.F.R. § 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 C.F.R.

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.
23

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 Current Part G 

Questions

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 C.F.R.

§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 the mission-related 

programmatic offices? If “yes,” please 

provide the title of the agency head 

designee in the comments.

N/A

B.1.a.2 Does the agency’s organizational 

chart clearly define the reporting 

structure for the EEO office? [see 29 

C.F.R. §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 C.F.R.

§1614.102(c)(1); MD-715 

Instructions, Sec. I] 

Yes B.2.a

B.1.c During this reporting period, did the 

EEO Director present to the head of 

the agency, and other senior 

management officials, the "State of 

the agency" briefing covering the six 

essential elements of the model EEO 

program and the status of the barrier 

analysis process? [see MD-715 

Instructions, Sec. I] If “yes,” please 

provide the date of the briefing in the 

comment’s column. 

Yes July 22, 2022 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
24

Compliance 

Indicator

Measures

B.2 – The EEO Director controls all 

aspects of the EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

New Compliance 

Indicator

Current Part G 

Questions

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 C.F.R.

§1614.102(c)] 

Yes B.3.a

B.2.b Is the EEO Director responsible for 

overseeing the completion of EEO 

counseling [see 29 C.F.R.

§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 C.F.R. §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 

C.F.R. §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 C.F.R. §§ 

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 C.F.R.

§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 C.F.R. §§ 1614.102(c)(2) and 

(c)(3)]

N/A
25

Compliance 

Indicators 

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 Current Part G 

Questions

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

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 drawn 

from all segments of 

American society. 

Foster a culture of 

inclusion that 

encourages 

collaboration, 

flexibility, and 

fairness.

Continue to conduct 

YOUniversity Bias 

Training to create 

opportunities for 

individuals to 

investigate their bias 

and to understand 

bias’s impact on 

equal employment 

opportunity
26

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 Current Part G 

Questions

B.4.a Pursuant to 29 C.F.R.

§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 C.F.R. § 

1614.102(c)(5) & 1614.105(b) – (f); 

MD-110, Ch. 1(IV)(D) & 5(IV); MD715, II(E)]

Yes E.5.b

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

employees with training on the EEO 

program, including but not limited to 

retaliation, harassment, religious 

accommodations, disability 

accommodations, the EEO complaint 

process, and ADR? [see MD-715, 

II(B) and III(C)] If not, please identify 

the type(s) of training with insufficient 

funding in the comments column. 

Yes B.4.f & B.4.g

B.4.a.5 To conduct thorough, accurate, and 

effective field audits of the EEO 

programs in components and the field 

offices, if applicable? [see 29 C.F.R.

§1614.102(c)(2)]

N/A E.1.c

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 

Yes
27

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 Current Part G 

Questions

systems with insufficient funding in 

the comments section.

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 U.S.C. § 7201; 38 U.S.C. § 4214; 5 

C.F.R. § 720.204; 5 C.F.R. § 

213.3102(t) and (u); 5 C.F.R. § 

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 antiharassment 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 

C.F.R. § 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 C.F.R. § 

1614.102(a)(1)]

Yes

B.4.c Are the duties and responsibilities of 

EEO officials clearly defined? [see 

MD-110, Ch. 1(III)(A), 2(III), & 6(III)]

Yes B.1.b

B.4.d Does the agency ensure that all new 

counselors and investigators, 

including contractors and collateral 

duty employees, receive the required 

32 hours of training, pursuant to Ch.

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

Yes E.2.d

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
28

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

Current Part 

G Questions

B.5.a Pursuant to 29 C.F.R. § 

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 MD715(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 MD715(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 

Current Part 

G Questions

B.6.a Are senior managers involved in the 

implementation of Special Emphasis 

Programs? [see MD-715 

Instructions, Sec. I]

Yes

B.6.b Do senior managers participate in the 

barrier analysis process? [see MD715 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 

MD-715 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 C.F.R. § 1614.102(a)(5)]

Yes During FY 2022, action 

plans were maintained 

and continued to be 

implemented. We will

continue to measure

results in 2023.

D.1.c
29

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 Current Part G 

Questions

C.1.a Does the agency regularly 

assess its component and field 

offices for possible EEO program 

deficiencies? [see 29 C.F.R.

§1614.102(c)(2)] If” yes”, please

provide the schedule for

conducting audits in the

comments section.

N/A

C.1.b Does the agency regularly 

assess its component and field 

offices on their efforts to remove

barriers from the workplace? [see 

29 C.F.R. §1614.102(c)(2)] If 

”yes”, please provide the 

schedule for conducting audits in 

the comments section.

N/A

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

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

Current Part G 

Questions

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

require corrective action to 

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]

Yes

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

firewall between the AntiHarassment 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 

Yes
30

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

Current Part G 

Questions

Enforcement Guidance on 

Vicarious Employer Liability for 

Unlawful Harassment by 

Supervisors (Enforcement 

Guidance), EEOC No. 915.002, § 

V.C.1 (June 18, 1999)].

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

EEO office informs the antiharassment 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 timelyprocessed inquiries in the 

comments column.

Yes

C.2.a.6 Do the agency’s training materials 

on its anti-harassment policy 

include examples of disabilitybased harassment? [see 29 

C.F.R. 1614.203(d)(2)]

Yes

C.2.b Has the agency established 

disability reasonable 

accommodation procedures that 

comply with EEOC’s regulations 

and guidance? [see 29 C.F.R.

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 C.F.R.

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
31

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

Current Part G 

Questions

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 C.F.R.

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 C.F.R.

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 C.F.R.

1614.203(d)(6)]

Yes

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

procedures for processing 

requests for Personal Assistance 

Services on its public website? 

[see 29 C.F.R. § 

1614.203(d)(5)(v)] If “yes,” please 

provide the internet address in the 

comments column.

Yes https://www.pbgc.gov/

sites/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

Current Part G 

Questions

C.3.a Pursuant to 29 C.F.R.

§1614.102(a)(5), do all 

managers and supervisors have 

an element in their performance 

Yes
32

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

Current Part G 

Questions

appraisal that evaluates their 

commitment to agency EEO 

policies and principles and their 

participation in the EEO 

program?

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 C.F.R.

§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 

C.F.R. §1614.102(a)(7)]

Yes A.3.a.7

C.3.b.6 Provide disability 

accommodations when such 

accommodations do not cause 

an undue hardship? [ see 29 

C.F.R. §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
33

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

Current Part G 

Questions

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 C.F.R. §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 C.F.R. §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 

C.F.R. §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 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]

Yes C.2.a, C.2.b, & 

C.2.c

C.4.c Does the EEO office have timely 

access to accurate and complete 

data (e.g., demographic data for 

Yes
34

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

workforce, applicants, training 

programs, etc.) required to prepare 

the MD-715 workforce data tables? 

[see 29 C.F.R. §1614.601(a)]

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 MD-715,

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 C.F.R. §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 MD715, 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 Current Part G 

Questions

C.5.a Does the agency have a disciplinary 

policy and/or table of penalties that 

covers discriminatory conduct? [see 

29 C.F.R. § 1614.102(a)(6); see also 

Douglas v. Veterans Administration, 

5 M.S.P.R. 280 (1981)]

Yes C.3.a.

C.5.b When appropriate, does the agency 

discipline or sanction managers and 

employees for discriminatory 

conduct? [see 29 C.F.R.

§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/sa

nctioned for 

this fiscal 

year.

C.3.c
35

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 Current Part G 

Questions

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 Current Part G 

Questions

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 

managers 

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
36

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 Current 

Part G Questions

D.1.a Does the agency have a process for 

identifying triggers in the workplace? 

[see MD-715 Instructions, Sec. I]

Yes

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 C.F.R.

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

Current Part G 

Questions

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 C.F.R.

§1614.102(a)(3)]

Yes B.2.c.2

D.2.c Does the agency consider 

whether any group of 

Yes B.2.c.1
37

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

Current Part G 

Questions

employees or applicants might 

be negatively impacted prior to 

making human resource 

decisions, such as reorganizations and 

realignments? [see 29 C.F.R.

§1614.102(a)(3)]

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 program 

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 Current Part G 

Questions

D.3.a. Does the agency effectively tailor 

action plans to address the identified 

barriers, in particular policies, 

procedures, or practices? [see 29 

C.F.R. §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
38

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

Current Part G 

Questions

D.4.a Does the agency post its affirmative 

action plan on its public website?

[see 29 C.F.R. 1614.203(d)(4)] 

Please provide the internet address 

in the comments.

Yes https://www.pbgc

.gov/sites/default

/files/documents/

fy2021-md715-

report.pdf

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 C.F.R.

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 

C.F.R. 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 C.F.R.

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 

Measures

E.1 - The agency maintains an 

efficient, fair, and impartial complaint 

resolution process.

Measure 

Met?

(Yes/No/NA) Comments Current 

Part G Questions

E.1.a Does the agency timely provide 

EEO counseling, pursuant to 29 

C.F.R. §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 C.F.R.

§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
39

Compliance 

Indicator 

Measures

E.1 - The agency maintains an 

efficient, fair, and impartial complaint 

resolution process.

Measure 

Met?

(Yes/No/NA) Comments Current 

Part G Questions

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 MD110, 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.

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 C.F.R. §1614.102(b)(6)?

Yes

E.1.f Does the agency timely complete 

investigations, pursuant to 29 C.F.R.

§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 C.F.R.

§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 C.F.R.

§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 

C.F.R. §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 MD110, Ch. 5(V)(A)] If “yes,” please 

Yes Yes, the Agency uses 

contract investigators 

to conduct EEO 

discrimination 

investigations. The 

EEO attorney-advisor 

requires weekly 

E.2.c
40

Compliance 

Indicator 

Measures

E.1 - The agency maintains an 

efficient, fair, and impartial complaint 

resolution process.

Measure 

Met?

(Yes/No/NA) Comments Current 

Part G Questions

describe how in the comments 

column.

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.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)]

N/A

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 C.F.R. § 

1614.403(g)]

Yes

Compliance 

Indicator 

Measures

E.2 – The agency has a neutral EEO 

process.

Measure 

Met?

(Yes/No/NA)

Comments

Revised Indicator

Current Part G 

Questions

E.2.a Has the agency established a clear 

separation between its EEO 

complaint program and its defensive 

function? [see MD-110, 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
41

Compliance 

Indicator 

Measures

E.2 – The agency has a neutral EEO 

process.

Measure 

Met?

(Yes/No/NA)

Comments

Revised Indicator

Current Part G 

Questions

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)]

N/A

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 Program: Efficiency

(Dec. 1, 2004)]

N/A E.6.c

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

Comments Current Part G 

Questions

E.3.a Has the agency established an ADR 

program for use during both the precomplaint and formal complaint 

stages of the EEO process? [see 29 

C.F.R. §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)]

No PBGC offers ADR, 

but managers and 

supervisors are not 

required to 

participate.

E.4.c

E.3.c Does the agency encourage all 

employees to use ADR, where ADR 

is appropriate? [see MD-110, 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 

MD-110, 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
42

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

Comments Current Part G 

Questions

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 Current Part G 

Questions

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

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

disability status of agency 

employees? [see 29 C.F.R.

§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 

C.F.R. § 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
43

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 Current Part G 

Questions

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 searches 

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
44

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 Current Part G 

Questions

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 C.F.R.

§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

Current Part G 

Questions

F.2.a Does the agency timely respond 

and fully comply with EEOC 

orders? [see 29 C.F.R.

§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 

Yes E.3.a.5
45

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

Current Part G 

Questions

the appropriate EEOC hearing 

office? [see 29 C.F.R.

§1614.108(g)]

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

discrimination that is not the 

subject of an appeal by the 

agency, does the agency 

ensure timely compliance with 

the orders of relief? [see 29 

C.F.R. §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 C.F.R.

§1614.403(e)]

Yes

F.2.a.4 Pursuant to 29 C.F.R.

§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 Current Part G 

Questions

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 

C.F.R. §1614.703(d)]

Yes
46

e. 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 2022 FY 2021

Number of 

Deficiencies Percentage

Number of 

Deficiencies Percentage

A - Demonstrated Leadership Commitment 0 100% 0 100%

B - Integration of EEO in Strategic Mission 1 97% 1 97%

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

D - Proactive Discrimination Prevention 0 100% 0 100%

E - Efficiency 1 97% 0 100%

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

Summary Score 99.0% 99.5%
47

f. 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 on July 22, 2022. 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.

· 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. The DEIA Council completed an Agency-Specific DEIA 

Strategic Plan. The Plan was submitted on March 23, 2022, and approved by OPM/DPC and 

OMB during the summer. DEIA also held virtual Community Day(s) during October 2022 that 

were well attended. 

· Agency staff participated in PBGC’s EEO/ 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 2022.

· 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.
48

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 2022, 

OGC and HRD jointly evaluated 6 reports of potential harassment and conducted inquiries as 

appropriate through the Agency’s 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 2022. 

· 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. 

· 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 alternative 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 2022, ADR was offered 5 times to 5 individuals and rejected 3 times by 3 individuals.

· PBGC received and processed 9 formal complaints alleging employment discrimination in FY 

2022.
49

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 2022 PBGC received and processed 9 formal complaints alleging employment 

discrimination.

· The Agency successfully processed 17 informal complaints within regulatory 

timeframes (including ADR and written extensions).

· The following reflects PBGC’s formal complaint activity in FY 2022.

o 9 formal complaints were filed in FY 2022.

o 13 Complaints were closed during FY 2022.

o Agency issued all FADs timely.

o Investigations were completed within a completion time of 150 days, well in 

advance of the 180-day requirement.
50

MD-715 – Part H

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

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

EEO program.

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

Objective(s) and Dates for EEO Plan

Date 

Initiated 

(mm/dd/yyyy)

Objective Target Date 

(mm/dd/yyyy)

Modified 

Date 

(mm/dd/yyyy)

Date 

Completed 

(mm/dd/yyyy)

10/01/2022 To include EEO Director in meetings that 

involve strategic planning, recruitment 

strategies, vacancy projections, 

succession planning, and selections for 

training/career development opportunities.

09/31/2023 NA NA

Responsible Official(s)

Title Name Performance Standards Address the 

Plan?

(Yes or No)

Chief Management Officer Alice Maroni No

Human Capital Director Arrie Etheridge No

OEEO Director Brenecia Watson No

Planned Activities Toward Completion of Objective

Target Date 

(mm/dd/yyyy)

Planned Activities Sufficient 

Funding & 

Staffing? 

(Yes or No)

Modified 

Date 

(mm/dd/yyyy)

Completion 

Date 

(mm/dd/yyyy)

09/31/2023 OEEO and HR Directors to 

meet semiannually to discuss 

PBGC’s recruitment strategy.

Yes 10/01/2022 NA

Report of Accomplishments

Fiscal Year Accomplishments

NA Objective initiated in FY2022
51

MD-715 – Part H

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

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

EEO program.

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

Statement of Model Program Essential Element Deficiency

Type of Program 

Deficiency

Brief Description of Program Deficiency

E – Efficiency: A fair 

and impartial 

complaints resolution 

process.

PBGC does not require managers and supervisors to participate in ADR 

once it has been offered.

Objective(s) and Dates for EEO Plan

Date 

Initiated 

(mm/dd/yyyy)

Objective Target Date 

(mm/dd/yyyy)

Modified 

Date 

(mm/dd/yyyy)

Date 

Completed 

(mm/dd/yyyy)

10/01/2022 To require participation in the ADR 

process once it has been deemed 

appropriate by OEEO as a means to 

resolution.

09/31/2023 NA NA

Responsible Official(s)

Title Name Performance 

Standards 

Address the 

Plan?

(Yes or No)

General 

Counsel

Karen Morris No

Planned Activities Toward Completion of Objective

Target Date 

(mm/dd/yyyy)

Planned Activities Sufficient 

Funding & 

Staffing? 

(Yes or No)

Modified 

Date 

(mm/dd/yyyy)

Completion 

Date 

(mm/dd/yyyy)

09/31/2023 Develop an Alternate Dispute 

Resolution Policy.

Yes 10/01/2022 NA

Report of Accomplishments

Fiscal Year Accomplishments

NA Objective initiated in FY2022
52

MD-715 – Part I

Agency EEO Plan to Eliminate Identified Barrier

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

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

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

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

Source of the 

Trigger

Specific 

Workforce 

Data Table 

Narrative Description of Trigger

Hispanic 

representation 

in PBGC is 

below the 

CLF 

benchmark

All Data 

Tables

OEEO continued to conduct its barrier analysis with the review of FY 

2022 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 continue to 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: 

(updated)

It should be noted, that during FY 2022, both Hispanics males and 

females occupied 1.32% of Grade GS-15 and neither group had 

representation in the SL ranks. Both percentages are below the 

benchmark identified in the chart above.

Hispanics had a total separation rate of 2.47% for males, which is 

higher than their representation in the agency. Females separated at 

a total rate 1.23%, which is at parity with their representation in 

PBGC’s workforce.

EEO Group(s) Affected by Trigger

EEO Group

Hispanic or Latino Males – YES

Hispanic or Latino Females – YES
53

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

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 for PBGC’s 

mission-critical occupations and representation at the GS-15 and SL grade level.
54

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 thru 

SL grade representation 

where Hispanics are below 

their benchmark’s 

representation. Continue to 

work with management and 

staff to investigate red flags 

and develop effective 

strategies and action plans. 

Continue to provide 

recommendations to 

organizational management 

to mitigate identified red flags

before they become barriers.

October 1, 

2016

September 

30, 2025

Yes October 1, 

2022

Efforts are 

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

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, 2022

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, 2022

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, 2022

Ongoing

September 

30, 2025

OEEO’s Affirmative Employment Committees

will continue to sponsor workshops regarding 

proactive career development.

September 

30, 2022

Ongoing
55

Report of Accomplishments 

Fiscal Year Accomplishments

FY 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.

FY 2022 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 2022 HRD continued its longstanding partnership with the Hispanic 

Association of Colleges and Universities (HACU)/National Internship 

Program with a dedicated HACU Program Coordinator

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 2022 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.
56

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 56.5% and males at a rate 

of 43.5%. The representation rates of females by race and ethnicity, and in 

comparison to their representation rate in the total workforce, which is the 

benchmark for grades, is reflected in the following charts: 

From FY 2021 to FY 2022, representation rates remained consistent amongst all 

demographics. Black and Hispanic females are consistently represented at a 

rate below their benchmark and Asian females are consistently below their SL 

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

benchmark for grades GS-14 thru SL. The rates are represented in the following 

graphs:

6.33%

21.08%

1.51%

19.58%

6.19%

20.20%

0.98%

20.85%

Asian Black Hispanic White

GS-14 by Race & Ethnicity

2022 2021
57

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.

Grievance Data (Trends) No

Findings from Decisions 

(e.g., EEO) 

No

Source of the 

Trigger

Specific 

Workforce 

Data 

Table 

Narrative Description of Trigger

It should be noted that demographics not reflected in the charts are at parity to 

their benchmark representation. 

7.89%

13.82%

1.32%

26.97%

7.43%

15.54%

2.03%

27.03%

Asian Black Hispanic White

GS-15 by Race & Ethnicity

2022 2021

2.70%

8.11%

0.00%

35.14%

2.70%

8.11%

0.00%

32.43%

Asian Black Hispanic White

SL by Race & Ethnicity

2022 2021
58

Sources of Data Source 

Reviewed?

(Yes or No)

Identify Information Collected

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. (Affinity Chats)

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
59

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

09/30/2022

09/30/2022

Provide tools and resources to 

organizational leadership that

supports equal employment 

opportunity programs.

06/01/2018 Ongoing

Yes

09/30/2022

09/30/2022

Advocate for career 

development programs that 

support professional 

development and growth.

05/01/2019 Ongoing

Yes

09/30/2022

09/30/22

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 

September 30, 

2025

Continued review of the applicant pool data to 

identify trends/barriers in hiring and selection of 

female employees and continue to investigate 

data to identify causes that impede GS-14 thru 

SL grades representation in comparison to the 

benchmarks.

September 

30, 2022

September 30, 

2025

September 30, 

2025

PBGC’s HR Department, Learning & 

Development Division, Affinity Groups, and 

OEEO continue to be a source of information for 

career enhancement efforts for all of PBGC’s 

workforce.

September 

30, 2022

September 30, 

2025

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, 2022

September 30, 

2025

September 30, 

2025

OEEO’s Affirmative Employment Committees 

will continue to sponsor workshops regarding 

proactive career development.

September 

30, 2022

September 30, 

2025
60

Report of Accomplishments 

Fiscal Year Accomplishments

FY 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.

FY 2022 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 2022 HRD continued its longstanding partnership with the Hispanic 

Association of Colleges and Universities (HACU)/National Internship 

Program with a dedicated HACU Program Coordinator

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 2022 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.
61

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 0 No X

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

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
62

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:

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

(Name, Title, Office, Email)

Full 

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 Coordinator 

HRD;beasley.donald@pbgc.gov;

Denorse Prince DEIA Program 

Manager, HRD, 

prince.denorse@pbgc.gov
63

Disability Program Task # of 

FTE

Staff 

by

Employment 

Status

Responsible Official

(Name, Title, Office, Email)

Processing reasonable 

accommodation requests 

from applicants and 

employees

1 Donald Beasley, Selective 

Placement Coordinator 

HRD;beasley.donald@pbgc.gov;

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, 

watkins.angela@pbgc.gov

Architectural Barriers Act 

Compliance

1 Delilah LumHo

Manager, Facilities and Services 

Division, 

lumho.delilah@pbgc.gov

Special Emphasis Program 

for PWD and PWTD

1 1 Denorse Prince

Special Emphasis Program 

Manager,

prince.denorse@pbgc.gov

Kierra Evans, Pathways Intern 

evans.kierra@pbgc.gov

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

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

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

Yes X No 0

Staff members attended The Department of Veterans Affairs-VRE training courses on: MultiGenerational 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.

Yes X No 0

PBGC’s Human Resources Department 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 
64

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. 

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” 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. 
65

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.

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

h. 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.

A. Advancement Program Plan

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

advancement.
66

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

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 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.

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(

%)

Internship Programs 1054 29 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

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. 
67

3. Do triggers exist for PWTD among the applicants and/or selectees for any of the career 

development programs identified? (The appropriate benchmarks are the relevant applicant pool 

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

box.

a. Applicants (PWTD) Yes 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
68

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
69

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
70

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.

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
71

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.

a. Voluntary Separations (PWTD) Yes 0 No X

b. Involuntary Separations (PWTD) Yes 0 No X

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

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

Not Applicable

B. Accessibility of Technology and Facilities

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

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

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

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

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

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

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

description of how to file a complaint. 

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

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

section).

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

providing access to its Web pages to all people-disabled or not-seeking information about PBGC. 

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

ensure effective communication with applicants, participants, personnel of other Federal entities, and 

members of the public.

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

any material on this Web site interferes with your ability to access information, please contact the 

PBGC Webmaster 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.
72

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.
73

(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.

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 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.
74

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. 

Trigger 1

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.

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
75

Sources of Data

Sources 

Reviewed?

(Yes or No)

Identify Information Collected

Exit Interview Data No

Focus Groups Yes

Perceptions of persons 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

September 30, 

2025

HRD will continue to train and educate 

on disability topics, including mandatory 

RA training for managers and 

supervisors. 

Yes September 

30, 2022

September 30, 

2025

September 30, 

2025

The agency will continue to operate a 

robust inter-departmental Section 508 

Compliance Team and offer hands-on 

Section 508 accessibility training and 

awareness to all employees.

Yes September 

30, 2022

September 30, 

2025

September 30, 

2025

OEEO will continue to explore how it 

can enhance programs for PWD and 

PWTD.

Yes September 

30, 2022

September 30, 

2025

Fiscal 

Year

Accomplishments

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

disability awareness, reasonable accommodations.

FY 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.

FY 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.

FY 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.

FY 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.
76

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.
77

Appendix