U.S. SECURITIES AND 

EXCHANGE COMMISSION 

FISCAL YEAR 2019 

EQUAL EMPLOYMENT 

OPPORTUNITY 

AFFIRMATIVE ACTION PLAN FOR THE 

RECRUITMENT, HIRING, ADVANCEMENT, AND 

RETENTION OF PERSONS WITH DISABILITIES 
Some information referenced in this report has been redacted to protect privacy. 

Please contact the Director of the SEC’s Ofce of Equal Employment Opportunity 

at 202-551-6040 or OEEO@sec.gov to request access to non-public information. 
CONTENTS 

SPECIAL PROGRAM PLAN FOR THE RECRUITMENT, HIRING, ADVANCEMENT, 

AND RETENTION OF PERSONS WITH DISABILITIES 1 

Section I: Efforts to Reach Regulatory Goals 1 

Section II: Model Disability Program 5 

Plan to Provide Suffcient & Competent Staffng for the Disability Program 5 

Plan to Ensure Suffcient Funding for the Disability Program 6 

Section III: Plan to Recruit and Hire Individuals with Disabilities 7 

Plan to Identify Job Applicants with Disabilities 7 

Plan to Establish Contacts with Disability Employment Organizations 10 

Progression Towards Goals (Recruitment and Hiring) 10 

Section IV: Plan to Ensure Advancement Opportunities for Employees with Disabilities 15 

Advancement Program Plan 15 

Career Development Opportunities 16 

Awards 21 

Promotions 24 

Section V: Plan to Improve Retention of Persons with Disabilities 33 

Voluntary and Involuntary Separations 33 

Accessibility of Technology and Facilities 36 

Reasonable Accommodation Program 38 

Personal Assistance Services Allowing Employees to Participate in the Workplace 41 

Section VI: EEO Complaint and Findings Data 42 

EEO Complaint Data Involving Harassment 42 

EEO Complaint Data Involving Reasonable Accommodation 42 

Section VII: Identifcation and Removal of Barriers 43 

Prepared by 

THE OFFICE OF EQUAL EMPLOYMENT OPPORTUNITY 

FISCAL YEAR 2019 | iii
This page intentionally left blank
SPECIAL PROGRAM PLAN FOR 

THE RECRUITMENT, HIRING, 

ADVANCEMENT, AND RETENTION OF 

PERSONS WITH DISABILITIES 

To capture agencies’ affrmative action plan for persons with disabilities (PWD) and persons with 

targeted disabilities (PWTD), EEOC regulations (29 C FR § 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 

SECTION I: EFFORTS TO REACH REGULATORY GOALS 

EEOC regulations (29 C FR § 1614 203(d)(7)) require agencies to establish specifc numerical goals 

for increasing the participation of persons with reportable and targeted disabilities in the federal 

government 

1 Using the goal of 12% as the benchmark, does your Agency have a trigger involving PWD by 

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

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

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

This report presents results for both persons with disabilities (PWD) and persons with targeted 

disabilities (PWTD) calculated in cluster results based on the locality adjusted salary specifed 

in the revised regulations implementing Section 501 of the Rehabilitation Act of 1973, 

compared to the locality adjusted salary of a GS-11, step 1, in the Washington, DC area For 

FY 2019, that salary was $69,581 Participation of PWD and PWTD are presented to assess 

against the specifc numerical goals found in EEOC regulations to identify the presence of any 

triggers A trigger is a trend, difference, variance, outlier, or anomaly that suggests the need for 

further inquiry into a particular policy, practice, procedure, or condition Statistics are only a 

starting point for analysis, which considers the totality of the circumstances 

For employees with salaries below a GS-11, step 1, the Agency achieved the numerical goal 

for PWD participation; 43 75% of employees in this cluster were PWD compared to the 

12% benchmark See Table B5-1. 

Continued on the next page 

FISCAL YEAR 2019 | 1
In FY 2019, SEC included permanent and temporary employees hired under authorities that 

take disability into account as PWD under hiring authority pursuant to EEOC regulation 

In this report, permanent and temporary employees who are not self-identifed on standard 

form 256 (SF-256) and whose personnel record documents veterans’ preference for hiring 

as “CPS—preference based on compensable service-connected disability of 30% or more” 

are included in the total PWD workforce data tables Similarly, permanent and temporary 

employees not self-identifed on SF-256 and whose personnel record documents that they 

were hired or converted into the competitive service under Schedule A, part u (5 C FR §

213 3102(u) Appointment of persons with intellectual disabilities, severe physical disabilities, 

or psychiatric disabilities) are included in the total PWD workforce for purposes of utilization 

analysis This action added 41 permanent employees to the PWD workforce data The 

workforce data tables included with this report1 and the analyses described in Parts J and 

below refect this change Prior year data for such employees was updated for comparison 

For employees with locality adjusted salaries above a GS-11, step 1, the Agency did not 

achieve the numerical goal involving PWD; 8 59% of employees in this cluster were PWD 

compared to the 12% benchmark While the numerical goal was not achieved, the current 

participation rate represents an increase of 2 24 percentage points since the end of FY 2015 

Between FY 2015 and FY 2019, the participation of PWD in the total workforce increased 

from 6 57% to 8 64%; participation increased in both the lower and higher salary clusters 

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

Applying the same salary clusters to PWTD as previously described, the SEC achieved 

the numerical goal established for PWTD in the lower salary cluster during FY 

2019 In the lower salary cluster, 6 25% of 16 permanent employees are PWTD The 

numerical goal for PWTD among higher salaried employees was fve one hundredths 

of a percent below the goal; 1 95% of higher salaried employees are PWTD 

In the workforce data Tables B1 through B9 accompanying this report, such employees are reported under the column 

titled “Other PWD” and combined with self-identifed employees in the column titled “Total PWD” As per guidance 

from EEOC, in EEOC’s data portal, FedSEP, SEC reports such persons in Tables B1 through B9 in the column labeled: 

“Disability (02-03, 06-99) ” 

2 | EEO AFFIRMATIVE ACTION PLAN 

1 
3 Describe how the Agency has communicated the numerical goals to the hiring managers 

and/or recruiters 

Hiring goals for PWTD (i e , 2% of the total workforce) are communicated to hiring managers 

during quarterly Offce of Human Resources Steering Committee meetings Additionally, metrics for 

disability hiring are published monthly and at the end of the year by the SEC’s Offce of the Chief 

Operating Offcer The overall percentage of employees who are PWTD is posted in the Diversity 

Dashboard sponsored by OMWI and the Diversity Council 

To augment these information sources, OHR implemented the Human Capital Reporting & 

Analytics (HCRA) dashboard in the second half of FY 2018 and continued to support managers 

in FY 2019 The HCRA provides, among other key human capital metrics, aggregate data on 

the disability status for self-identifed PWD and PWTD A series of data flters enable leaders 

to understand employee gains and losses within their particular Division or Offce for specifc 

occupations, grades, and duty stations OHR plans to use this information to support Human 

Capital strategic planning 

Throughout FY 2019 and particularly during National Disability Employment Awareness Month 

in October 2018, the Agency hosted events that focused on inclusion of persons with a disability 

As described later, these events were often sponsored and/or hosted by the Disability Interests 

Advisory Committee (DIAC) In opening and/or closing remarks, leaders noted the Agency’s goals 

for recruiting and hiring PWD, frequently mentioning the high value such employees bring to the 

Agency’s mission 

Relatedly, OHR has developed an updated 2020-2022 Recruitment Strategy, which describes the 

support and collaboration necessary from senior leadership, OEEO, and OMWI to recruit a diverse 

candidate base The Recruitment Strategy includes the following goals, among others: 

n	Build a pipeline of qualified Schedule A applicants; and 

n	Improve Veteran recruitment efforts 

The Recruitment Strategy specifcally denotes an objective to “Increase workforce 

representation for people with disabilities and people with targeted disabilities ” Specifc 

strategies and tasks in the plan for recruitment explain how this objective will be 

accomplished 

Continued on the next page 

FISCAL YEAR 2019 | 3
For specifc hiring actions, OHR continues to address special hiring authorities, including 

Schedule A, in conversations with hiring managers to reinforce progress toward achieving 

numerical goals A checklist is used by OHR Staffng specialists when vacant positions are 

identifed to ensure hiring managers understand all their options for flling positions, including 

using Schedule A and veterans’ hiring authorities for those applicants with a service-connected 

disability of 30% or more 

OEEO led periodic meetings with a cross-functional working group comprised of 

representatives from OHR and OMWI, including those who support recruiting, to discuss 

MD-715 and the Agency’s progress related to equal employment opportunity, participation, 

and inclusion of employees and applicants for employment For these meetings, OEEO 

provided up-to-date information from the Agency workforce data tables and highlighted areas 

for discussion, including goals and progress related to the participation and inclusion of PWD 

and PWTD 

4 | EEO AFFIRMATIVE ACTION PLAN 
SECTION II: MODEL DISABILITY PROGRAM 

Pursuant to 29 C FR § 1614 203(d)(1), agencies must ensure suffcient 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 

Plan to Provide Sufcient & Competent Stafng for the Disability Program 

1 Has the Agency designated suffcient qualifed personnel to implement its disability program 

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

upcoming year 

Yes X No 0 

The Agency designates talent acquisition resources and FTE to Special Programs classifcation, 

recruitment, and staffng in support of the disability program 

2 Identify all staff responsible for implementing the Agency’s disability employment program by the 

offce, staff employment status, and responsible offcial 

Disability Program Task 

Number of Full-Time Equivalent Staff 

by Employment Status 

Responsible Official

Full Time Part Time (Name, Title, Office, Email)

Collateral 

Duty 

Processing applications from PWD 

and PWTD 

13 0 0 Kai Petty, Lead HR Specialist 

Office of Human Resources

pettyka@sec.gov 

Answering questions from the public

about hiring authorities that take

disability into account

13 0 0 Kai Petty, Lead HR Specialist 

Office of Human Resources

pettyka@sec.gov 

Processing reasonable

accommodation requests from

applicants and employees 

3 0 0 Dia Gonsalves, 

Disability Program Officer

Office of Human Resources

gonsalvesd@sec.gov 

Section 508 Compliance 1 0 0 Sharvon Jones, Governance Branch, 

Office of Information Technology

jonessh@sec.gov

Architectural Barriers Act Compliance 0 0 3 Ray Ferrari, RA, LEED AP, Architect,

Office of Support Operations (OSO)-Office

of Building Operations (OBO)

FerrariR@sec.gov

Jinhee Kim, RA, LEED AP, Architect,

OSO-OBO

KimJin@sec.gov

Carla Hairston; NCIDQ, COEE,

OSO-OBO

HairstonC@sec.gov

Special Emphasis Program for PWD

and PWTD 

2 0 0 Xiya Li, Branch Chief

Office of Human Resources

lixiy@sec.gov 

Kai Petty, Lead HR Specialist 

Office of Human Resources

pettyka@sec.gov 

FISCAL YEAR 2019 | 5
3 Has the Agency provided disability program staff with suffcient 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 

The two and a half full-time employees who work on the disability program staff came 

to the Agency with signifcant HR experience in the federal government, but were new to 

reasonable accommodation programs and the responsibilities inherent in responding to 

reasonable accommodation requests They received on-the-job training from the Disability 

Program Offcer and departing Reasonable Accommodation Coordinator and periodically 

attended training programs and reviewed recent case law to stay apprised of the current 

developments in this area Additionally, the Disability Program Offcer, representing the 

half-time employee, also responded to reasonable accommodation requests when possible 

while managing a diverse portfolio of other HR programs The Disability Program Offcer 

completed courses specifc to recruiting, accommodating, hiring, and retaining PWD via 

OPM’s HR University and the SEC’s Learning Management System, LEAP, in addition to 

the general training received 

More generally, all of the SEC’s HR specialists have completed training courses related 

to staffng and placement offered by the USDA Graduate School or OPM and through 

various other platforms The Agency’s training and development offce also offers learning 

options that include processing applications for PWD The Agency will continue these 

practices in the future 

Changes are planned in line with implementation of requirements and recommendations 

under Section 501 of the Rehabilitation Act Those changes will require more focused and 

specifc training on related policy and procedure post implementation for both HR specialists 

and disability program staff 

Plan to Ensure Sufcient Funding for the Disability Program 

1 Has the Agency provided suffcient 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 suffcient funding and other resources 

Yes X No 0 

The Agency was resourced adequately during the reporting period to implement the disability 

program successfully 

6 | EEO AFFIRMATIVE ACTION PLAN 
SECTION III: PLAN TO RECRUIT AND HIRE INDIVIDUALS WITH 

DISABILITIES 

Pursuant to 29 C FR § 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 

Plan to Identify Job Applicants with Disabilities 

1 Describe the programs and resources the Agency uses to identify job applicants with disabilities, 

including individuals with targeted disabilities 

OHR continued to take steps toward improving the participation of PWD and PWTD 

in applicant pools Since focusing on these efforts under OHR’s 2018-2019 Recruitment 

Strategy, the SEC has realized an increase in the overall representation of people with 

disabilities through effective recruitment and outreach efforts that identify the Agency as an 

employer of choice 

Despite the government shutdown, the Agency maintained a physical recruitment presence 

in FY 2019 The SEC attended over 17 career fairs and events supporting efforts in building 

pipelines for future employment 

The SEC is committed to being a model employer for people with disabilities; as such, the 

SEC introduced a more direct and streamlined approach to the general hiring process using 

the Schedule A hiring authority for persons with disabilities This streamlined approach 

required all external hiring requests be fltered through the Selective Placement Program 

Coordinator (SPPC) for review The SPPC referred qualifed applicants to hiring managers 

prior to or concurrently with the general staffng process OHR will continue to leverage the 

DIAC for recruitment resources and assistance Further, OHR will continue to retain and 

review applications from people with disabilities for future openings and will conduct targeted 

outreach to connect with qualifed candidates by collaborating with community-based 

partners such as nonproft organizations, national and local disability organizations, and 

federally funded state and local employment programs 

FISCAL YEAR 2019 | 7
2 Pursuant to 29 C F R § 1614 203(a)(3), describe the Agency’s use of hiring authorities that 

take disability into account (e g , Schedule A) to recruit PWD and PWTD for positions in the 

permanent workforce 

The Agency uses a variety of available resources that support hiring through Schedule A 

and other hiring authorities that take disability into account During FY 2019, the Special 

Programs Manager continued to source potential candidates from available resources such as 

OPM’s Shared List of People with Disabilities 

The Special Programs Manager receives notifcations and newsletters from the following 

groups and transmits information to OHR staff engaged in recruiting: 

n	EARN—Employer Assistance Resource Network: askearn org 

n	JAN—Job Accommodation Network: askjan org 

n	ODEP—Office of Disability Employment Policy, Department Of Labor: 

dol gov/odep/ 

n	OWF—Operation Warfighter Program: warriorcare dodlive mil/carecoordination/ 

operation-warfighter/ 

3 When individuals apply for a position under a hiring authority that takes disability into account 

(e g , Schedule A), explain how the Agency (1) determines if the individual is eligible for 

appointment under such authority and (2) forwards the individual’s application to the relevant 

hiring offcials with an explanation of how and when the individual may be appointed 

The following describes two procedures for processing applications under the Schedule A hiring 

authority for persons with disabilities, one used in response to a specifc vacancy posting and the 

other for unsolicited Schedule A applications 

The Offce of Human Resources processes Schedule A applications in response to a Job 

Opportunity Announcement (JOA). 

Applicants who wish to be considered for a specifc vacancy under the Schedule A hiring 

authority must submit the appropriate documentation when applying for a current open JOA 

The SEC defers to the OPM-identifed appropriate documentation Applications are reviewed by 

HR specialists to determine if the applicant is minimally qualifed as identifed in the JOA If the 

applicant is minimally qualifed, that individual is referred to the hiring manager on a separate 

certifcate of eligible candidates HR specialists provide written guidance to hiring managers via 

email that explains how Schedule A applicants can be selected once the certifcate has been issued 

Continued on the next page 

8 | EEO AFFIRMATIVE ACTION PLAN 
The Offce of Human Resources also processes unsolicited Schedule A applications. 

Applicants who wish to be considered under the Schedule A hiring authority, outside the process 

for a specifc vacancy posting, must submit the appropriate documentation as identifed by OPM 

with their application The Special Programs Manager will proactively contact the prospective 

applicant if the individual did not submit the required documentation The application will not be 

processed until the appropriate documentation is received 

Resumes submitted directly to the Special Programs Manager are reviewed to determine the 

potential job series the applicant may be suitable for based on the knowledge, skills, and abilities 

identifed on the applicant’s resume Building a pool of qualifed candidates is important to the 

SEC; as such, the Agency has developed a Schedule A Resume Database 

The SEC process for hiring starts with a Staffng Action Request Form (SARF) submitted by the 

hiring manager When a SARF is received by OHR, the Special Programs Manager compiles a 

certifcate of eligible candidates from the database per the job series and refers candidates to hiring 

managers In some cases, the Special Programs Manager conducts a one-on-one consultation with 

the hiring manager to discuss the certifcate of eligible candidates, as appropriate 

The SEC’s administrative regulations on its Veterans Employment Program provides instruction 

for hiring veterans with disabilities and was last updated in January 2017 The Agency’s 

administrative regulations are available upon request 

4 Has the Agency provided training to all hiring managers on the use of hiring authorities that take 

disability into account (e g , Schedule A)? If “yes”, describe the type(s) of training and frequency If 

“no”, describe the agency’s plan to provide this training 

Yes X No 0 N/A 0 

OHR partnered with the DIAC to host the frst Hiring Manager’s Forum on Schedule A 

Disability and Veterans’ hiring authorities in an effort to further educate SEC hiring managers 

and promote the use of such authorities The event was sponsored by SEC leadership and 

featured an in-depth presentation by the Special Hiring Programs Manager, a panel discussion 

with senior managers from across the Agency who shared their experience using Schedule A 

to hire staff, and a Q&A session 

In FY 2019, periodic training occurred with each hiring manager who requested to fll a 

position The hiring checklist used by the staffng specialists contains a Schedule A section 

that is discussed in-depth during the one-on-one hiring conversation The specialist trains the 

hiring manager on the various procedures of the Schedule A hiring process and offers it as a 

course of action where applicable 

Continued on the next page 

FISCAL YEAR 2019 | 9
In FY 2019, the Agency successfully recruited and hired staff through Schedule A following 

two years of no Schedule A hiring In addition, recruitment under Schedule A procedures 

led to the eventual hire of a veteran with a service-connected disability directly into the 

competitive service DIAC and the Disability Program Offce will continue to promote such 

successful Schedule A hiring to support the Agency’s Strategic Recruitment Plan amongst 

hiring managers 

The Disability Program Manager speaks at DIAC meetings/events on a regular and recurring 

basis on a variety of topics, including the hiring authorities that take disability into account 

Plan to Establish Contacts with Disability Employment Organizations 

1 Describe the Agency’s efforts to establish and maintain contacts with organizations that assist 

PWD, including PWTD, in securing and maintaining employment 

The SEC’s Special Programs Manager continued to maintain established partnerships 

with organizations that assist PWD in securing and maintaining employment The Special 

Programs Manager updates the SEC’s list of affnity organizations to maintain contact and 

foster relationships for recruitment events and candidate sourcing 

The SEC is currently exploring a potential partnership with Broad Futures, which is a 

DC-based organization that places students with learning disabilities into government and 

private sector internships The SEC plans to explore this partnership further in FY 2020 

The Special Programs Manager maintains an ongoing relationship with the SEC’s DIAC 

and the Veterans Committee 

The SEC continued the pilot of the Operation Warfghter Program (OWF) during FY 2019 

OWF is an internship program created by the Department of Defense that matches qualifed 

wounded, ill, and injured service members with non-funded federal internships for them 

to gain valuable work experience during recovery and rehabilitation The SEC is fnalizing 

program policies and procedures and plans to implement Agency-wide in FY 2020 

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 X No 0 

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

10 | EEO AFFIRMATIVE ACTION PLAN 
Data from FY 2019 presented in Table B1 were reviewed for evidence of differences in hiring 

into the permanent workforce The Agency did not achieve a 12% participation rate for PWD 

among new hires in the permanent workforce The Agency did achieve the numerical goal of 

2% participation of PWTD among permanent new hires In FY 2019, the Agency hired 53 

permanent employees, among them were fve (9 43%) employees who are PWD and three 

(5 66%) PWTD 

2 Using the qualifed applicant pool as the benchmark, do triggers exist for PWD and/or PWTD 

among the new hires for any of the mission-critical occupations (MCO)? If “yes”, please describe 

the triggers below 

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

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

In FY 2019, Table B6 was reviewed for evidence of triggers in the hiring of permanent 

employees into MCO positions From these data, no PWD or PWTD applicants were found 

qualifed for two out of fve of the MCO positions, securities compliance examiner and 

economist, and no PWTD were found in the qualifed applicant pool for accountants PWD 

were found in the qualifed applicant pools for attorneys, accountants, and IT management 

specialists; qualifed applicants for attorney and IT management positions also included 

PWTD In FY 2019, the SEC hired and onboarded a total of 53 permanent staff employees 

Among these newly hired staff members were 39 persons in MCO positions, 28 attorneys, 

eight IT management specialists, two securities compliance examiners, and one accountant 

Three of those 39 (7 69%) newly onboarded MCO permanent staff were PWD and two 

were also PWTD [Redacted to protect privacy.] These were the only PWD or PWTD hired 

into MCO positions during FY 2019 

To assess these differences, the percentage of PWD in the permanent new hires for each 

occupation was compared to the qualifed applicant pool (QAP) As described above, 

the applicant fow data summarizes the phases of the hiring process through selection for 

vacancies that were posted and closed through USAJOBS during the fscal year The data 

in Table B6 refect the pool of qualifed applications for permanent vacancies announced 

through USAJOBS during FY 2019 In FY 2019, OPM implemented a number of actions to 

help agencies in their analysis of AFD OPM: (1) made information about appointment type 

(permanent or temporary) available for each vacancy; (2) created a variable so that agencies 

can more easily identify supervisory versus non-supervisory vacancies; and (3) changed 

Continued on the next page 

FISCAL YEAR 2019 | 11
AFD so that all applications submitted by the same applicant refected a unique identifer, 

providing valuable data for agencies to analyze and identify demographic trends for successful 

and unsuccessful applicants In future years’ reports, we anticipate fully leveraging OPM’s 

FY 2019 changes to AFD, namely, the ability to identify trends in successful and unsuccessful 

applicants based on demographic groups 

Table B6 also presents data on permanent new hires on boarded during the course of the fscal 

year Some newly hired staff applied for a vacancy posted in a prior fscal year or may have 

elected not to volunteer demographic information Differences may be observed in comparing 

the demographic statistics of the QAP and that of new hires on boarded Triggers comparing 

the composition of PWD and PWTD in applicant fow versus new hire data should be 

interpreted with these differences in mind 

Triggers were observed for PWD in the hiring of permanent staff attorneys and accountants 

For PWTD, triggers were found for the attorney and IT management occupations 

PWD represent 3 57% of 28 newly hired permanent staff attorneys, which is below their 

participation (5 34%) in the QAP For attorneys, the QAP for PWTD was 1 13%; no PWTD 

(0 00%) were hired as permanent staff attorneys 

One newly hired permanent employee in FY 2019 was an accountant, who was neither 

PWD nor PWTD Two PWD were found among the QAP for accountant at 1 96%; this 

difference represents a trigger for the accountant occupation amongst PWD No PWTD 

were found in the QAP for accountants, and none were hired; as such, no difference in 

participation was observed 

For securities compliance examiner vacancies posted in FY 2019, no PWD or PWTD were 

found in the QAP, and none were hired As such, no difference in participation was observed 

For IT management, eight employees were hired as permanent staff in FY 2019 The QAP 

was 18 96% PWD and 2 68% PWTD, and PWD participation among new hires exceeds 

that of the QAP, and PWTD also exceeded their participation amongst the QAP [Redacted to 

protect privacy.] 

Finally, for economists, no permanent staff economist positions were posted in FY 2019; as 

such, there was no opportunity to observe triggers in the hiring of permanent staff economists 

12 | EEO AFFIRMATIVE ACTION PLAN 
3 Using the relevant applicant pool as the benchmark, do triggers exist for PWD and/or PWTD 

among the qualifed internal applicants for any of the mission-critical occupations (MCO)? If 

“yes”, please describe the triggers below 

a. Qualifed Applicants for MCO (PWD) Yes X No 0 

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

In the FY 2019 data presented in Table B6, differences were identifed in the participation 

of PWD in the qualifed internal applicants for competitive promotions as compared to the 

relevant applicant pool (RAP) within four of the SEC’s MCOs, i e , attorney, accountant, 

securities compliance examiner, and IT management Differences were also identifed between 

the RAP and QAP for PWTD within the internal competitive promotion data for the MCOs 

of attorney, accountant, securities compliance examiner, and IT management 

The RAP was defned for each MCO based on the number of employees holding a qualifying 

occupation series and in the SK-levels encumbered at the Agency between SK-11 and SK-16 

Specifcally, for attorneys, the RAP included all employees in the 0905 series For accountants, 

the RAP included all employees in the 0510 series For securities compliance examiners, 

the RAP included all employees in the 1831 and the 0501, Financial Administration and 

Program series For the information technology management occupation, the RAP included 

all employees in the 2210 series, and for the economist occupation, the RAP included all 

employees in the 0110 series 

For attorneys, the RAP for PWD was 5 54%, and PWD represented 4 52% of the qualifed 

internal applicants The RAP for PWTD was 1 15%, and PWTD were 0 00% of the qualifed 

internal applicants for attorneys The Agency observed a small difference between the RAP 

and the qualifed applicants for attorney internal promotions of PWD and PWTD 

For accountants, the RAP for PWD was 5 51%, and PWD were 13 33% of the qualifed 

internal applicants However, no PWD were referred or selected The RAP for PWTD was 

0 90%, and no PWTD applied, suggesting a negligible difference 

For securities compliance examiners, the RAP for PWD was 7 45%, and PWD represented 

5 56% of the qualifed internal applicants The RAP for PWTD was 1 55%, and no 

PWTD applied 

For IT management, the RAP for PWD was 11 90% There was a decline in percentage PWD 

from the applied stage (16 71%) to the qualifed stage (8 67%) that brought the percentage of 

qualifed applicants below the RAP The RAP for PWTD was 1 12%, and PWTD represented 

0 67% of the qualifed internal applicants, suggesting a negligible difference 

For economists, no vacancies were posted for permanent promotion As such, no PWD or 

PWTD were found in either the RAP or the qualifed internal applicant pool; therefore, no 

difference was found in participation for this occupation 

FISCAL YEAR 2019 | 13
4 Using the qualifed 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 X No 0 

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

The selection data indicate a difference for PWD in the attorney, accountant, securities 

compliance examiner, and IT management occupations No competitive promotions were 

made amongst permanent staff economists in FY 2019 There was no opportunity to observe 

triggers for this MCO 

A difference was observed among PWD attorneys The QAP for PWD was 4 52%, and PWD 

represented 2 78% of selections There were no PWTD in the QAP, and as such there was no 

basis for comparison 

For accountants, the QAP for PWD was 13 33% (two applicants), and no PWD were 

selected There were no PWTD in the QAP, and as such there was no basis for comparison 

For securities compliance examiners, the QAP for PWD was 5 56% (one applicant), and 

no PWD were selected For IT management specialists, the QAP for PWD was 8 67%, and 

PWD were 11 11% of selections, indicating an increase in percentage PWD from the qualifed 

to the selection stage For PWTD, the QAP for IT management specialists was 0 67% (one 

applicant), and no PWTD were selected 

14 | EEO AFFIRMATIVE ACTION PLAN 
SECTION IV: PLAN TO ENSURE ADVANCEMENT OPPORTUNITIES FOR 

EMPLOYEES WITH DISABILITIES 

Pursuant to 29 C FR § 1614 203(d)(1)(iii), agencies are required to provide suffcient 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 

Advancement Program Plan 

1 Describe the Agency’s plan to ensure PWD, including PWTD, have suffcient opportunities 

for advancement 

To promote equal employment opportunity, the Agency takes a number of steps to ensure 

that opportunities for advancement are open and available to all, including PWD and 

PWTD in the workforce Information about training, mentoring programs, and career 

development options is widely shared with the workforce The following describes efforts 

to promote opportunities for advancement 

n	OHR updated and maintains a user-friendly, interactive portal, AskHR, on the SEC’s 

intranet, which provides employees with information about hiring, compensation 

and benefits, employee development, performance management, and disability 

accommodations, among a number of other topics In addition, all employees receive 

a daily communication, SEC Today, which highlights important information about 

events and opportunities for details, training, and SEC staff accomplishments 

n	The CHCO is an active member of the SEC Veterans Committee, which hosts a 

website that includes information concerning veterans’ benefits, to include a link to 

the Feds Hire Vets website that highlights special hiring authorities for veterans 

n	DIAC regularly communicates with its membership, which includes PWD and 

PWTD, about its own activities, other events, developmental opportunities, and job 

postings or support available to the workforce These more targeted communications 

help ensure that PWD and PWTD are aware of the available options and any 

processes for requesting participation or enrollment 

FISCAL YEAR 2019 | 15
Career Development Opportunities 

1 Please describe the career development opportunities that the Agency provides to its employees 

The SEC provides numerous opportunities for employees to acquire the skills and 

certifcations needed to succeed in their technical positions and to progress in their careers 

Classroom-style and e-Learning programs offer an extensive array of learning opportunities 

in technical areas (e g , courses on Hedge Funds, Mutual Funds, and Credit Derivatives, etc ) 

as well as in leadership development to SEC senior leaders and non-supervisory staff alike 

Among the variety of learning and development offerings, the SEC offers the three career 

development training programs highlighted below Data on participation in these programs is 

captured along with other training program data below 

n	The Women in Leadership program is offered once a year under the auspices of the 

Brookings Institution Each year, the SEC provides either managers (SK-15 and SK-17 

supervisors) or non-managerial staff (SK-14 and SK-16 levels) the opportunity to 

participate in this leadership development program Program participants from across 

federal agencies learn how to strengthen leadership qualities and explore key elements of 

senior leadership success while maintaining authenticity and balance 

n	The EIG Fellows Program, coordinated by the Partnership for Public Service, strengthens 

the leadership skills of experienced federal employees through a combination of 

innovative coursework, best practices benchmarking, challenging action-learning projects, 

executive coaching, and government-wide networking This program is offered to SEC 

employees in the SK-14 to SK-17 (a mix of supervisory and non-supervisory) levels 

SEC’s EIG Fellows attend facilitated sessions at SEC Headquarters to share what they are 

learning and to explore how this information can be applied to improve organizational 

performance, workplace relationships, and productivity 

n	The Aspiring Leaders program is an interactive blended-learning program designed to 

strengthen the leadership and management skills of SEC non-supervisory (SK-13 and 

SK-14) employees The program covers: critical leadership skills for effective supervision; 

first-line management responsibilities; understanding government policy, process, and 

regulations relevant to management; and increasing self-awareness through guided selfassessments and feedback 

The SEC’s robust training program also offers seminars targeted to specifc audiences, 

including Senior Offcers, managers, and employees, covering relevant subject matter In FY 

2018, OHR continued to implement enhancements to its learning management system, LEAP 

Within this system’s MyCareer@SEC module, employees can fnd information about career 

paths mapped to their current position, the responsibilities and occupational requirements of 

positions in that career path, and options for training and development that would enable 

Continued on the next page 

16 | EEO AFFIRMATIVE ACTION PLAN 
them to progress toward their career goals SECU established initial career paths in FY 2017 

based on prior projects to defne competency requirements for a variety of occupations In FY 

2019, OHR and SECU also: 

n	Developed and worked with NTEU to administer a Competency Assessment Survey 

to inform workforce planning efforts and shape the future of SEC-wide training and 

development programs The survey was launched in September 2018, and data collection 

continued into FY 2019 The data gleaned from the competency survey will be used to 

enhance the value of the new LEAP career path options 

The Agency supports employees in pursuing leadership development through a variety 

of program offerings, including both individual coaching and an Agency-wide mentoring 

program Since 2012, 144 managers have completed a 12-session coaching engagement with 

an external coach Coaching with an internal certifed executive coach is not tracked, nor is 

demographic information captured, due to confdentiality 

OHR’s Human Capital Strategy Group continued working on a long term, multi-year 

planning effort for a leadership development program similar to the SES Candidate 

Development Programs offered by other federal agencies 

Relatedly, in early FY 2019, the Agency successfully launched a pilot mentoring program 

leading to the frst cohort of 30 participants who will receive mentoring throughout FY 

2019 In the frst wave, 142 permanent employees submitted a statement of interest in the 

program On a frst come, frst serve basis, 30 participants were accepted into the mentoring 

program and matched with volunteer mentors with deep technical expertise and/or leadership 

experience The SEC held formal events throughout FY 2019 to help guide the mentoring 

relationship toward success The Inaugural Mentoring Program celebrated its fnale event 

on June 26, 2019 Positive feedback about the program informed the Agency’s decision to 

institute the program ongoing In late FY 2019, OCOO was pleased to announce the launch 

of the next Mentoring Program cohort On September 23, 2019, 103 employees registered 

interest in participating in the next mentoring cohort Thirty employees were paired with 

mentors for the next cohort The SEC’s Mentoring Program will provide career development 

and support to these 30 employees from October of 2019 until the Capstone event scheduled 

for June 16, 2020 Formal program events for both mentors and participants are scheduled 

quarterly and facilitated by OCOO and SECU experts The SEC held an orientation session 

for both mentors and participants on October 28 and 29, 2019 

Participation among PWD and PWTD in the Agency’s career development opportunities is 

provided on page 150 

FISCAL YEAR 2019 | 17
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 Opportunities1 

Total Participants PWD PWTD 

Applicants

(#)

Selectees

(#)

Applicants

(%)

Selectees

(%)

Applicants

(%)

Selectees

(%)

Internship Programs 103 0 5.83% 0.00% 0.97% 0.00% 

Fellowship Programs 183 16 1.64% 0.00% 0.55% 0.00% 

Mentoring Programs 931 30 13.98% 13.33% 3.23% 3.33% 

Coaching Programs NA NA NA NA NA NA

Training Programs 1,386 1,386 10.68% 10.68% 1.80% 1.80% 

Detail Programs 178 16 1.69% 6.25% 1.12% 6.25% 

Other Career Development Programs NA NA NA NA NA NA

1 Two applicants for the mentoring program, who are serving under temporary appointments, were not included in this analysis.

Training Programs data show demographic data for all permanent employees’ registrations for training in LEAP and completed training

opportunities during FY 2019. There is no competition for training class registration. All eligible employees who register or apply are

invited or selected to complete the training course. Applicant and selectee participation records are thus identical. These Applicant

registration and Selectee participation records may include more than one training opportunity per employee, representing both

mandatory and elective courses. Therefore, the total registration and participation data exceed the total number of employees.

Detail Programs summarize information only for Temporary Promotions announced for competitive selection by the Agency. These data

do not reflect detail opportunities that do not include a change to the employee’s personnel record, e.g., a detail to a job in the same pay

grade and location. 

Notes: With more limited hiring in FY 2019, there was no recruitment or hiring of applicants for Internship programs.

The SEC does not currently have Detail Programs or Other Career Development Programs as defined for inclusion here.

Demographic data on applicants for the Agency’s Fellowship Programs are not currently captured. Neither are such data captured for

participants in Coaching Programs to protect the confidential relationship between employee and coach.

The SEC’s Mentoring Program was open for registration. Applications for the program were reviewed and paired with volunteers to serve

as mentors from among the Agency’s leadership cadre.

18 | EEO AFFIRMATIVE ACTION PLAN 
3 Do triggers exist for PWD among the applicants and/or selectees for any of the career development 

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

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

a. Applicants (PWD) Yes X No 0 

b. Selections (PWD) Yes X No 0 

From the Career Development Opportunities table above, data on the participation of PWD 

and PWTD in applications or selections for various programs were reviewed 

For the Agency’s economist and accountant Fellows programs, the Agency noted a 

difference in the participation of PWD among (external) applicants for these programs 

and eventual selections for positions While 1 64% of applicants were PWD, none of the 

Fellows hired were PWD (0 00%) 

No selections, of persons with or without disability, were eventually made among applicants 

for a Pathways Student Internship posting 

Within the Agency’s mentoring program, the Agency found no evidence of a trigger in the 

participation rate among those who expressed interest in the next cohort of the mentoring 

program (i e , applicants) as compared to participation of PWD in the permanent workforce 

While 8 72% of all permanent staff are PWD, PWD represent 13 98% of those employees who 

expressed interest in the mentoring program and 13 33% of those selected for mentoring The 

participation rate of PWD among those selected to participate in the mentoring program for FY 

2020 (i e , Selectees) approximates their participation among those expressing interest 

Aggregate PWD participation in training programs approved on standard form 182 through the 

Agency’s learning management system, LEAP, exceeds their participation on rolls; 10 68% of 

training requiring separate approval on SF-182 were completed by PWD, compared to 8 72% of 

permanent employees who are PWD PWD participation in training was higher than that among 

permanent employees; this difference was statistically signifcant (X2

 = 27 85, p< 0001) 

Data about Detailed employees show evidence of a difference disadvantaging PWD among 

those who applied for Temporary Promotion and no trigger among those selected While 1 69% 

of applicants for temporary promotion were PWD, PWD represent 8 72% of permanent staff 

employees A larger proportion of persons selected for a Temporary Promotion or Detail were 

PWD (6 25%) than were found among applicants (1 69%) 

For other Career Development Opportunities, demographic data specifc to disability status are 

not captured or maintained The Agency will continue to offer such programming and to focus 

communication efforts to encourage participation of PWD and PWTD as described above, supra 

FISCAL YEAR 2019 | 19
4 Do triggers exist for PWTD among the applicants and/or selectees for any of the career 

development programs identifed? (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 X No 0 

b. Selections (PWTD) Yes X No 0 

From the Career Development Opportunities table in Section IV2 above, data on the participation of PWTD in various programs were reviewed for equality of employment opportunity 

in the applications or selections for these programs 

Similar to the PWD data for the Agency’s economist and accountant Fellows programs combined, the Agency noted a difference in the participation of PWTD among (external) applicants for these programs and eventual selections for positions While 0 55% of applicants 

were PWTD, none of the Fellows hired (0 00%) were PWTD 

No selections, of persons with or without disability, were eventually made among applicants 

for a Pathways Student Internship posting 

Within the Agency’s mentoring program, the Agency noted no difference that disadvantaged 

PWTD in the participation rate among those who expressed interest in the mentoring program (i e , applicants), as compared to PWTD among permanent staff While 1 97% of the 

Agency’s permanent staff are PWTD, PWTD were 3 23% of those employees who expressed 

interest in the mentoring program The participation of PWTD among employees selected for 

mentoring in FY 2020 (3 33%) exceeds that among applicants No evidence of triggers were 

found in these data 

In the aggregate, training records show that PWTD participated in training programs 

approved on SF-182 through LEAP at rates below their participation on rolls; 1 88% of training opportunities requiring special approval were completed by PWTD, compared to 1 97% 

of PWTD permanent employees 

Data about Detailed employees show evidence of a difference disadvantaging PWTD among 

those who applied for Temporary Promotion and no trigger among those selected While 

1 67% of applicants for temporary promotion were PWTD, PWTD represent 1 97% of permanent staff employees A larger proportion of persons selected for a Temporary Promotion 

or Detail were PWTD (6 25%) than were found among applicants (1 67%) 

20 | EEO AFFIRMATIVE ACTION PLAN 
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 X No 0 

b. Awards, Bonuses, & Incentives (PWTD) Yes X No 0 

Table B9-2 presents information on awards distributed to employees during the year as part 

of its employee recognition program The EEOC has suggested that agencies consider awards 

distribution based on inclusion rates, the degree to which each employee group is distributed 

across workforce indicators, e g , awarded or separated Please note this analysis requires 

aggregating data to the person level as presented in Table B9-2 Employees who received at 

least one award in any particular award category are counted once in this table 

Aggregated data enables inclusion to be calculated as the proportion for all PWD and PWTD 

who received each type or category of award In contrast, Table B9-1 presents participation 

rates among awards distributed One employee can and often does receive more than one 

award in a year In Table B9-1, one employee is represented more than once if he or she 

received more than one award in that category Differences in calculation should be noted 

when interpreting data from Tables B9-1 and B9-2 

The inclusion rate for PWD was calculated by comparing the number and percent of 

employees with disabilities who received at least one award in each applicable program 

element to the number and percent of employees without a disability (this category combines 

persons with no disability and those who did not identify as having a disability) who received 

at least one award in each applicable program element 

The inclusion rate for PWTD was calculated by comparing the number and percent of 

employees with targeted disabilities who received at least one award in each applicable 

program element to the number and percent of employees without a targeted disability (this 

category combines persons with no disability, those who did not identify as having a disability, 

and those with a disability that is not targeted) who received at least one award in each 

applicable program element 

The Agency did not fnd a trigger in the distribution of time-off awards less than 10 hours 

There was a negligible difference among PWD for time-off awards of 11-40 hours The 

inclusion rate for PWD at 25 54% was less than half a percentage point lower than the 

inclusion rate for persons with no disability at 25 99% The inclusion rate for PWTD 

(26 19%) was greater than that of persons with no targeted disability (25 94%) 

Continued on the next page 

FISCAL YEAR 2019 | 21
For cash awards, the Agency found triggers for PWD for cash awards of $1,000-$1,999 and 

$3,000 or more 

For cash awards of $1,000-$1,999, the inclusion rate for PWD was 19 89%, and the 

inclusion rate for people with no disability was 30 23% For cash awards of $3,000 or more, 

the inclusion rate for PWD was 0 81%, and the inclusion rate for people with no disability 

was 2 18% 

For cash awards, the Agency found triggers for PWTD in the award categories of $1,000 to 

$1,999 and for the category of awards greater than $3,000 

For cash awards of $1,000-$1,999, the inclusion rate for PWTD was 13 10%, and the 

inclusion rate for people with no targeted disability was 29 65% For cash awards of $3,000 

or more, the inclusion rate for PWTD was 0 00%, and the inclusion rate for people with no 

targeted disability was 2 10% 

The Agency is actively researching the observed differences in the distribution of discretionary 

awards as part of our barrier analysis program, described earlier in this plan, supra 

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

To address the question posed here, the following summarizes data from performancebased pay increases distributed under the Agency’s Performance Management Program 

and the nature of action (NOA) code 891, Regular Performance Pay, in accordance with 

EEOC instruction for presenting these data No trigger was found in performance-based 

pay increases 

The inclusion rate was calculated by comparing the number and percent of employees who 

received a performance-based pay increase (NOA 891) among PWD to the number and 

percent of employees with no disability (this group includes those who did not identify as 

having a disability) The inclusion rate for PWD was 100 27%, and for people without 

disabilities and those who did not self-identify with a disability, it was 100 10% This was 

because some employees separated 

Continued on the next page 

22 | EEO AFFIRMATIVE ACTION PLAN 
The inclusion rate for PWTD was calculated by comparing the number and percent of 

PWTD who received a performance-based pay increase (NOA 891) to the number and 

percent of employees without a targeted disability (i e , the combined total of persons with 

no disability, those who do not identify as having a disability, and those with a disability 

that is not targeted) who received such a performance-based pay increase No difference 

was found in performance rating based pay increases The inclusion rate for PWTD was 

101 19%, and for people without targeted disabilities (including those with no disability, 

those who did not self-identify as having a disability, and those with a disability that is not 

targeted), it was 100 10% 

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 0 N/A X

b. Other Types of Recognition (PWTD) Yes 0 No 0 N/A X

In FY 2019, the Agency did not offer other formal recognition programs for which 

demographic data, including disability status, are captured in the human resource data 

systems The Agency recognizes the value of recognition to support PWD and PWTD in the 

workforce; trigger analysis is not conducted for programs such as the SEC Honorary Awards 

program or any of the several honors programs offered by Division Directors 

FISCAL YEAR 2019 | 23
Promotions 

1 Does your Agency have a trigger involving PWD among the qualifed internal applicants and/or 

selectees for promotions to the senior grade levels? (The appropriate benchmarks are the relevant 

applicant pool for qualifed internal applicants and the qualifed 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 

Qualifed Internal Applicants (PWD) Yes 0 No X

Internal Selections (PWD) Yes X No 0 

b. Grade GS-15 

Qualifed Internal Applicants (PWD) Yes 0 No X

Internal Selections (PWD) Yes X No 0 

c. Grade GS-14 

Qualifed Internal Applicants (PWD) Yes 0 No X

Internal Selections (PWD) Yes 0 No X

d. Grade GS-13 

Qualifed Internal Applicants (PWD) Yes X No 0 

Internal Selections (PWD) Yes X No 0 

The SEC crosswalks the Agency’s SK alternative pay plan’s senior grade levels to the General 

Schedule according to the following equivalencies: SES = SO and EX; GS-15 = SK-15 and 

SK-17; GS-14 = SK-14 and SK-16; GS-13 = SK-13 We note that the relevant applicant pools 

(RAP) for the SK grade equivalencies of the GS-14 and GS-15 levels combine data across 

SK-grade levels This combination was made to conform analyses to the format provided, 

though the actual RAPs for the individual SK-levels differ 

Table B7 presents the relevant FY 2019 data to assess whether triggers exist with regard 

to promotions to senior grade levels Of 1,972 qualifed internal applications for senior 

grade level positions, 307 (15 57%) were submitted by PWD The Agency was successful in 

supporting PWD in their interest in and application for senior grade level positions There 

were no triggers identifed among qualifed internal applicants to the SES, GS-15, and GS-14 

equivalent senior grades For the GS-13 equivalent grade level, a difference was observed 

Among internal selections, differences were observed for the SES and GS-15 equivalent levels, 

but not the GS-14 or GS-13 equivalent levels Of the 86 internal promotions to senior grade 

levels in Table B7, seven (8 14%) were PWD, which is lower than their availability in the QAP 

at 15 57% The following presents data for each grade level equivalent 

Continued on the next page 

24 | EEO AFFIRMATIVE ACTION PLAN 
At the SES equivalent level, the RAP, comprised of all employees at grade levels SK-14 and 

higher, was 6 69% PWD, and among qualifed internal applicants, a larger proportion 

(10 98%) were PWD None of the employees selected for SO positions were PWD 

At the GS-15 equivalent level, the RAP, comprised of employees at grades SK-14, SK-15, and 

SK-16, was 6 72%, while the participation of PWD among qualifed internal applicants was 

greater at 18 20% The Agency noted a difference involving internal selections for senior 

grade levels at GS-15 equivalent grade levels; 2 86% of selections were PWD compared to 

their participation among qualifed internal applicants at 18 20% 

At the GS-14 equivalent level, PWD exceeded the relevant benchmarks at the qualifed 

and selected stages The RAP, comprised of employees at grades SK-13, SK-14, and SK-15, 

was 8 02%, and the participation of PWD among qualifed internal applicants was 13 67% 

On the other hand, 14 29% of selections were PWD compared to 13 67% of qualifed 

internal applicants 

At the GS-13 equivalent level, the Agency noted a difference at the qualifed and selected 

stages The RAP, comprised of employees at the SK-12 level, was 16 84%, and the 

participation of PWD among qualifed internal applicants was 10 77% Among selections 

for internal promotions at the SK-13 level, 12 50% were PWD, and 10 77% of the qualifed 

internal applicants were PWD 

2 Does your agency have a trigger involving PWTD among the qualifed internal applicants and/or 

selectees for promotions to the senior grade levels? (The appropriate benchmarks are the relevant 

applicant pool for qualifed internal applicants and the qualifed 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 

Qualifed Internal Applicants (PWTD) Yes 0 No X

Internal Selections (PWTD) Yes X No 0 

b. Grade GS-15 

Qualifed Internal Applicants (PWTD) Yes 0 No X

Internal Selections (PWTD) Yes X No 0 

c. Grade GS-14 

Qualifed Internal Applicants (PWTD) Yes 0 No X

Internal Selections (PWTD) Yes X No 0 

d. Grade GS-13 

Qualifed Internal Applicants (PWTD) Yes X No 0 

Internal Selections (PWTD) Yes X No 0 

FISCAL YEAR 2019 | 25
Applying the same comparisons to PWTD as described above for PWD, the Agency presents 

information on trigger identifcation for PWTD in promotions to senior grade levels Of 1,972 

qualifed internal applications for senior grade level positions, 38 (1 93%) were submitted by 

PWTD Of the 86 promotions to senior grade levels in Table B7, none (0 00%) were PWTD 

Overall, the Agency was successful in supporting PWTD in their interest in and application 

for senior grade level positions at the highest levels and was less successful in selecting PWTD 

for those promotions 

Differences were observed in the qualifed applicant pools for the GS-13 equivalent senior 

grade level and among selectees at all of the equivalent senior grade levels No differences 

were observed in the qualifed applicant pools for the GS-14, GS-15, or SES equivalent grade 

levels The following presents data for each grade level 

At the SES equivalent, SO, grade level, the Agency notes that the RAP was 1 35% PWTD, 

and the participation among qualifed internal applicants of PWTD was 1 22% Zero 

selections for SO positions were PWTD among the qualifed internal applicants 

At the GS-15 equivalent level, the RAP was 1 36%, and among the qualifed internal 

applicants, 1 70% were PWTD For the internal selections to GS-15 equivalent positions; no 

selections were PWTD 

At the GS-14 equivalent level, the RAP was 1 58% while 2 30% of the qualifed internal 

applicants were PWTD None of the selections were PWTD 

At the GS-13 equivalent level, the Agency observed a difference involving PWTD among 

qualifed internal applicants The RAP was 6 32%, and the participation of PWTD among 

qualifed internal applicants was 2 05% None of the PWTD qualifed internal applicants 

were selected 

26 | EEO AFFIRMATIVE ACTION PLAN 
3 Using the qualifed 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 X No 0 

b. New Hires to GS-15 (PWD) Yes 0 No X

c. New Hires to GS-14 (PWD) Yes X No 0 

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

Applying the same grade equivalencies that were previously described, the Agency presents 

information on trigger identifcation for PWD new hires to senior grade levels based on 

reviewing Table B6 Among the 53 newly hired staff members in FY 2019 were 48 persons 

hired into senior grade level positions, three SOs, six into GS-15 equivalent positions, 21 into 

GS-14 equivalent position positions, and 18 into GS-13 equivalent positions Four of those 48 

(8 33%) newly hired permanent staff in senior grade levels identifed as PWD The following 

evaluates participation of PWD in each senior grade equivalent level 

The QAP from Table B7 summarizes data where the applicant self-identifed with a 

disability and qualifed for the position Data in this table describe vacancies for permanent 

positions with the SEC that were posted in USAJOBS with a closing date during the fscal 

year In contrast, Table B7 also presents data on new hires onboarded during the course of 

the fscal year; some of whom applied for a vacancy posted prior to the start of the fscal 

year Differences may be observed in the demographic statistics of those selected versus 

those onboarded as new hires Triggers comparing the composition of PWD and PWTD in 

applicant fow versus new hire data should be interpreted with these difference in mind 

At the SES equivalent level, the QAP was 1 37% PWD, and none of the three newly hired 

permanent SOs identifed as PWD 

At the GS-15 equivalent level, the QAP was 11 89% PWD, and 33 33% of the permanent 

new hires for those positions identifed as PWD [Redacted to protect privacy.] 

At the GS-14 equivalent levels, the QAP was 10 81% PWD while 4 76% newly hired 

permanent staff were PWD [Redacted to protect privacy.] 

At the GS-13 equivalent level, the QAP was 13 27% PWD, while 5 56% of the new hires to 

GS-13 equivalent positions identifed as PWD [Redacted to protect privacy.] 

FISCAL YEAR 2019 | 27
4 Using the qualifed 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 X No 0 

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

Applying the same grade equivalencies that were described above in the section on promotions, 

the Agency presents information on trigger identifcation for PWTD new hires to senior grade 

levels 4 17% of the newly hired permanent staff in senior grade levels were PWTD [Redacted to 

protect privacy.] 

For the senior grade level equivalent GS-14 level, the Agency found a trigger in the difference 

in participation of PWTD between qualifed applicants and among new hires Because no 

PWTD were found among the qualifed applicants for SES/SO positions, no trigger was 

identifed at that level 

More detail about each senior grade level follows in descending order by level 

At the GS-15 equivalent level, the QAP was 1 40%; 16 67% of new hires were PWTD 

[Redacted to protect privacy.] 

At the GS-14 equivalent level, the QAP was 2 01% PWTD; none of the newly hired GS-14 

equivalent staff were PWTD 

At the GS-13 equivalent level, the QAP was 1 76% PWTD, and 5 56% of new hires were 

PWTD [Redacted to protect privacy.] 

5 Does your agency have a trigger involving PWD among the qualifed internal applicants and/or 

selectees for promotions to supervisory positions? (The appropriate benchmarks are the relevant 

applicant pool for qualifed internal applicants and the qualifed applicant pool for selectees ) If 

“yes”, describe the trigger(s) in the text box 

a. Executives 

Qualifed Internal Applicants (PWD) Yes 0 No X

Internal Selections (PWD) Yes X No 0 

b. Managers 

Qualifed Internal Applicants (PWD) Yes 0 No X

Internal Selections (PWD) Yes X No 0 

c. Supervisors 

Qualifed Internal Applicants (PWD) Yes X No 0 

Internal Selections (PWD) Yes 0 No X

28 | EEO AFFIRMATIVE ACTION PLAN 
The SEC cross-walked the Agency’s alternative pay plan supervisory levels to the Executive, 

Manager, and Supervisor levels according to the following equivalencies: Executives = SO; 

Managers = SK-17 and the supervisory Administrative Law Judges in pay plan Administrative 

Law (AL); and Supervisors = employees or positions at SK-levels below SK-17 who hold 

supervisory status We note that, similar to the senior grade level equivalencies, the relevant 

applicant pools (RAP) for supervisory levels at the Agency combine data across multiple SK 

levels This combination was made to conform analyses to the format provided, though the 

actual RAPs for the specifc leadership levels differ 

FY 2019 data underlying Table B8 are relevant for assessing whether triggers exist with regard 

to promotions to supervisory or managerial positions Among the promotions in FY 2019 

were 77 persons promoted to a leadership position at the supervisor, manager, or executive 

level, eight SOs, 19 managers, and 50 supervisors 9 09% of those promoted identifed as 

PWD [Redacted to protect privacy.] The following evaluates participation of PWD in each 

leadership level 

For the executive and manager levels, the participation of PWD in the qualifed internal 

applicant pool exceeds that in the RAP Therefore, no triggers were found in the QAP data for 

executives and managers There was a slight difference at the supervisor level The QAP for 

PWD was 7 50%, which fell below the RAP of 8 90% 

Differences were found when comparing PWD selections into leadership positions to the 

qualifed internal applicant pools at the executive and manager levels, but not the supervisor 

level As found for senior grade levels, overall, the Agency was successful in supporting PWD 

in their interest in and application for leadership roles and was less successful in selecting 

PWD for those promotions 

For executives, the Agency had a trigger involving internal selections The RAP, comprised of 

permanent managers with supervisory status at the SK-17 level, was 6 43% PWD, and the 

qualifed internal applicants were 10 98% PWD Therefore, no trigger was found for qualifed 

internal applicants However, the Agency found lower participation of PWD among selections 

None of the internal selections for SO positions identifed as PWD, while 10 98% of the 

qualifed internal applicants were PWD 

For managers, the RAP, comprised of permanent supervisors at the SK-13 through SK-15 

levels, was 7 43%, and the qualifed internal applicant pool was 16 62% Among the 

SK-17 manager selections noted in internal competitive promotion data 5 25% were PDW 

[Redacted to protect privacy.] 

For supervisors, the RAP, comprised of both supervisory and non-supervisory employees at 

the SK-12 through SK-14 levels, was 8 90% PWD, and the qualifed internal applicants were 

17 50% PWD However, there was a difference found for internal selections 12 00% PWD 

were among the internal selections for frst level supervisor positions compared to 17 50% of 

the QAP [Redacted to protect privacy.] 

FISCAL YEAR 2019 | 29
6 Does your Agency have a trigger involving PWTD among the qualifed internal applicants and/or 

selectees for promotions to supervisory positions? (The appropriate benchmarks are the relevant 

applicant pool for qualifed internal applicants and the qualifed applicant pool for selectees ) If 

“yes”, describe the trigger(s) in the text box 

a. Executives 

Qualifed Internal Applicants (PWTD) Yes 0 No X

Internal Selections (PWTD) Yes X No 0 

b. Managers 

Qualifed Internal Applicants (PWTD) Yes 0 No X

Internal Selections (PWTD) Yes X No 0 

c. Supervisors 

Qualifed Internal Applicants (PWTD) Yes 0 No X

Internal Selections (PWTD) Yes X No 0 

Applying the same grade equivalencies that were described previously, the Agency presents 

information on trigger identifcation for PWTD internal promotions to supervisory positions 

from Table B8 None of the promotions were PWTD The following evaluates participation of 

PWTD in each leadership level [Redacted to protect privacy.] 

For all three leadership levels, there was no difference between the participation of PWTD in 

the qualifed internal applicant pool compared to the RAP However, differences were found 

when comparing PWTD selections into leadership positions to the qualifed internal applicant 

pools for all three leadership levels As found for senior grade levels, overall, the Agency was 

successful in supporting PWTD in their interest in and application for senior leadership roles 

and was less successful in selecting PWTD for those promotions 

For executives, the RAP was 1 29% PWTD and 1 22% of the qualifed internal applicants 

were PWTD The Agency did identify a difference in participation for PWTD involving 

internal selections; no PWTD were among the eight employees promoted to SO positions 

For managers, the RAP was 1 14% PWTD and 1 36% of the qualifed internal applicants 

were PWTD The Agency identifed a difference involving internal selections; no PWTD were 

selected out of 17 manager promotions, though 1 36% of the qualifed internal applicants 

were PWTD 

For supervisors, the RAP was 1 94%, and 1 74% of the qualifed internal applicants were 

PWTD None of those selected for supervisory positions were PWTD 

30 | EEO AFFIRMATIVE ACTION PLAN 
7 Using the qualifed 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 X No 0 

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

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

Applying the same grade equivalencies that were described previously, the Agency presents 

information on trigger identifcation for PWD new hires into leadership positions Table B8 

is relevant for assessing whether differences exist with regard to applicants and new hires in 

supervisory positions for PWD (this question) and PWTD (see the next question) A difference 

was found in FY 2019 new hire data for PWD at the executive and supervisor levels 

The SEC hired 53 new staff members in FY 2019 22 22% newly hired permanent staff in 

leadership positions were PWD in manager positions [Redacted to protect privacy.] The 

following evaluates participation of PWD in each leadership level Because no permanent 

staff PWD employees were hired into either SO or supervisor positions, participation of 

PWD was higher among the QAP than among newly hired leaders At the manager level, 

there was no trigger for the permanent new hires for either PWD or PWTD 

The QAP from Table B8 summarizes data where the applicant self-identifed with a disability 

and qualifed for the position Data in this pool describe vacancies for permanent and 

temporary positions with the SEC that were posted in USAJOBS with a closing date during 

the fscal year In contrast, Table B8 also presents data on new hires onboarded during the 

course of the fscal year; some of whom applied for a vacancy posted prior to the start of the 

fscal year Differences may be observed in the demographic statistics of those selected versus 

those on boarded as new hires Triggers comparing the composition of PWD and PWTD in 

applicant fow versus new hire data should be interpreted with these differences in mind 

For executives, the QAP was 1 37% PWD, and none of the newly-hired permanent 

executives identifed as PWD For managers, PWD participation of 66 67% among newly 

hired managers exceeds their participation in the QAP at 5 83% [Redacted to protect 

privacy.] For supervisors, no PWD were newly hired into supervisory positions, while 

13 80% of the QAP were PWD 

FISCAL YEAR 2019 | 31
8 Using the qualifed 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 X No 0 

A difference was found in FY 2019 new hire data for PWTD at the supervisor level, but not 

at the executive or manager levels 11 11% of newly hired permanent staff in leadership 

positions identifed as PWTD [Redacted to protect privacy.] 

For executives, no PWTD (0 00%) were found in the qualifed applicant pool, so there was 

no opportunity to observe a trigger No PWTD were onboarded or selected as new hires for 

executive positions in FY 2019 

For managers, the qualifed applicant pool was 0 97% PWTD, and 33 33% of the newlyhired permanent managers was PWTD For supervisors, the qualifed applicant pool was 

1 53% PWTD, and none of the newly-hired permanent supervisors identifed as PWTD 

[Redacted to protect privacy.] 

32 | EEO AFFIRMATIVE ACTION PLAN 
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 to 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 

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 FR § 213 3102(u)(6)(i))? If 

“no”, please explain why the agency did not convert all eligible Schedule A employees 

Yes X No 0 N/A 0 

The SEC maintains discretion on conversions to a career or career-conditional appointment 

among employees on Schedule A appointments As a general practice, those Schedule A 

employees who were not converted voluntarily accepted a new Schedule A appointment 

within the Agency One employee was converted to the competitive service under the Schedule 

A hiring authority during FY 2019 within two years of the Schedule A appointment A 

review of records for other Schedule A employees, who were hired or transferred to the SEC 

and remain on rolls at the close of FY 2019, confrms that all were converted to competitive 

service within two years of appointment 

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 X No 0 

b. Involuntary Separations (PWD) Yes 0 No X

Table B1 provides FY 2019 data on voluntary and involuntary separation by disability These 

data were used to calculate the inclusion rates More information about inclusion rates is 

provided above in the analysis of awards Inclusion rates were calculated as the number of 

PWD who separated among all PWD in the workforce, compared to the same proportion 

among persons with no disability (this category is combined with those who did not selfidentify as having a disability) FY 2019 data show that PWD separated at higher rates than 

those with no disability 

Continued on the next page 

FISCAL YEAR 2019 | 33
For voluntary separations, the percentage of PWD exceeded that of persons without 

disabilities The inclusion rate for PWD was 5 11%, and for people without disabilities, 

including those who did not self-identify, the inclusion rate was 3 34% 

For involuntary separations, the percentage of PWD did not exceed that of persons without 

disabilities There were no separations for PWD (inclusion rate of 0 00%, and for people 

without disabilities, including those who did not self-identify, the inclusion rate was 0 03%) 

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 X No 0 

b. Involuntary Separations (PWTD) Yes 0 No X

Using data from Table B1 to calculate the inclusion rates for PWTD, the following was found 

in FY 2019 data Inclusion rates were calculated as the number of PWTD who separated 

among all PWTD in the workforce, compared to that same proportion among persons with 

no disability (this group also includes those who did not self-identify as having a disability and 

those with a disability that is not targeted) 

For voluntary separations, the percentage of PWTD exceeded that of persons without 

disabilities The inclusion rate for PWTD was 5 95%, and for people without disabilities, 

including those who did not self-identify, the inclusion rate was 3 44% For involuntary 

separations, the percentage of persons without targeted disabilities exceeded that of PWTD 

There were no separations among PWTD, and for people without targeted disabilities, the 

inclusion rate was 0 02% 

34 | EEO AFFIRMATIVE ACTION PLAN 
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 

To understand the reasons why PWD were separating from the Agency, voluntary separation 

data were more closely reviewed, combined with other demographic information about 

employees with disabilities Analysis considered any trends in employee separation by Division 

or Offce, by occupation, by grade, and by age The most infuential trend observed in these 

data was a relationship between age and disability The largest portion of voluntary separations 

for PWD and PWTD were retirements from federal service The Bureau of Labor Statistics 

has similarly documented the age profle of the U S population of PWD (Source: bls gov/ 

spotlight/2018/labor-force-characteristics-of-people-with-a-disability/home htm ) 

The very small number of PWD separated under involuntary conditions limits the reliability 

of general conclusions from these data [Redacted to protect privacy.] At the same time, 

exploring the involuntary separation of this small volume of the PWD employee population 

may be informative With that caveat, OEEO gathered data in FY 2019 about the reasons 

for involuntarily removing PWD to uncover any preventive action or support needed for 

current and future employees Specifcally, based on technical assistance suggested by EEOC’s 

Offce of Federal Operations (OFO), OEEO gathered qualitative data about PWD who were 

involuntarily separated from the Agency during FY 2017 and FY 2018 Data sources included 

records gathered as part of relevant EEO complaint activity fled by separated PWD prior 

to departure and interviews with the supervisors of these former PWD employees The data 

included a small number of employees [Redacted to protect privacy.] No patterns in results 

were evident that would form the basis for additional action 

The SEC invites all departing employees to complete an exit survey during their last pay 

period on SEC rolls This survey asks exiting employees to self-identify if they have a disability 

and whether or not an accommodation was needed or provided Among 51 employees who 

completed the exit survey in FY 2019, two self-identifed as having a disability (3 92%)—and 

both employees reported that they were provided reasonable accommodation 

The small number of separating employees who self-identifed with a disability and completed 

the exit survey limits the reliability of conclusions to be drawn from these data about the 

reasons why those employees left the Agency To this end, in FY 2019 the Agency analyzed 

information from the exit survey across two fscal years (FY 2018 and FY 2019) to support 

more general conclusions about why employees with disabilities left the SEC 

Continued on the next page 

FISCAL YEAR 2019 | 35
In FY 2019, 56% of employees who separated and reported a disability indicated they 

left the SEC due to retirement Of note, all departing employees who self-identifed as 

having a disability were overwhelmingly more positive when responding to items on the 

exit survey related to diversity and inclusion when compared to employees who did not 

report a disability: 100% agreed that their workgroup was open to diverse viewpoints and 

backgrounds (compared to 73% of employees who did not report a disability); 89% agreed 

that their supervisor/team lead treated them with respect (versus 81%); 100% agreed their 

co-workers fostered an cohesive work environment (versus 77%); and 100% agreed policies 

and programs promoted diversity in the workplace (versus 60%) The results of the exit 

survey suggest employees who separated and indicated a disability were much more satisfed 

with SEC diversity and inclusion efforts than other separated employees 

The analyses described here were completed as part of the in-process barrier analysis for PWD 

and PWTD described more fully in Section VII, infra 

Accessibility of Technology and Facilities 

Pursuant to 29 C FR § 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 fle 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 fle a complaint 

Information specifc to the accessibility of SEC facilities and technology under Sections 504 

and 508 of the Rehabilitation Act is not currently consolidated into one specifc notice or 

resource Such information can be gathered from a variety of sources, including 17 C FR 

§§ 200 601 to 200 670, Enforcement of Nondiscrimination on the Basis of Handicap 

in Programs or Activities Conducted by the Securities and Exchange Commission (SEC 

504 regulations), SEC Administrative Regulation 24-10 (SECR 24-10), Information 

and Communication Technology (ICT) Section 508/Accessibility Program, and SEC 

Administrative Regulation 11-3 (SECR 11-3), Leasing Program 

Continued on the next page 

36 | EEO AFFIRMATIVE ACTION PLAN 
Information about the SEC’s Accessibility/Disability Program is posted on SEC gov: 

sec gov/disability/sec_access htm and sec gov/accessibility/sec-accommodation-procedures 

pdf SEC recently updated the Accessibility page of SEC gov with applicable complaint-fling 

procedures under both Sections 504 and 508 of the Rehabilitation Act and the Architectural 

Barriers Act Updates included an explanation of the Rehabilitation Act and Architectural 

Barriers Act, informal processes for providing feedback about accessibility of facilities and 

technology to SEC, contact information and specifc complaint processes for fling a formal 

claim related to accessibility, and additional resources for individuals to learn more An SEC 

Administrative Regulation (SECR) and SEC Operating Procedures (SECOP) setting forth the 

complaint process related to Sections 504 and/or 508 and the Architectural Barriers Act is 

drafted, expected to be fnalized in FY 2020, and will be posted on SEC gov thereafter 

Every SEC vacancy announcement posted to USAJOBS includes information about obtaining 

accommodations, including alternative methods to apply The name of SEC’s Special 

Programs Manager serving as the Selective Placement Program Coordinator (SPPC) is posted 

on OPM’s website OHR has built a separate page providing more in-depth information 

about hiring PWD (sec gov/ohr/sec-disability-program-page html) This page includes a 

link to an online form (sec gov/forms/ADA4Applicants) for requesting accommodations 

in the technology-enabled job application process and information on alternate methods for 

contacting the Disability Program at the SEC 

The SEC also currently posts information on how to fle an EEO complaint under, inter alia, 

Section 501 of the Rehabilitation Act at sec gov/eeoinfo/eeocomplaints htm 

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 fle a complaint 

Information is posted on SEC gov (http://www sec gov/disability/sec_access htm ) This 

page contains the required notice explaining employees’ and applicants’ rights under the 

Architectural Barriers Act, including how to fle a complaint 

FISCAL YEAR 2019 | 37
3 Describe any programs, policies, or practices that the Agency has undertaken, or plans on 

undertaking over the next fscal year, designed to improve accessibility of agency facilities and/ 

or technology 

SEC continues to improve upon current practices in place to ensure all Information 

and Communication Technology (ICT) is accessible to internal and external parties, as 

mandated by the Rehabilitation Act of 1973 The Agency’s testing and validation process 

includes dedicated resources, testing tools, documented test processes, and a remediation 

process The majority of ICT products and tools are tested before they are deployed Upon 

completion of testing, project teams are notifed of the defects and are instructed to submit, 

for approval, a Remediation Plan, indicating a defnitive timeline in which the vendor will 

make the respective product 508 compliant 

The Offce of Public Affairs has been instrumental in educating SEC staff on the guidelines 

and importance of Section 508 of the Rehabilitation Act Training courses have been 

offered, as well as “how to” videos that inform staff of the process with making electronic 

information technologies accessible to all parties Further, all Agency Contracting Offcer 

Representatives (CORs) are required to complete Section 508 training in both FY 2019 

and in FY 2020 

The Offce of Information Technology will be active in supporting the SEC Administrative 

Regulation that defnes roles and responsibilities of SEC staff to address formal Section 

508 Complaint Procedures related to accessibility of IT programs and services 

Reasonable Accommodation Program 

Pursuant to 29 C FR § 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 ) 

The SEC has established a reasonable accommodation (RA) processing timeline of 20 business 

days from the day of request to fulfllment, absent extenuating circumstances Excluding 

the provision of adjustable height tables (AHTs), in FY 2019, 57% of initial requests for 

accommodation were processed within 20 business days 

Continued on the next page 

38 | EEO AFFIRMATIVE ACTION PLAN 
The overall time frame for processing RA requests in FY 2019 was affected by a number of 

organizational and business process changes that resulted in a 15% decrease from the FY 

2018 timeliness result of 72% Specifcally, in FY 2019, changes to the procurement process 

for the purchase and installation of equipment and assistive technology impacted SECs ability 

to provide accommodations timely In addition, the SEC initiated more consultations with 

medical experts at the Federal Occupational and Health (FOH) to complete medical reviews 

of employees with a wide range of conditions in an effort to improve their ability to do their 

jobs and maintain a high level of productivity In FY 2019, medical reviews completed by FOH 

were processed in 37 8 days on average Implementation of the new RA policy and operational 

procedures have also impacted efforts to implement a case management system in FY 2020 

In FY 2021 an assessment will be conducted to determine whether the FY 2020 acquisition 

review of a new Human Resources Service Delivery (HRSD) module will be a viable option for 

automating the RA workfow and case tracking for RA The implementation of an automated 

RA system is expected to address timeliness standards set by the new SEC RA policy Changes 

to the RA policy and operational procedures will likely necessitate updates to training, job 

aids, notices, and other information sources in FY 2020 and beyond The Agency is currently 

engaged in a review for system design of an automated electronic case management system for 

processing RA requests 

In the meantime, a more structured set of processes and procedures were developed and used 

in FY 2019 for capturing data related to processing RA requests The time frame for processing 

initial requests for RA during FY 2019 was 22 9 days; RA requests, excluding AHT were 

processed in 28 9 days; and requests for AHTs were processed in 11 7 days, respectively 

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 

The interactive portal, AskHR, on the Agency’s intranet provides employees with information 

about reasonable accommodation and the processes for making requests To support 

employees in making such a request, the Agency will replace the resource guide, “Disability 

Accommodation Procedures,” with a new RA policy and operational procedures in FY 

2020 This new guidance will be available on the interactive portal for everyone involved 

in the accommodations process It explains how persons with disabilities should request 

accommodations, how requests are processed, and, as applicable, how requestors may seek 

review of decisions where a request has been denied 

Continued on the next page 

FISCAL YEAR 2019 | 39
The SEC provides temporary accommodations to employees with short-term medical 

conditions even when the condition does not constitute a covered disability when supervisory 

offcials and the Disability Program Offce decide that it is appropriate to do so In FY 2019, 

the SEC processed 119 Temporary Medical Telework (TMT) requests, processed 133 RA 

requests, of which 34 were requests for telework as a reasonable accommodation 

All new SEC managers participate in mandatory training regarding the reasonable 

accommodation process as part of the LD 307 Fundamentals of Human Resource 

Management training Additionally, the SEC’s New Employee Orientation includes a 

presentation on the following programs and processes: RA, TMT, Telework, and Leave 

(i e , annual/sick, advance leave, and FMLA, etc ) This information is included in the New 

Employee Handbook and made available on the AskHR portal 

The SEC revisited and revised the business requirements to implement an electronic case 

management system that would allow employees to request reasonable accommodations 

personally and privately will continue in FY 2020 and beyond While the project was 

delayed in FY 2019, OHR did create RA and TMT Request and Agreement forms to 

simplify the process for employees making requests; to ensure current, accurate, and 

complete information is obtained to reduce processing times; and to improve the reliability of 

records indicating customer approval of the reasonable accommodation(s) provided 

Additionally, OHR continues to fnd ways to strengthen the current manual tracking process, 

including tracking timeliness for processing RA requests, and meeting on a monthly basis 

with the CHCO to review and discuss timeliness and processing of all RA cases The Agency 

will continue its efforts to implement the business requirements for the electronic case 

management system 

Requests and information relative to Personal Assistance Services (PAS) remain available on 

AskHR interactive portal The SEC intends to publish the new RA policy and operational 

procedures approved by the EEOC in FY 2020 During FY 2019, the Agency continued the 

review of the electronic case management system’s business requirements, the new policy, and 

related procedural changes that support RA for employees and applicants for employment 

Furthermore, changes to RA procedures will likely necessitate updates to training, job aids, 

notices, and other information sources in FY 2020 and beyond 

40 | EEO AFFIRMATIVE ACTION PLAN 
Personal Assistance Services Allowing Employees to Participate 

in the Workplace 

Pursuant to 29 C FR § 1614 203(d)(5), federal agencies, as an aspect of affrmative 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 

1 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 

In FY 2018, the Disability Program Offce updated the Agency’s Disability Accommodation 

Procedures to include information related to the PAS that was made available on the AskHR 

interactive portal In FY 2019, a new policy and operational procedures was established 

and approved by the EEOC for implementation The SEC intends to publish the revised RA 

policy and operational procedures in FY 2020 that include information regarding PAS and 

submission requirements that will be made available on AskHR In addition, the Agency 

modifed its current contact for Personal Assistant and Reader Services to enhance the level of 

support and ensure consistent delivery of health care services In FY 2019, employee usage of 

PAS services increased 25% [Redacted to protect privacy.] The SEC continues to use the PAS 

form to capture requests Data from this form will provide information that may be used to 

understand program adoption and effectiveness going forward 

FISCAL YEAR 2019 | 41
SECTION VI: EEO COMPLAINT AND FINDINGS DATA 

EEO Complaint Data Involving Harassment 

1 During the last fscal year, did a higher percentage of PWD fle a formal EEO complaint alleging 

harassment, as compared to the government-wide average? 

Yes 0 No X N/A 0 

2 During the last fscal year, did any complaints alleging harassment based on disability status result 

in a fnding of discrimination or a settlement agreement? 

Yes 0 No X N/A 0 

3 If the Agency had one or more fndings of discrimination alleging harassment based on disability 

status during the last fscal year, please describe the corrective measures taken by the Agency 

During FY 2019, the Agency did not have any fndings of discrimination alleging harassment 

based on disability status 

EEO Complaint Data Involving Reasonable Accommodation 

1 During the last fscal year, did a higher percentage of PWD fle 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 fscal year, did any complaints alleging failure to provide reasonable 

accommodation result in a fnding of discrimination or a settlement agreement? 

Yes X No 0 N/A 0 

3 If the Agency had one or more fndings of discrimination involving the failure to provide a 

reasonable accommodation during the last fscal year, please describe the corrective measures taken 

by the Agency 

During FY 2019, the Agency did not have any fndings of discrimination involving the failure 

to provide reasonable accommodation 

42 | EEO AFFIRMATIVE ACTION PLAN 
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 identifed 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 identifed barrier(s), 

objective(s), responsible offcial(s), planned activities, and, where applicable, accomplishments 

Analyses of Persons with Disability and Targeted Disability in the Workforce

STATEMENT OF CONDITION THAT WAS A TRIGGER FOR A POTENTIAL BARRIER: 

Provide a brief narrative describing the condition at issue.

How was the condition recognized as a potential barrier?

There was a lower-than-expected participation rate of Persons with Targeted Disabilities (PWTD) in the total workforce and in promotions

to higher level positions when this study was initiated based on data from FY 2014. The participation rate of PWTD in the SEC’s workforce

was less than 1% in FY 2014 based on the then-current Standard Form 256 (SF-256) Self Identification of Disability. Participation of 

PWTD in the permanent workforce has increased based on the revised categories reflected in the new October 2016 version of the

SF-256 to 2.02% in FY 2018.

In FY 2018 data, the participation rate of Persons with Disabilities (PWD) in the total permanent workforce and among higher salaried

employees as documented in responses to earlier sections of Part J is below the goal of 12% established by Section 501 of the

Rehabilitation Act. The participation rate of higher salaried employees is 8.64%.

Participation of PWD, and sometimes PWTD, among new hires and internal competitive promotions to mission critical, senior grade level,

and leadership positions and among those who were selected for career development is below their availability in the relevant or qualified

applicant pools. Further, the participation rate of PWD and PWTD among employees receiving higher value awards and for PWD among

those separating from the Agency in both FY 2017 and FY 2018 exceeded that expected based on their participation in the total workforce

and in comparison to persons with no disability.

Source of the Trigger Specific Workforce Data Table 

Workforce Data Table (if so identify the table) Tables B1 through B9

EEO Complaint(s)

Grievance(s)

Climate Assessment Survey

Exit Interview(s)

FISCAL YEAR 2019 | 43
Source of the Trigger Specific Workforce Data Table 

Anecdotal 

Other

EEO Group(s) Affected by Trigger 

EEO Group 

Persons with Disability X 

Persons with Targeted Disability X 

Barrier Analysis Process 

Source of the Trigger

Source 

Reviewed? 

(Yes or No)

Identify Information Collected

Workforce Data Tables Yes Workforce data tables and participation rates for PWD and

PWTD from FY 2011 – FY 2018

Demographic information related to retention for separated and

on rolls PWD 

Complaint Data (Trends) Yes EEO complaint activity filed between FY 2012 – FY 2017 to

identify any trends in complaints filed by PWD or PWTD

Climate Assessment Survey (e.g., FEVS) Yes Federal Employee Viewpoint Survey (FEVS) data to compare

responses from persons with disabilities to those with no

disability

Responses from PWD and PWTD to a Workplace Experience 

Survey conducted at the SEC during FY 2018

Exit Interview Data Yes Responses provided by PWD to the Agency’s exit survey data

from FY 2016 through FY 2018

Focus Groups No

Interviews Yes Interviews with subject matter experts in OHR and OMWI and

subject matter experts in disabled student service offices at

Gallaudet University and Rochester Institute of Technology

Interviews with the managers of PWD involuntarily separated

during FY 2018 to uncover any preventable reasons for

separation 

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

OPM)

Yes Reports and regulations related to the employment of PWD and

PWTD in the federal workforce offered by OPM, EEOC, DOL/

ODEP, EARN, and other agencies and supporting organizations

44 | EEO AFFIRMATIVE ACTION PLAN 
Source of the Trigger

Source 

Reviewed? 

(Yes or No)

Identify Information Collected

Other (Please Describe) Yes Laws and federally mandated hiring and promotions policies,

practices, and procedures applicable to recruitment and retention

of persons with disabilities

The Agency’s hiring and promotions policies, practices, and

procedures applicable to people with disabilities, including those

with targeted disabilities

Selection case files (hiring and promotions) from FY 2014 and

FY 2015

Research literature, collective bargaining agreement language,

and reports to better understand career development, promotion,

retention, or recruiting and hiring processes related to PWD and

PWTD 

Information about best practices in recruiting PWD in the federal

government and private industry

Status of Barrier Analysis Process 

Barrier Analysis Process Completed?

(Yes or No)

Barrier(s) Identified?

(Yes or No)

No No

Statement of Identified Barrier(s) 

Barrier Name* (required) Description of Policy, Procedure, or Practice

No barrier has yet been identified pending further analysis. While the Agency has not identified specific policies, practices,

or procedures that represent a “barrier that affects employment

opportunity for PWD or PWTD,” representatives of OEEO and OHR

agreed to take action toward enhancing equal employment opportunity

for persons with targeted disabilities in the following areas:

• Develop and implement policies and procedures specific to the

recruitment, hiring, advancement, and retention of persons with

disabilities (PWD) or persons with targeted disabilities (PWTD)

that are aligned with the federal government-wide flexibilities and

requirements for affirmative action;

• Enhance consistency and structure in the posting, screening, and

interview processes for selection; and

• Create awareness on the part of hiring managers and subject

matter experts (or others involved in the Agency’s recruitment and

selection processes) about the requirements for, and flexibilities

available under, government-wide programs supporting PWD and

the affirmative action plan for PWTD; and employment programs,

especially reasonable accommodation and disability programs,

supportive of PWD and PWTD.

FISCAL YEAR 2019 | 45
Objective(s) and Dates for EEO Plan 

Date 

Initiated 

(mm/dd/yyyy)

Target 

Date 

(mm/dd/yyyy)

Sufficient 

Staffing & 

Funding 

(Yes or No)

Modified 

Date From 

(mm/dd/yyyy)

Date 

Completed 

(mm/dd/yyyy)

Objective

10/01/2015 10/31/2020 Yes 09/30/2020 The objective of these efforts will

be to continue to implement action

plans developed to address the

experience of PWTD and expand 

those plans to cover PWD in line

with the revised EEOC regulations.

Additional action will focus on:

• Analysis of quantitative and

qualitative data, including

employee perceptions 

among the population of

PWD and PWTD;

• Implementing the

recommended and required

actions under Section 501

of the Rehabilitation Act of

1973;

• Implementing, as feasible,

revisions to the workforce

data tables presenting

information on PWD and 

PWTD, as per instruction

from EEOC; and

• Reviewing and updating

agreed-upon action plans

to address the broader

population of PWD and/or to

cover Section 501 regulatory

changes.

Responsible Official(s) 

Title Name 

Performance Standards 

Address the Plan? 

(Yes or No)

Chief Human Capital Officer, OHR Jamey McNamara Yes

Director, OEEO Peter J. Henry Yes

46 | EEO AFFIRMATIVE ACTION PLAN 
Planned Activities toward Completion of Objective 

Target 

Date 

(mm/dd/yyyy)

Planned 

Activities

Sufficient 

Staffing & 

Funding 

(Yes or No)

Modified 

Date From 

(mm/dd/yyyy)

Completion 

Date 

(mm/dd/yyyy)

11/30/2017 OEEO will conduct a Workplace Experience Survey 

of the Agency workforce to explore employee

perceptions among the population of PWD and

PWTD as well as those without disabilities on,

among other topics, the recruitment, hiring,

promotion, recognition, and retention of talent. 

Yes 11/6/2017

01/31/2018 The Agency will establish a cross-functional working

group with representatives from OEEO and OHR

to develop action plans and implement required

and recommended activity under Section 501 of the

Rehabilitation Act of 1973.

Yes 11/02/2017

03/31/2019 OEEO will gather data to determine the reasons

for removal of PWD by reviewing data on file

from any specific EEO activity and interviewing

the supervisors of PWD who were involuntarily

separated in FY 2017 and FY 2018.

Yes 3/31/2019

10/31/2020 OEEO will implement feasible changes to the

workforce data tables providing information on PWD

and PWTD in collaboration with a shared service

provider. 

Yes 09/30/2019

Report of Accomplishments 

Fiscal Year Accomplishments

2016 OHR engaged in the following recruitment/outreach initiatives:

• Partnered with the Department of the Army’s Wounded Warriors Program and Department of Labor

to successfully implement a Disability Hiring Event, which resulted in the direct hire of two persons

with disabilities;

• Participated in two Career Fairs: EOP Career Fair and Veterans’ Resource Expo;

• Partnered with George Mason University and implemented the MASON Life Program at the SEC and

sponsored internships for students with intellectual and physical disabilities;

• Partnered with DIAC to solicit participation in career fairs and leverage their professional networks/

partnerships with other organizations;

• Explored recruiting strategies among various federal and state rehabilitation centers and affinity

groups; and

• Attended and sponsored the New Perspectives training conference.

OHR completed the following:

• Training managers and supervisors to ensure they are aware of how the Schedule A hiring authority is used

by the SEC to hire persons with severe disabilities and the role of managers/supervisors in the recruitment

and hiring process;

• Surveying disability organizations at universities near the SEC Home Office and Regional Offices to obtain

information to improve recruitment of applicants with disabilities;

• Using the Hiring Checklist in strategic conversations with hiring managers to ensure they are aware of

flexibilities available to hire persons with disabilities;

• Implementing and monitoring compliance with the Agency’s selection policy memorandum outlining the

requirements for screening and interviewing job candidates (published on September 26, 2016); and

• Developing and refining targeted recruitment strategy and performance metrics to measure effectiveness of

the Agency’s outreach efforts to applicants with disabilities.

FISCAL YEAR 2019 | 47
Fiscal Year Accomplishments

2017 In January 2017, the EEOC issued revised regulations under the federal government’s obligation to engage

in affirmative action for people with disabilities that modified Section 501 of the Rehabilitation Act of 1973. This

revision addresses the hiring, retention, and career opportunity for persons with disabilities and those with targeted

disabilities. OEEO had previously initiated barrier analysis focused on persons with targeted disabilities. As the

Agency prepares for implementation of the revised regulation in FY 2018, OEEO will leverage or expand this prior

work to include the population of persons with disabilities in the workforce.

Representatives from OEEO and OHR implemented a number of actions responsive to the recommendations from

the original study of the SEC’s PWTD workforce, including:

• Reviewing best practices and recommendations from OPM and the EEOC regarding the employment of

PWD and PWTD;

• Publishing revised policy on Requirements for Screening and Interviewing Job Candidates that requires

documentation for each hiring action;

• Developing an enhanced communication plan, including open information sessions, on the requirements

under the revised policy for screening and interviewing job candidates (these sessions improve transparency

and further educate SEC employees on available career opportunities and resources);

• Conducting training open to all employees and mandatory training for anyone involved in the hiring or

promotions process;

• Increasing the quality of interaction between HR specialists and hiring managers toward more strategic

conversation and the consideration of hiring options that take disability into account;

• Reviewing OHR’s FY 2017 Strategic Recruitment Plan;

• Resurveying the workforce in July and August of 2017 to encourage review of employee data and selfidentification of disability;

• Continuing to evaluate workforce and applicant flow data to determine progress towards removing the

potential barriers for PWTD, including reviewing the impact of revised disability and targeted disability

categories in the revised SF-256 as they influence participation of PWD and PWTD;

• Verifying the hiring and assignment of a Special Programs Manager within OHR focused on supporting the

recruitment, hiring, development, and retention of PWD and PWTD; and

• Developing an enhanced communications plan, in concert with DIAC, which included hosting guest

speakers, events and open information sessions supporting the population of PWD and PWTD.

In Quarter (Q2) and Q4 of FY 2017, representatives from OEEO and OHR worked together on transitioning to the

new October 2016 version of SF-256 Self-Identification of Disability. OHR recoded employees on rolls against the

categories of disability on the new form in Q2 of FY 2017. OHR and OEEO jointly sponsored a resurvey of the

workforce in July and August 2017 (Q4). As part of this resurvey effort, OHR provided each employee individualized

information showing their current demographic and disability coding. The resurvey encouraged employees to

verify and update their disability information. Employees could update their personal information through either

employee self-service or with individualized support from OHR for personnel processing. The resurvey of the

workforce included a broad-based outreach and communications campaign to all employees, to include messaging

describing the value of self-identification, as suggested by OPM’s Office of Diversity and Inclusion. Pre- and postanalysis of the resurvey effort showed that 76 employees had their disability information change in some way with a

net increase of 20 persons with disabilities (7%) and three persons with targeted disabilities (3%).

Further, to support the accurate reporting of information about PWD and PWTD from FPPS, OEEO contracted

with a service provider to develop an automated tool that extracts, accurately codes, summarizes, and provides

reporting on demographic information about employees and applicants for employment. This tool, the Equal

Employment Opportunity–Analytic Tool (EEO-AT), was used to generate the data for workforce data tables in this

report as well as the responses to data-related questions. The EEO-AT provides for more efficient and accurate

summary data, more effective interface with FedSEP, and greater facility for OEEO to respond to anticipated and

future changes to reporting demographic information.

48 | EEO AFFIRMATIVE ACTION PLAN 
Fiscal Year Accomplishments

2018 The following provides detail about OEEO’s analytic work in support of this analysis during FY 2018.

1. OEEO conducted a Workplace Experience Survey of the Agency workforce to explore employee perceptions

of, among other topics, promotional opportunity, recruitment, and hiring for leadership positions. OEEO

analyzed 1,360 responses and narrative comments from 469 employees. Among the respondents were

90 responses from employees who self-identified as having a disability other than those targeted and 34

responses from PWTD. Analyses compare responses on a variety of index and item level results. PWD and

PWTD reported more favorable perceptions in the areas of: interview processes, availability of information

about the EEO process and related policies, supervisory relations, work team inclusion, and training for

success within occupation.

2. In line with implementation of Section 501 requirements, OEEO facilitated the Agency’s decision to include

persons hired under authorities that take disability into account as PWD. This action allowed the Agency to

target support, development, and retention efforts toward two persons hired under Schedule A, part u and 38

veterans, who received hiring preference based on a service connected disability, as PWD.

3. OEEO used a series of self-service workforce data summary tools to review the demographic composition

and disability status data within specific occupations of the entire workforce, newly hired staff, AFD, and

separations by critical organizational characteristics.

4. OEEO analyzed the increase in self-identification from five-year trend data. Analysis uncovered the positive

impact of annual employee demographic resurveys and more inclusive definitions of PWD and PWTD

between FY 2013 and FY 2018. Specifically, we observed a 0.93% point increase in self-identified PWD

after the first annual employee resurvey in FY 2015, an additional 0.90% point increase after the changes to

SF-256, and a 0.66% point increase as a result of the resurvey in FY 2018.

5. OEEO analyzed the number and percent of complaint records filed by PWD between FY 2013 and FY 2017.

Results were concerning in the relative volume of complaint activity filed by PWD. The inclusion rate of PWD

among formal or informal EEO complaint related activity was three times that of persons with no disability.

Further, complaint activity for PWD was more likely to lead to the formal stage.

6. With respect to retention, OEEO investigated turnover data for PWD and PWTD among those who separated

the Agency in FY 2016 through FY 2018. These data revealed that PWD separations were more frequently due

to retirement as compared to separations among persons with no disability; almost half of the PWD separations

(48.00%) were coded for retirement, compared to about one third (34.75%) of separations among persons

with no disability. Further review of these data established a correlation between age, disability, and retirement.

PWD represent more than twice the proportion of the separations for employees over the age of 60 (17.24%)

as compared to their participation among separations for persons under 40 (6.44%). On average, PWD in the

Agency workforce are older (PWD average age = 49.32; No Disability average age = 46.88, t = -4.68, p<.001),

and, therefore, more likely to be eligible for retirement.

As further explored below, OEEO and OHR established a strong cross functional approach to supporting PWD and

PWTD in the Agency’s workforce, while leveraging OMWI’s EAG network. In recognition of this partnership, leaders

in OHR and OEEO were invited to share their thoughts in a cross Agency panel discussion at the July meeting of

the Federal Exchange on Employment with Disabilities (FEED).

OHR and OEEO jointly sponsored a resurvey of the workforce in July and August 2018 following successful

resurvey efforts in prior years. OHR provided each employee individualized information showing their current

demographic and disability coding. Pre- and post-analysis of the resurvey effort showed that 57 employees had

their disability information change in some way with a net increase of 22 PWD (6.8%) and six PWTD (7.4%).

To understand better how the Agency can support PWD and PWTD, OHR updated the exit survey. As of

September 2018, the Agency’s survey of departing staff, who self-identify as PWD asks: “What accommodations,

personal assistance, or other support could improve the inclusion and advancement of individuals with disabilities

at the SEC?” OHR plans to use and share the information with other stakeholders, including OEEO and DIAC in

support of current and future employees with disabilities.

OHR continued to make significant enhancements to the SEC’s training and development programs, which provide

support for the career growth of PWD. As described above in Section IV, the SEC added to the offerings within its

career development program. 

• OHR developed and worked with NTEU to finalize a Competency Assessment Survey to inform workforce

planning efforts and shape the future of SEC-wide training and development programs. The survey was

launched in September 2018, and data collection continued into the new fiscal year.

• In early FY 2018, OHR-SECU implemented development plans for specific occupations or combinations

of occupations in the Agency’s learning management system, LEAP. The development plan for examiners

and accountants includes suggested developmental activities and training classes focused on specific

technical knowledge and skill. Further, LEAP provides career path information based on the career ladders

and occupational series to enable employees to identify the next step in development within occupation or to

find lateral transfer opportunities based on competency profile similarity. These tools support employees in

pursuing career growth within the Agency.

• SECU expanded offerings under the Career Horizons program that provide individualized support for

employees in creating development plans and pursuing career growth.

FISCAL YEAR 2019 | 49
Fiscal Year Accomplishments

2018 (continued) In recognition of the critical importance of mentoring to support career development, the Agency considered options

for and developed a pilot mentoring program. In June and July of 2018, a pilot was successfully launched leading to

the first cohort of 30 participants. An orientation session for both mentors and participants was held on September

28, 2018. Throughout FY 2019, mentors will meet with participants on a periodic basis. Formal events are planned

to help guide the mentoring relationship toward success. To encourage participation among PWD, DIAC shared

information about the mentoring program with their membership by quarterly meetings and their shared mailing list.

• In total, 142 permanent employees submitted a statement of interest in the program. Among them, eight

(5.63%) were PWD, for an inclusion rate of 2.09%. By way of comparison, the inclusion rate of persons with

no disability and those who did not self-identify among applicants was 3.37%.

• On a first come, first serve basis, 30 participants were accepted into the mentoring program (29 permanent

and one temporary employee) and matched with volunteer mentors with either or both deep technical

expertise and leadership experience. The 29 permanent employee participants include two (6.90%) PWD, for

an inclusion rate of 0.52%. The inclusion rate of persons with no disability among participations was 0.68%.

• OHR will partner with OMWI and DIAC to improve PWD participation in future mentoring program offerings.

2019 The following provides detail about OEEO’s analytic work in support of this analysis during FY 2019.

1. In line with implementation of Section 501 requirements, OEEO facilitated the Agency’s decision to include

persons hired under authorities that take disability into account as PWD. This action allowed the Agency to

target support, development, and retention efforts toward two persons hired under Schedule A, Part U, and

39 veterans who received hiring preference based on a service connected disability, as PWD.

2. OEEO used a series of self-service workforce data summary tools to review the demographic composition

and disability status data within specific occupations of the entire workforce, newly hired staff, AFD, and

separations by critical organizational characteristics. Workforce data demonstrate the steady participation of

PWD and PWTD meeting the goals established for both PWD and PWTD among lower salaried employees

and PWTD among employees in the higher salary cluster. More work will be needed to meet the participation

of PWD in the higher salary cluster.

3. With respect to awards and recognition, OEEO ran multiple regressions to assess the influence of various

factors on awards distribution outcomes aggregated by award amounts, award hours, and award counts.

Data were analyzed for five years, FY 2013 through FY 2017. The sample sizes were small, limiting the

reliability of the inconsistent effects found for PWD.

4. Based on technical assistance suggested by EEOC’s Office of Federal Operations (OFO), OEEO gathered

qualitative data about the involuntary separation of PWD during FY 2019. Data sources included records

gathered as part of relevant EEO complaint activity filed by separated PWD prior to departure and interviews

with the supervisors of former PWD employees. The data included a small number of employees. No

patterns in results were evident that would form the basis for additional action.

5. OEEO reviewed separations data among PWD in FY 2019. A larger proportion of the PWD population

separated from the Agency, as has been found in prior years. More often than is found for persons with no

disability, PWD separate through voluntary retirement; 60.00% of PWD separations were due to voluntary

retirement, unfortunately an additional 10.00% of the separated PWD died during FY 2019. By way of

comparison, among the separated employees identified as having no disability, 28.46% retired and 0.81%

died during FY 2019. The relationship between age, disability, and retirement is a key explanatory variable to

understand separation data for PWD.

6. Relatedly, OEEO worked with OHR to evaluate the perceptions of separated employees who are PWD from

the Agency’s Exit Survey. These analyses are summarized in other sections of this report.

7. OEEO led an inter-Agency working group to support the implementation of changes to procedures required

or suggested by the revised Section 501 regulation. This working group met two times in FY 2019 and

continued to provide support for agencies seeking to improve conditions for PWD across the government.

In total 14 agencies are represented. The working group helps agencies share best practices and support

their own workforce more effectively. In early FY 2020, OEEO facilitated this working group’s visibility and

achievement in a presentation at the monthly EEO Director’s meeting, thereby, increasing the group’s

influence in the EEO community.

8. In FY 2019, OEEO collaborated with cross functional intra-Agency representatives to develop and publish

a suite of interactive web pages sharing tips for working inclusively with PWD in the workforce. These

tips include resources both within the Agency and externally hosted focused on helping supervisors and

coworkers gain a deeper understanding of how their words and actions may impact PWD differently based

on their particular experiences. This effort involved strong participation from DIAC, OHR, OMWI, and the

Office of Public Affairs. The resources were compiled between July and September and made available to

the workforce during National Disability Employment Awareness Month (NDEAM).

50 | EEO AFFIRMATIVE ACTION PLAN 
Fiscal Year Accomplishments

2019 (continued) 9. In concert with launching the disability inclusion tips, DIAC, OHR, OMWI, and OEEO hosted invited speakers

whose expertise and study focuses on self-identification and support for PWD (among other groups). That

event closed out a highly successful set of NDEAM events including an eyeglasses donation drive in support

of the Lion’s Club’s well known program.

10. OPA continued to expand the support for PWD when they are interacting with SEC staff and resources.

During FY 2019, the external website was modified for increased accessibility to a wider range of members

of the public.

11. OEEO continued to work on implementing the changes required by OFO’s instructions for MD-715 2.0.

Working with data experts in other agencies, OEEO leads the community to understand better the implications

of 2.0 design for reporting and analysis. In particular, OEEO supported work in the following areas:

— Suggested enhancements to the data provided about applicant flow data (AFD) from OPM’s USAStaffing

systems. These suggestions helped to ensure that the revised reporting from AFD included variables to

distinguish supervisory roles and the hiring of permanent versus temporary staff.

— Summarized and analyzed differences in self-identification for internal SEC staff from the records of

applicants, even those who are also SEC staff, filed on the applicant profile in USAStaffing. Among data in

AFD over the five year period from FY 2012 to FY 2018, more than 30% of the records are coded as “I do

not wish to identify my disability.” Over the same time period, self-identification among internal employees

grew so that in FY 2019 more than 85% of staff are specifically identified as to their disability status.

The differences in results from AFD compared to internal records suggests need for additional work to

encourage applicants to self-identify in OPM’s records so as to provide a clearer and more accurate

picture of the government’s efforts to recruit PWD into federal service.

— Engaged with contracted resources to complete the work necessary for updating and expanding the EEOAT for MD-715 2.0. As found in the annual program status report, OEEO completed the 2.0 design. OEEO

also worked to align workforce analysis by race and gender with the operational definitions that workforce

underlie analysis by disability in this plan. Consistent definitions will help ensure OEEO’s continued

influence through data driven practical analytics going forward.

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

planned activities 

Updates to the EEOC’s timelines, instructions, and requirements under MD-715 2 0 extended 

the timeline for implementing feasible changes to workforce data tables providing information 

on PWD and PWTD in collaboration with a shared service provider The modifed date is 

September 30, 2020 

FISCAL YEAR 2019 | 51
5 For the planned activities that were completed, please describe the actual impact of those activities 

toward eliminating the barrier(s) 

As described in other sections above, after a steady increase in participation over the 

past seven years, the Agency achieved the goals established under Section 501 of the 

Rehabilitation Act for both PWTD and PWD at the lower salary levels Because of the 

relatively small size of the PWD and PWTD populations, small changes in workforce 

participation, year over year, can have large impacts on the observed rates of change 

Nonetheless, the SEC notes the following indications of growth within this employee 

population From FY 2013 to FY 2019: 

n	The permanent workforce of PWTD experienced net growth of 12 persons or 16 67%, 

which outpaces the 7 13% net growth in the total permanent workforce over that same 

time period Participation of PWTD in the total permanent workforce rose from 1 81% 

to 1 97% PWTD among higher salaried employees increased from 1 50% to 1 95% (56 

to 83 PWTD employees) 

n	The permanent PWD workforce experienced net growth of 141 persons or 66 82% 

Participation of PWD rose from 5 60% in the total workforce to 8 72% and from 4 93% 

to 8 59% among higher salaried employees, with an additional 158 persons in higher 

salaried jobs identified as PWD 

Trend data over time revealed that increased participation resulted from greater selfidentifcation based on employee resurveys, changes to categories defning PWD, and a 

general increase in the proportion of SEC staff in higher salaried jobs OEEO will continue 

to monitor the PWD and PWTD workforce participation for signs of continued or 

accelerated growth and consider effects of underreporting on these statistics 

Data from SF-256s collected prior to October 2016 were recharacterized in line with the 

defnitions found in the revised form in order to estimate over-time trends Accordingly, the 

numbers of employees who are reported in this trend analysis as PWTD and/or PWD in 

prior years may underestimate the workforce due to the addition of disability and targeted 

disability categories 

52 | EEO AFFIRMATIVE ACTION PLAN 
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 fscal year 

Triggers from the original study of PWTD continue to require focused attention toward 

improvement Starting in FY 2016 and through FY 2019, representatives of OEEO and OHR 

initiated and completed actions intended to address the recommendations to improve equal 

employment opportunity These actions were completed in FY 2019 The Agency will be 

implementing additional required and recommended actions during FY 2020 and beyond 

In the meantime, the plan to address identifed triggers for PWD and PWTD focuses on 

developing SEC’s capability to generate and review the data called for in this Part Further 

analysis of the PWD and/or PWTD population will be considered under the framework for 

prioritizing barrier analysis work embedded in our Agile project planning approach 

FISCAL YEAR 2019 | 53
This page intentionally left blank

OFFICE OF EQUAL EMPLOYMENT OPPORTUNITY 

U.S. Securities and Exchange Commission 

100 F Street NE 

Washington, DC 20549