AFFIRMATIVE 

ACTION PLAN 

AND REPORT

FOR THE RECRUITMENT, HIRING, 

ADVANCEMENT, AND RETENTION OF 

PERSONS WITH DISABILITIES
2 | AFFIRMATIVE ACTION PLAN
FISCAL YEAR 2022 | i

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 4

Plan to Provide Sufficient & Competent Staffing for the Disability Program 4

Plan to Ensure Sufficient 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 14

Advancement Program Plan 14

Career Development Opportunities 16

Awards 22

Promotions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24

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

Voluntary and Involuntary Separations 33

Accessibility of Technology and Facilities 35

Reasonable Accommodation Program . . . . . . . . . . . . . . . . . . . . . . . . . . . .37

Personal Assistance Services Allowing Employees to Participate in the Workplace . . . . .41

Section VI: EEO Complaint and Findings Data . . . . . . . . . . . . . . . . . . . . . . . . .43

EEO Complaint Data Involving Harassment 43

EEO Complaint Data Involving Reasonable Accommodation 43

Section VII: Identification and Removal of Barriers . . . . . . . . . . . . . . . . . . . . . . .44

TABLE B1: TOTAL WORKFORCE—DISTRIBUTION BY DISABILITY 45

Prepared by

THE OFFICE OF EQUAL EMPLOYMENT OPPORTUNITY
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FISCAL YEAR 2022 | 1

SPECIAL PROGRAM PLAN FOR 

THE RECRUITMENT, HIRING, 

ADVANCEMENT, AND RETENTION OF 

PERSONS WITH DISABILITIES

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

targeted disabilities (PWTD), Equal Employment Opportunity Commission (EEOC) regulations 

(29 CFR § 1614.203(e)) and Management Directive-715 (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.

1

SECTION I: EFFORTS TO REACH REGULATORY GOALS

EEOC regulations (29 CFR § 1614.203(d)(7)) require agencies to establish specific numerical 

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

federal government.

1 In FY 2022, Office of Personnel Management (OPM) changed the format of Applicant Flow Data with respect to 

disability identification. A new “disability omitted” category was added, which includes both applicants who did not 

submit a disability identification form and applicants who selected they did not wish to answer questions on their disability 

on the disability identification form. The U.S. Securities and Exchange Commission’s (SEC) MD-715 workforce tables 

account for persons who did not submit a form in a new “No Form” column, and persons who selected they did not 

wish to answer questions on their disability in the “Not Identified” column. Since the Agency has no information on the 

disability status of persons who did not submit a form, persons who did not submit a form are not included in the totals.
2 | AFFIRMATIVE ACTION PLAN

 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 separate results for both persons with disabilities (PWD) and persons 

with targeted disabilities (PWTD) employed, or seeking employment, with the SEC. As 

required by the EEOC, the analysis and report reflect the participation of persons with 

(targeted) disabilities in two different “clusters”—Cluster GS-1 to GS-10, and Cluster GS-11 

to SES (Senior Officer-equivalent for the SEC). The clusters are calculated based on the 

locality adjusted salary specified in the revised regulations implementing Section 501 of the 

Rehabilitation Act of 1973. As a point of reference, in FY 2022, the locality adjusted salary 

of a GS-11, step 1, in the Washington, DC, area was $74,950.

The EEOC has established numerical goals for the employment and utilization of persons 

with disabilities (12%) and persons with targeted disabilities (2%) for each of the two 

clusters. The SEC’s goal is to meet and exceed these relevant benchmarks for PWD and 

PWTD for each cluster.

The SEC included permanent and temporary employees hired under authorities that 

take disability into account as PWD under the relevant hiring authority. Permanent and 

temporary employees who did not self-identify on standard form 256 (SF-256) as having a 

disability but whose personnel record indicates they received veterans’ preference (e.g., 

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-identified on SF-256 but whose personnel record documents that they 

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

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.

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

for PWD participation; three or 30.00% of employees in this cluster were PWD compared 

to the 12% benchmark.

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

achieve the required numerical goal: 10.14% 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 3.57 percentage points since the end of FY 2015.

Between FY 2015 and FY 2022, the participation of PWD in the total workforce increased 

from 6.57% to 9.21%.
FISCAL YEAR 2022 | 3

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 X No 0

The SEC achieved the numerical goal established for PWTD in the lower salary cluster 

during FY 2022. In the lower salary cluster, one of the ten permanent employees is a PWTD.

The SEC did not achieve the numerical goal for PWTD among higher-salaried employees, as 

1.85% of higher-salaried employees are PWTD.

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

and/or recruiters.

The SEC’s Office of Human Resources (OHR) is implementing the 2022 – 2024 Recruitment 

Strategy (Recruitment Strategy) to “Increase workforce representation for people with 

disabilities and people with targeted disabilities.” The Recruitment Strategy employs two 

goals towards this objective: (1) build a talent pool of qualified Schedule A applicants; and 

(2) improve veteran recruitment efforts. SEC senior leadership, OHR, the Office of Equal 

Employment Opportunity (OEEO), and Office of Minority and Women Inclusion (OMWI) 

are working together to communicate these goals throughout the Agency.

OHR continues to communicate opportunities to utilize special hiring authorities, including 

Schedule A hiring options, in conversations with hiring managers to reinforce how the 

Agency may improve progress toward achieving numerical goals. A checklist is used by 

OHR Staffing specialists when vacant positions are identified to ensure hiring managers 

understand all of their options for filling positions, including using Schedule A and veterans’ 

hiring authorities for those applicants with a service-connected disability of 30% or more.

SEC Division and Office heads have access to the Agency’s Diversity Dashboard, an 

interactive web-enabled data feed that aggregates workforce data. Multiple views of gender, 

race, generation, veteran, and disability status provide a real-time status on the progress the 

Agency is making toward its goals. SEC employees explored and engaged with the Diversity 

Dashboard throughout the year, resulting in 1,946 total visits in FY 2022.

Continued on the next page
4 | AFFIRMATIVE ACTION PLAN

OHR also continues to share workforce data through the Human Capital Reporting & 

Analytics (HCRA) dashboard. The HCRA provides, among other key human capital metrics, 

aggregate data on the disability status for self-identified PWD and PWTD. A series of data 

filters enable leaders to understand employee gains and losses within their particular Division 

or Office for specific occupations, grades, and duty stations. OHR uses this information to 

support Human Capital strategic planning. In FY 2022, OHR held Human Capital Review 

sessions with each SEC Division and Office and shared PWD and PWTD on-board and 

target data points. These discussions enhanced transparency and awareness of the Agency’s 

interests in improving workforce diversity.

SECTION II: MODEL DISABILITY PROGRAM

Pursuant to 29 CFR §1614.203(d)(1), agencies must ensure sufficient staff, training and resources 

to recruit and hire persons with disabilities and persons with targeted disabilities, administer 

the reasonable accommodation program and special emphasis program, and oversee any other 

disability hiring and advancement program the Agency has in place.

Plan to Provide Sufficient & Competent Staffing for the Disability Program

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

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

upcoming year.

Yes X No 0

The Agency designated sufficient talent acquisition resources and Full Time Equivalents to 

Special Programs classification, recruitment, and staffing in support of the disability program.
FISCAL YEAR 2022 | 5

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

office, staff employment status, and responsible official.

Disability Program Task

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 

15 0 0 Xiya Li, Branch Chief

Office of Human Resources

lixiy@sec.gov

Answering questions from the public 

about hiring authorities that take 

disability into account

15 0 0 Xiya Li, Branch Chief

Office of Human Resources

lixiy@sec.gov

Processing reasonable 

accommodation requests from 

applicants and employees

2 0 0 Dia Gonsalves, Disability Program Officer

Office of Human Resources 

gonsalvesd@sec.gov

Section 508 Compliance 1 0 0 Sharvon Jones, Section 508 Coordinator

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, 

Space Management Specialist 

OSO-OBO

hairstonc@sec.gov

Special Emphasis Program for PWD 

and PWTD

3 0 0 Xiya Li, Branch Chief

Office of Human Resources

lixiy@sec.gov
6 | AFFIRMATIVE ACTION PLAN

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

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

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

Yes X No 0

Reasonable Accommodation (RA) Program Staff, to include the Disability Program Officer 

(DPO), receive on-the-job training and periodically attend training programs. The office also 

reviews recent case law to stay current with developments in this area. The RA Coordinator 

and the RA Program Staff completed courses specific to recruiting, accommodating disabilities, religious accommodations, performance management, hiring, and retaining PWD 

and PWTD via webinars sponsored by the EEOC, LRP Publications, and through the SEC’s 

on-demand learning management system, LEAP.

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

staffing and placement offered by the USDA Graduate School or OPM and through various 

other platforms. The Agency’s training and development office, SECU, also offers learning 

options that include processing applications for PWD and PWTD. The Agency will continue 

these practices in the future.

Plan to Ensure Sufficient Funding for the Disability Program

1.Has the Agency provided sufficient funding and other resources to successfully implement the 

disability program during the reporting period? If “no”, describe the Agency’s plan to ensure all 

aspects of the disability program have sufficient funding and other resources.

Yes X No 0

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

the disability program.
FISCAL YEAR 2022 | 7

SECTION III: PLAN TO RECRUIT AND HIRE INDIVIDUALS 

WITH DISABILITIES

Pursuant to 29 CFR § 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.

The SEC is committed to being a model employer for people with disabilities. The SEC 

streamlined the approach to the general hiring process using the Schedule A hiring authority 

for persons with disabilities. This streamlined approach for external hiring requests was 

filtered through the Selective Placement Program Coordinator (SPPC) for review. The SPPC 

referred qualified applicants to hiring managers prior to or concurrently with the general 

staffing process.

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

in applicant pools. Since implementation of the FY 2022 – 2024 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. The SEC used OPM’s Agency Talent Portal to search for resumes of individuals 

with disabilities. Invitations to complete the web form and/or apply to jobs posted on 

USAJOBS.gov are sent to individuals with disabilities who demonstrated an interest in 

mission critical occupations (MCO) at the SEC. The SEC noted that in FY 2022, within the 

MCO of Accountant, Examiner, and IT Management, applications from PWD remained at 

the same rates as in FY 2021 or slightly declined.

Despite the mandatory telework posture, the Agency maintained a strong recruitment 

presence in FY 2022, and attended 13 virtual career fairs and events supporting disability 

recruitment efforts in building talent pools for future employment.

In FY 2023, OHR will host two job fairs specifically targeting individuals with disabilities 

and veterans seeking employment opportunities in the SEC’s mission critical occupations and 

will seek opportunities to engage with law and business students interested in internships 

with the SEC. Further, OHR will continue to retain and review applications from people 

with disabilities for future openings and will conduct targeted outreach to connect with 

qualified candidates by collaborating with community-based partners such as nonprofit 

organizations, national and local disability organizations, and federally-funded state and 

local employment programs.

Finally, OHR will continue to leverage the employee affinity group Disability Interests 

Advisory Committee (DIAC) for recruitment resources and assistance.
8 | AFFIRMATIVE ACTION PLAN

2.Pursuant to 29 CFR § 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.

The Disability Program Manager and/or SPPC receives notifications and newsletters from the 

following groups and transmits information to OHR staff engaged in recruitment:

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/agencies/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 officials 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 specific vacancy 

posting and the other for unsolicited Schedule A applications.

1. The Office of Human Resources processes Schedule A applications in response to a Job 

Opportunity Announcement (JOA).

Applicants who wish to be considered for a specific 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-identified appropriate documentation. Applications 

are reviewed by HR specialists to determine if the applicant is minimally qualified as 

identified in the JOA. If the applicant is minimally qualified, that individual is referred to 

the hiring manager on a separate certificate of eligible candidates. HR specialists provide 

written guidance to hiring managers via email that explains how Schedule A applicants 

can be selected once the certificate has been issued.

Continued on the next page
FISCAL YEAR 2022 | 9

2. The Office 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 specific vacancy posting, must submit the appropriate documentation 

as identified by OPM with their application. The SPPC 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 SPPC are reviewed to determine the potential job series 

the applicant may be suitable for based on the knowledge, skills, and abilities identified 

on the applicant’s application. Building a pool of qualified 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 Staffing Action Request Form (SARF) submitted 

by the hiring manager. Upon request, when a SARF is received by OHR, the SPPC 

compiles a certificate of eligible candidates from the database per the job series and refers 

candidates to hiring managers. The SPPC conducts a one-on-one consultation with the 

hiring manager to discuss the certificate 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 December 2021.

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

In FY 2022, OHR Staffing specialists used a hiring checklist in the one-on-one conversation 

with the hiring manager. The checklist contains a section on Schedule A hiring of persons with 

disabilities, and the specialist advises the hiring manager on the Schedule A hiring process and 

offers it as a course of action where applicable.

The SEC will continue to promote among hiring managers the successful use of Schedule A 

hiring to support the SEC’s Recruitment Strategy and Affirmative Action Plan for People with 

Disabilities. In addition, in FY 2023, OHR will develop and launch a new training for hiring 

managers describing the various hiring authorities available to them, including Schedule A 

hiring authority for persons with disabilities.
10 | AFFIRMATIVE ACTION PLAN

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 SPPC continued to maintain established partnerships with organizations that 

assist PWD and PWTD in securing and maintaining employment. The SPPC updated 

the SEC’s list of affinity organizations to maintain contact and foster relationships for 

recruitment events and candidate sourcing. The SEC continued to leverage the Operation 

Warfighter (OWF) program during FY 2022.OWF is an internship program created by the 

Department of Defense that matches qualified wounded, ill, and injured service members 

with non-funded federal internships for them to gain valuable work experience during 

recovery and rehabilitation.

The SPPC also maintains an ongoing relationship with the SEC’s DIAC and the Veterans 

Committee members which help support the Agency’s efforts to recruit PWD and PWTD.

In addition, the Agency continued work to strengthen partnerships with stakeholders to 

include SEC program offices, such as OMWI, the National Treasury Employees Union 

(NTEU), DIAC, and employee affinity groups to identify sustainable actions to improve 

the Agency’s Diversity and Inclusion initiatives for the PWD and PWTD communities.

These actions will promote greater inclusion of the PWD and PWTD communities in the 

SEC workforce and will support their immediate and long-term needs when the Agency 

transitions back to normal work posture post the COVID-19 pandemic.

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 X No 0

In FY 2022, the Agency hired 260 permanent employees, of which PWD and PWTD 

represented 8.46% and 1.15%, respectively, of all new hires. As such, the Agency did not 

achieve the numerical goals of 2% participation of PWTD and 12% participation of PWD 

among permanent new hires.See Table B1.
FISCAL YEAR 2022 | 11

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

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

the triggers below.

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

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

In FY 2022, the SEC hired and on-boarded a total of 260 permanent staff employees.

Among these newly-hired staff members were 197 persons in MCO positions as follows: 

130 attorneys; 14 accountants; 18 securities compliance examiners; 20 IT management 

specialists; and 15 economists. Fifteen of the 197 (7.61%) newly-on-boarded MCO 

permanent staff were PWD.

As a preliminary matter, differences may be observed in comparing the demographic statistics 

of the qualified applicant pool (QAP), selections, and new hires on-boarded. Reasons for 

these differences vary. Some newly-hired staff applied for a vacancy posted in the prior fiscal 

year or may have elected not to volunteer demographic information with their application.

In addition, in FY 2022, one Division posted open continuous announcements for which 

the applicant flow data do not fall into a specific fiscal year based on the close dates of the 

postings. Triggers comparing the composition of PWD and PWTD in applicant flow versus 

new hire data should be interpreted with these differences in mind.

Triggers were observed for PWD in the hiring of permanent IT Management specialists, 

Economists, and Attorneys as follows: 

n For IT Management, 15.00% of new hires were PWD, below their representation in the 

qualified applicant pool of 45.36%.

n For Economists, 20.00% of new hires were PWD, below their representation in the 

qualified applicant pool of 24.02%.

n For Attorneys, 4.62% of new hires were PWD, below their representation in the 

qualified applicant pool of 18.02%.

n For Accountants, 7.14% of new hires were PWD, above their representation in the 

qualified applicant pool of 5.26%.

n For Securities Compliance Examiners, 16.67% of new hires were PWD, above their 

representation in the qualified applicant pool of 9.77%.

Continued on the next page
12 | AFFIRMATIVE ACTION PLAN

Triggers were also observed for PWTD in the Attorney, IT Management, Economist, and 

Accountant occupations:

n For Attorneys, the QAP for PWTD was 3.81%; no PWTD was hired.

n Sixteen PWTD were in the QAP (5.50%) for IT Management, and no PWTD was hired.

n Thirteen PWTD were in the QAP (6.37%) for Economist positions, and no PWTD 

was hired.

n Six PWTD were in QAP (3.45%) for Securities Compliance Examiners, and no PWTD 

was hired.

n One PWTD was in the QAP (2.63%) for an Accountant position, and no PWTD 

was hired.

3.Using the relevant applicant pool as the benchmark, do triggers exist for PWD and/or PWTD 

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

“yes”, please describe the triggers below.

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

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

In the FY 2022 data presented differences were identified in the participation of PWD in 

the qualified internal applicants for competitive promotions as compared to the relevant 

applicant pool (RAP) within the Attorney occupation. Differences were also identified 

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

the MCOs of Securities Compliance Examiner and Economist.

The RAP was defined 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. Specifically, 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 IT 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.

Continued on the next page
FISCAL YEAR 2022 | 13

For Securities Compliance Examiners, the Agency observed a difference between the RAP 

and qualified internal applicants for PWTD. The RAP for PWTD was 1.38%, and PWTD 

represented none of the qualified internal applicants.

For Economists, the Agency observed a difference between the RAP and qualified internal 

applicants for PWD. The RAP for PWD was 5.43%, and PWD represented none of the 

qualified internal applicants. The RAP for PWTD was 3.26%, and there were no PWTD 

among qualified internal applicants.

4.Using the qualified applicant pool as the benchmark, do triggers exist for PWD and/or PWTD 

among employees promoted to any of the mission-critical occupations (MCO)? If “yes”, please 

describe the triggers below.

a. Promotions for MCO (PWD) Yes X No 0

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

The selection data indicate a difference for PWD in the Attorney, Accountant, and IT 

Management occupations.

n For Attorneys, the QAP for PWD was 7.03%, and PWD were 5.56% of selections.

n For Accountants, the QAP for PWD was 18.18%, and PWD were 0.00% of selections.

n For IT Management, the QAP for PWD was 62.60%, and PWD were 50.00% 

of selections.

The selection data also indicate there were differences between selections and the qualified 

applicant pool for PWTD in the Accountant and IT Management occupations.

n For Accountants, the QAP for PWTD was 13.64%, and PWTD were 0.00% 

of selections.

n For IT Management, the QAP for PWTD was 6.50%, and PWTD were 0.00% 

of selections.
14 | AFFIRMATIVE ACTION PLAN

SECTION IV: PLAN TO ENSURE ADVANCEMENT OPPORTUNITIES FOR 

EMPLOYEES WITH DISABILITIES 

Pursuant to 29 CFR §1614.203(d)(1)(iii), agencies are required to provide sufficient advancement 

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

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

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

programs designed to ensure advancement opportunities for employees with disabilities.

Advancement Program Plan

1.Describe the Agency’s plan to ensure PWD, including PWTD, have sufficient 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 in the workforce, 

including PWD and PWTD. The following describes efforts to promote opportunities 

for advancement.

Information about training, the Agency’s Mentoring Program, and career development 

opportunities is widely shared with the workforce via SEC Today, which is the SEC’s daily 

newsletter published agency wide.

OHR 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.

The Chief Human Capital Officer (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.

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.

Continued on the next page
FISCAL YEAR 2022 | 15

In FY 2022, OHR reserved five (5) slots in the 2022 Mentoring Program cohort for 

employees with disabilities and collaborated with DIAC to communicate this opportunity.

Through this collaboration, the SEC exceeded its goal—six PWD participated in the 

FY 2022 Mentoring Program.

In addition, in FY 2021, the SEC launched a cross-office working group comprised of 

Senior Officers who are champions of disability inclusion, subject matter experts in OHR, 

OEEO, OMWI, and key members of the DIAC. This working group began meeting in 

FY 2021 and, leveraging evidence-based data, made 17 recommendations to management 

in FY 2022 related to the recruitment, hiring, career development, promotion, reasonable 

accommodation, and retention of PWD and PWTD at the SEC (PWD Recommendations).

Subsequently, the SEC launched a new cross-office working group (comprised of accountable 

experts and/or leads in OHR, OMWI, OEEO, OIT, and OCOO) charged with implementing 

the PWD Recommendations. The majority of the 17 PWD Recommendations fall within 

OHR’s jurisdiction, and OHR has already implemented a couple of recommendations, 

including, the sharing of the Schedule A PWD list with Division/Office hiring managers prior 

to the publication of a job announcement provided there are qualified candidates in the 

resume database to refer, and sharing aggregate disability data with Divisions/Offices as part 

of the Human Capital reviews.

The PWD Recommendations serve as guiding principles for this new working group.

In FY 2022, for each recommendation accepted by the Agency for implementation, the 

working group identified the responsible office/branch and established projected timeframes 

for implementation. To ensure progress is made on the recommended actions, the 

implementation working group meets on a monthly basis and has scheduled accountability 

meetings with Agency leaders—including the Agency’s Operations Steering Committee (a 

standing committee that is consulted on various matters related to the Agency’s human 

capital), the Chief Operating Officer, and the two Senior Officer co-leads for the working 

group that developed the recommendations. The accountability meetings not only serve to 

hold the working group accountable but also as an opportunity to request needed resources 

and/or support from other Agency stakeholders in the implementation phase.

The PWD recommendations will be the focus of intentional effort in FY 2023.
16 | AFFIRMATIVE ACTION PLAN

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 

certifications 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), 

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 career 

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

captured along with other training program data noted in the section below.

n The C.O.R.E. Connections—Opportunity—Relationships—Equity program is a 

transformative professional development experience designed to provide employees at 

the SEC with tools and techniques to increase their effectiveness, span of contributions 

and engagement within their function, and support their personal well-being and 

growth. The series equips employees with knowledge, skills, and strategies to 

successfully manage their unique challenges as they strive to reach senior-level positions 

at the SEC while helping to drive our Agency’s overall success and mission effectiveness.

The series has five two-hour webinars, in which participants learn strategies for 

authentic and difficult conversations, managing conflict and exploring the role that 

emotions play in leadership outcomes.

n Leadership Development for Women program was developed by SECU in place of the 

Brookings Institute’s Women in Leadership Program. In FY 2022, CLTD offered three 

sessions of Lead Forward: Leadership Development for Women at the SEC. This course 

presents the opportunity for women to engage with other women, increase their support 

network, and further define their leadership style and mindset. Participants learn more 

about the leaders they want to be and make commitments about behavioral changes 

they want to implement to move their own careers forward, advocating for themselves 

and for other women.

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 to share what they are learning and 

to explore how this information can be applied to improve organizational performance, 

workplace relationships, and productivity.

Continued on the next page
FISCAL YEAR 2022 | 17

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; and understanding government 

policy, process, and regulations.

n The Career Advancement Program (CAP) is a 12-month external professional 

development program geared toward mid-career professionals who aspire to senior 

leadership roles. CAP is conducted by Management Leadership for Tomorrow (MLT), 

a nonprofit organization that aims to transform the career trajectories of diverse leaders 

by providing them the skills, coaching and connections needed to accelerate their 

careers. CAP’s professional development journey includes realistic business simulations, 

sustainable strategies and tools for professional growth and development, and a cohort 

of peers representing various industries and functions.

n The Upward Mobility Program offers SEC employees in support staff positions the 

opportunity to expand their careers by competing for entry-level program specialist 

positions (series 301) starting at the SK-7 or SK-9 level and with promotion potential 

to the SK-12 level. These positions are open to all SEC employees serving under a 

permanent appointment. This program includes two years of formal training designed 

to foster the success of participants. The training, developed by SEC University, includes 

tailored guidance and mentoring for both the participants and their supervisors.

In addition to the career development programs referenced above, the Agency encourages 

employees, including PWD and PWTD, to pursue leadership development through a variety 

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

program. In FY 2022, 56 SEC managers engaged in coaching with an external coach. Due 

to confidentiality considerations, the SEC does not track demographic information for the 

employees engaged in coaching opportunities. Non-supervisory offerings developed for 

leaders without formal authority included, for example: Empowering Your Development

and Leading Without Authority (courses are designed to enhance relationship-building and 

maintain effective relationships for SEC leaders at all levels).Continued on the next page
18 | AFFIRMATIVE ACTION PLAN

In FY 2022, the SEC finalized and launched a Leadership, Evaluation, Accession, and 

Development Program (LEAD Program), which emphasizes the importance of certain 

leadership skills essential for success at the SEC. The program is designed to improve the 

process for developing, identifying, and selecting future SEC Senior Officers (SOs) by 

including standardized leadership assessments that screen candidates on essential leadership 

competencies in a fair and legally-compliant manner. In August 2022, OHR launched the 

LEAD website, which serves as a repository of LEAD Program information and offers links 

to training and resources that support self-directed leadership development. The easy-tonavigate website is available to all SEC employees to learn about the program, use leadership 

development tools, and advocate for their own leadership development opportunities that are 

aligned to critical SO leadership competencies. The LEAD website also provides assessment 

information and self-preparation materials for employees interested in applying to SO 

positions. The Managing Board and LEAD team developed the leadership assessments, and 

worked with a leading HR consulting firm, to provide automated test delivery that ensures 

fair and standardized applicant testing. This standardized approach eliminates unintended 

test bias, providing all applicants a comparable testing process and experience. Trained 

raters score LEAD assessments, with candidate responses anonymized prior to scoring, 

where possible. In addition, internal SEC applicants receive feedback on the LEAD 

assessments, highlighting their leadership strengths and weaknesses, to support their 

ongoing leadership development.

In addition to targeted communications to educate employees and create awareness on the 

LEAD Program, in Q4 FY 2022, OHR offered a series of general informational briefings for 

all interested employees and provided briefings to Division and Office management teams.

After an initial launch of the LEAD assessments with vacancies in the Division of Investment 

Management and OCOO offices, an agency-wide launch of the LEAD assessments is 

planned for FY 2023.
FISCAL YEAR 2022 | 19

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

competition and/or supervisory recommendation/approval to participate.

Career Development Opportunities

Total Participants PWD PWTD

Applicants 

(#)

Selectees 

(#)

Applicants 

(%)

Selectees 

(%)

Applicants 

(%)

Selectees 

(%)

Internship Programs 52,770 6,219 3.51% 4.58% 1.68% 1.09%

Fellowship Programs 86 19 0.00% 0.00% 0.00% 0.00%

Mentoring Programs 31 31 12.90% 12.90% 9.68% 9.68%

Coaching Programs NA NA NA NA NA NA

Training Programs 38,837 38,837 9.22% 9.22% 1.67% 1.67%

Detail Programs 86 25 20.93% 16.00% 1.16% 0.00%

Other Career Development Programs 41 35 9.09% 9.09% 0.00% 0.00%

Notes to help the reader understand the data above: 

The SEC’s Mentoring Program was open for registration to all employees. Mentees were selected 

on a first-come, first-served basis.

Due to confidentiality considerations, the SEC does not track demographic information for 

employees engaged in coaching programs.

Training Programs data show demographic data for all permanent employees’ registrations for 

training in LEAP and completed training opportunities during FY 2022. 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 by the 

Agency for competitive selection. 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.

In this report, the Agency included FY 2022 selection data for its leadership development 

programs, including the Excellence in Government Fellows Program and the Aspiring Leaders 

Program. While completion of these programs do not lead to placement at a specific grade (a 

criterion for inclusion in the MD-715 Workforce Data Tables), they do contribute to the pool 

of employees who may potentially be considered for leadership positions in the future. Data 

for these leadership programs have been consolidated into the “Other Career Development 

Programs” category.
20 | 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 and selections for various programs were reviewed.

For the Internship Program, 3.51% of applicants were PWD and PWD were 4.58% of 

selections. As selections had a higher percentage of PWD than the percentage of PWD among 

applicants, there was no trigger for internships.

For the Agency’s Economist, Accountant and Attorney Fellows Programs, the Agency noted 

no difference in the participation of PWD among (external) applicants for these programs 

and eventual selections for positions. While 0.00% of applicants were PWD, none of the 

Fellows hired were PWD (0.00%).

Within the Agency’s Mentoring Program (selections were on a first-come, first-served basis), 

the Agency found no evidence of a trigger in the participation rate among those who applied 

for the Mentoring Program (i.e., applicants) as compared to participation of PWD in the 

permanent workforce (9.21%). PWD represent 12.90% of those employees who expressed 

interest in the Mentoring Program and 12.90% of those selected for mentoring.

In FY 2022, training data includes trainings approved on standard form 182 through 

the Agency’s learning management system, LEAP, trainings from Pluralsight, Becker, the 

Practising Law Institute, and Udemy. Aggregate PWD participation in training programs 

matched their participation on rolls: 9.22% of trainings were completed by PWD, compared 

to 9.21% of permanent employees who are PWD. No trigger was found for applications 

or selections.

Data about detailed employees show evidence of differences in selection disadvantaging 

PWD among those who applied for details and among those selected. While 9.21% 

of permanent staff were PWD, 20.93% of applicants for temporary promotion were 

PWD, and PWD were 16.00% of selections. Selection data for PWD on Other Career 

Development Programs indicated no evidence of a trigger for PWD. PWD were 9.09% of 

selectees among the consolidated selectees of the Excellence in Government and Aspiring 

Leaders programs, and 9.21% of permanent SEC employees.
FISCAL YEAR 2022 | 21

4.Do triggers exist for PWTD among the applicants and/or selectees for any of the career development programs identified? (The appropriate benchmarks are the relevant applicant pool for 

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

a. Applicants (PWTD) Yes X No 0

b. Selections (PWTD) Yes X No 0

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

PWTD in various programs were reviewed for equality of employment opportunity in the 

applications and selections for these programs.

In the Agency’s Economist, Accountant, and Attorney Fellows Programs, 0.00% of 

applicants were PWTD, thus, no PWTD were selected as Fellows in FY 2022.

For the Internship Program, 1.68% of applicants were PWTD, and PWTD were 1.09% of 

selections. Within the Agency’s Mentoring Program, the participation rate for PWTD among 

applicants (9.68%) exceeded the percentage of PWTD among permanent staff (1.86%).

Thus, no trigger was found among applicants. The participation of PWTD among employees 

selected for mentoring in FY 2022 (9.68%) exceeded the participation rate of PWTD in the 

permanent workforce. Thus, no trigger was found among selections.

No evidence of a trigger was found among applicants or selections in the training programs.

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

above their participation on rolls; 1.67% of training opportunities requiring special approval 

were completed by PWTD, compared to 1.86% of permanent employees.

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

those who applied for Temporary Promotion and among those selected. While 1.16% of 

applicants for temporary promotion were PWTD, PWTD represent 0.00% of permanent 

staff employees selected.

Selection data for PWTD on Other Career Development Programs suggested a trigger at 

the application phase. Of 41 selectees among the consolidated selectees for the Excellence 

in Government and Aspiring Leaders programs, no applicants were PWTD, and as a result, 

none were selected.
22 | 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

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. This analysis requires aggregating data to the person level. Employees 

who received at least one award in any particular award category are counted once.

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

who received each type or category of award. One employee can and often does receive more 

than one award in a year. One employee is represented more than once if he or she received 

more than one award in that category.

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 found a trigger in the distribution of time-off awards of 11–40 hours for 

PWD. The inclusion rate for PWD was 18.05%, while the inclusion rate for people without 

disability was 19.07%. The inclusion rate for PWTD was 18.07%.

Continued on the next page
FISCAL YEAR 2022 | 23

For cash awards, the Agency found triggers for PWD and PWTD for cash awards of 

$1,000–$1,999 and $2,000–$2,999.

For cash awards at the $1,000–$1,999 level, the inclusion rate for PWD was 31.46%, and 

the inclusion rate for persons without disability was 41.07%. The inclusion rate for PWTD 

was 28.92%, and the inclusion rate for persons with no targeted disability was 40.40%.

For cash awards at the $2,000–$2,999 level, the inclusion rate for PWD was 6.34%, and 

the inclusion rate for persons without disability was 10.17%. The inclusion rate for PWTD 

was 6.02%, and the inclusion rate for persons with no targeted disability was 9.89%.

OEEO researched the observed differences in the distribution of discretionary awards, made 

recommendations, and is actively monitoring the implementation as part of our barrier 

analysis program.

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

The Agency did not have a trigger for PWD or PWTD for performance-based pay increases.

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

N/A
24 | AFFIRMATIVE ACTION PLAN

Promotions

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

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

applicant pool for qualified internal applicants and the qualified applicant pool for selectees.) For 

non-GS pay plans, please use the approximate senior grade levels. If “yes”, describe the trigger(s) 

in the text box.

a. SES

Qualified Internal Applicants (PWD) Yes X No 0

Internal Selections (PWD) Yes 0 No X

b. Grade GS-15

Qualified Internal Applicants (PWD) Yes 0 No X

Internal Selections (PWD) Yes X No 0

c. Grade GS-14

Qualified Internal Applicants (PWD) Yes 0 No X

Internal Selections (PWD) Yes X No 0

d. Grade GS-13

Qualified Internal Applicants (PWD) Yes 0 No X

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 

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.

Of 1,044 qualified internal applications for senior grade level positions, 374 (35.82%) were 

submitted by PWD.

A trigger was observed for qualified applicants compared to the Relevant Applicant Pool 

for PWD at the SES-equivalent level. However, there was only one posting, and two selfidentified applicants. The Relevant Applicant Pool was 7.44%, and neither of the two 

applicants were PWD. No differences were observed among qualified applicants at any 

of the other senior grades.

Continued on the next page
FISCAL YEAR 2022 | 25

Among internal selections, differences were observed at the GS-15, GS-14, and GS-13 

equivalent levels, but not the SES-equivalent level. Of the 100 selections for internal 

promotions to senior grade levels, 8.00% were PWD, which was below their availability in 

the QAP at 35.82%.

At the GS-15 equivalent level, PWD represented 31.31% of qualified applicants, while they 

represented 3.85% of selections.

At the GS-14 equivalent level, PWD represented 29.69% of qualified applicants, while they 

represented 15.00% of selections.

At the GS-13 equivalent level, PWD represented 53.25% of qualified applicants, while no 

selections were PWD.

2.Does your Agency have a trigger involving PWTD among the qualified internal applicants and/or 

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

applicant pool for qualified internal applicants and the qualified applicant pool for selectees.) For 

non-GS pay plans, please use the approximate senior grade levels. If “yes”, describe the trigger(s) 

in the text box.

a. SES

Qualified Internal Applicants (PWTD) Yes X No 0

Internal Selections (PWTD) Yes 0 No X

b. Grade GS-15

Qualified Internal Applicants (PWTD) Yes 0 No X

Internal Selections (PWTD) Yes X No 0

c. Grade GS-14

Qualified Internal Applicants (PWTD) Yes 0 No X

Internal Selections (PWTD) Yes X No 0

d. Grade GS-13

Qualified Internal Applicants (PWTD) Yes 0 No X

Internal Selections (PWTD) Yes X No 0
26 | AFFIRMATIVE ACTION PLAN

Applying the same comparisons to PWTD as described above, the Agency presents 

information on trigger identification for PWTD in promotions to senior grade levels. Of 

1,044 qualified internal applications for senior grade level positions, 61 (5.84%) were 

submitted by PWTD, and no selections were PWTD.

A difference was observed in the qualified applicant pool for the SES-equivalent level, 

compared to the Relevant Applicant Pool. The Relevant Applicant Pool was 1.33% PWTD, 

and no qualified applicants were PWTD. However, there was only one posting, and it had 

two self-identified applicants. No differences were observed among qualified applicants 

at any of the other senior grades. Among selections, triggers were observed at the GS-15, 

GS-14, and GS-13 equivalent levels.

At the GS-15 equivalent level, PWTD represented 6.31% of qualified applicants, and 

represented no selections.

At the GS-14 equivalent level, PWTD represented 3.39% of qualified applicants, and 

represented no selections.

At the GS-13 equivalent level, PWTD represented 8.94% of qualified applicants, and 

represented no selections.
FISCAL YEAR 2022 | 27

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

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

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

a. New Hires to SES (PWD) Yes X No 0

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

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

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

The QAP summarizes data where the applicant self-identified with a disability and qualified 

for the position. Data describe vacancies for permanent positions with the SEC that were 

posted in USAJOBS with a closing date during the fiscal year. Also presented is data on new 

hires on-boarded during the course of the fiscal year, some of whom applied for a vacancy 

posted prior to the start of the fiscal year, and some of whom were on-boarded from open, 

continuous postings. 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 (See Question 5 immediately below) in applicant flow versus new hire data 

should be interpreted with these differences in mind.

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

information on trigger identification for PWD new hires to senior grade levels. Among 

the 260 newly-hired staff members in FY 2022 were 207 persons hired into senior grade 

level positions: four SOs, three into GS-15 equivalent positions, 109 into GS-14 equivalent 

positions, and 87 into GS-13 equivalent positions. Sixteen of those 207 (7.73%) newlyhired permanent staff in senior grade levels identified as PWD. The following evaluates 

participation of PWD in each senior grade equivalent level.

At the SES equivalent level, the QAP was 10.42% PWD, and none of the four newly-hired 

permanent SOs identified as PWD.

At the GS-15 equivalent level, the QAP was 31.94% PWD, and 14.29% of the seven newlyhired permanent staff for those positions identified as PWD.

At the GS-14 equivalent levels, the QAP was 19.94% PWD, and 9.17% of the 109 newlyhired permanent staff were PWD.

At the GS-13 equivalent level, the QAP was 24.24% PWD, while 5.75% of the 87 new hires 

to GS-13 equivalent positions identified as PWD.
28 | AFFIRMATIVE ACTION PLAN

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

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

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

a. New Hires to SES (PWTD) Yes 0 No X

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

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

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

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

information on trigger identification for PWTD new hires to senior grade levels. The 

qualified applicant pool for PWTD was 2.32%.

The Agency found triggers in participation of PWTD between qualified applicants and new 

hires at the SES, GS-15, GS-14, and GS-13 equivalent levels.

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

At the SES equivalent level, none of the qualified applicants were PWTD, and none 

were hired.

At the GS-15 equivalent level, the QAP was 5.76%; no newly-hired staff members were 

PWTD (0.00%).

At the GS-14 equivalent level, the QAP was 4.59% PWTD; 1.83% of the newly-hired 

GS-14 equivalent staff were PWTD.

At the GS-13 equivalent level, the QAP was 5.37% PWTD; 1.15% of the newly-hired staff 

members were PWTD.
FISCAL YEAR 2022 | 29

5.Does your Agency have a trigger involving PWD among the qualified internal applicants and/or 

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

applicant pool for qualified internal applicants and the qualified applicant pool for selectees.) If 

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

a. Executives

Qualified Internal Applicants (PWD) Yes X No 0

Internal Selections (PWD) Yes 0 No X

b. Managers

Qualified Internal Applicants (PWD) Yes 0 No X

Internal Selections (PWD) Yes X No 0

c. Supervisors

Qualified Internal Applicants (PWD) Yes 0 No X

Internal Selections (PWD) Yes X No 0

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. The Agency notes that, similar to the senior grade level 

equivalencies, the relevant applicant pools 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 specific leadership levels differ.

FY 2022 data are relevant for assessing whether triggers exist with regard to promotions to 

supervisory or managerial positions. Among the promotions in FY 2022 were 54 persons 

promoted to a leadership position at the supervisor, manager, or executive level: one SO, 

27 managers, and 24 supervisors. The following evaluates participation of PWD in each 

leadership level.

For executives, a trigger was observed for qualified applicants compared to the Relevant 

Applicant Pool for PWD. However, there was only one posting, and two self-identified 

applicants. The Relevant Applicant Pool was 7.44%, and neither of the two applicants 

were PWD.

For the manager, and supervisor levels, there were no differences to the disadvantage of PWD 

in the qualified internal applicant pool compared to the RAP. However, there were triggers at 

both of these levels with respect to selections. For managers, the qualified applicant pool was 

40.14%, and PWD were 3.70% of selections. For supervisors, the qualified applicant pool 

was 61.29%, and no PWD were selected.
30 | AFFIRMATIVE ACTION PLAN

6.Does your Agency have a trigger involving PWTD among the qualified internal applicants and/or 

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

applicant pool for qualified internal applicants and the qualified applicant pool for selectees.) If 

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

a. Executives

Qualified Internal Applicants (PWTD) Yes 0 No X

Internal Selections (PWTD) Yes 0 No X

b. Managers

Qualified Internal Applicants (PWTD) Yes 0 No X

Internal Selections (PWTD) Yes X No 0

c. Supervisors

Qualified Internal Applicants (PWTD) Yes 0 No X

Internal Selections (PWTD) Yes X No 0

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

information on trigger identification for PWTD internal promotions to supervisory positions.

Of 54 individuals selected for promotion, none were PWTD.

At the Executive level, the Agency observed triggers with respect to qualified applicants and 

selections. The RAP was 1.33% PWTD, and none of the qualified applicants were PWTD.

As such, no PWTD were selected. However, there was only one posting, for which there were 

two qualified applicants.

At the manager level, the Agency observed a trigger with respect to selections for 

promotions. The QAP for PWTD was 4.93%, while no selections were PWTD.

At the supervisor level, the Agency observed a trigger with respect to selections for 

promotions. The QAP for PWTD was 10.97%, while no selections were PWTD.
FISCAL YEAR 2022 | 31

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

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

in the text box.

a. New Hires for Executives (PWD) Yes 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 above, the Agency presents 

information on trigger identification for PWD new hires into leadership positions.

A difference was found in FY 2022 new hire data for PWD at the executive and supervisor 

levels. No trigger was found at the manager level.

Among the 260 newly-hired staff members in FY 2022 were 12 persons hired into leadership 

positions: four SOs, four SK-17 managers, and four supervisors below SK-17. One of those 

12 (8.33%) newly-hired permanent staff in leadership positions identified as PWD. The 

following evaluates participation of PWD in each leadership level.

For executives, the QAP was 10.42% PWD, and none of the four newly-hired permanent 

executives identified as PWD.

For managers, the QAP was 25.96% PWD, and 25.00% of the four newly-hired managers 

identified as PWD.

For supervisors, the QAP was 37.11%, and none of the four newly-hired permanent 

supervisors identified as PWD.
32 | AFFIRMATIVE ACTION PLAN

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

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

in the text box.

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

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

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

Differences were found in the new hire data for PWTD at the executive, manager, and 

supervisor levels.

For executives, the QAP was 2.08% PWTD, and no PWTD were hired for executive 

positions in FY 2022.

For managers, the QAP was 3.85% PWTD, and no PWTD were hired for manager positions 

in FY 2022.

For supervisors, the QAP was 7.22% PWTD, and no PWTD were hired for supervisor 

positions in FY 2022.
FISCAL YEAR 2022 | 33

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 CFR § 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. During FY 2022, one employee was converted to the competitive service 

under the Schedule A hiring authority within two years of their most recent Schedule 

A appointment. Five employees are currently serving on their most recent Schedule A 

appointment that was processed within the past two years. All five employees are serving 

on an initial Schedule A appointment that has not reached the two-year threshold. One staff 

member was newly-hired under Schedule A during FY 2022. 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 2022, confirms that all were converted to the competitive service within two 

years of their most recent Schedule A appointment.
34 | AFFIRMATIVE ACTION PLAN

2.Using the inclusion rate as the benchmark, did the percentage of PWD among voluntary and involuntary separations exceed that of persons without disabilities? If “yes”, describe the trigger below.

a. Voluntary Separations (PWD) Yes 0 No X

b. Involuntary Separations (PWD) Yes 0 No X

Data on voluntary and involuntary separations by disability were used to calculate the 

inclusion rates. 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 self-identify as having a 

disability).

The Agency did not have a trigger for voluntary separations in FY 2022. The inclusion rate 

on voluntary separations was 3.41% for PWD, and 5.76% for persons with no disability.

The inclusion rate on involuntary separations was 0.24% for PWD and 0.05% for persons 

with no disability.

3.Using the inclusion rate as the benchmark, did the percentage of PWTD among voluntary and 

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

trigger below.

a. Voluntary Separations (PWTD) Yes 0 No X

b. Involuntary Separations (PWTD) Yes 0 No X

The 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 targeted 

disability (this group also includes those who did not self-identify as having a disability and 

those with a disability that is not targeted).

The Agency did not have a trigger for voluntary separations in FY 2022. For PWTD, the 

inclusion rate on voluntary separations was 1.20%, and the inclusion rate for persons 

without targeted disability was 5.63%.

For PWTD, there were no involuntary separations in FY 2022, and among persons with no 

targeted disability, the inclusion rate for involuntary separations was 0.07%.
FISCAL YEAR 2022 | 35

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

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

Not applicable. There were no triggers involving separation rates in FY 2022.

Accessibility of Technology and Facilities

Pursuant to 29 CFR § 1614.203(d)(4), federal agencies are required to inform applicants and 

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

concerning the accessibility of Agency technology, and the Architectural Barriers Act of 1968 (42 

U.S.C.§ 4151-4157) concerning the accessibility of Agency facilities. In addition, agencies are required 

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

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

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

description of how to file a complaint.

Information about the SEC’s Accessibility/Disability Program is posted on SEC.gov: 

SEC.gov/disability/sec_access.htm and SEC.gov/accessibility/sec-accommodationprocedures.pdf. The SEC has also made available a Section 508 Resource Center to all 

SEC personnel. This online resource center provides links to accessibility training and 

resources, federal regulations and general guidance, as well as “how-to” instructions to 

make documents, presentations, and electronic files 508-compliant. Information specific 

to the accessibility of SEC facilities and technology under Sections 504 and 508 of the 

Rehabilitation Act is also available in a variety of sources, including 17 CFR §§ 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.

The 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. If a product 

is deemed not 508-compliant, project teams are instructed to submit a Remediation Plan 

indicating a plan of action or timeline in which the vendor will make the respective product 

508-compliant and obtain an approval from senior management before deploying.

Continued on the next page
36 | AFFIRMATIVE ACTION PLAN

Every SEC vacancy announcement posted to USAJOBS includes information about obtaining 

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

Placement Program Coordinator is posted on OPM’s website. OHR has built a separate page 

providing more in-depth information about hiring PWD (SEC.gov/sec-disability-programsoverview). This page includes a link to an online form (SEC.gov/forms/ADA-4Applicants) 

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 posts information on how to file 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 file a complaint.

Information is posted on SEC.gov: 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 file a complaint alleging violations of the Architectural 

Barriers Act.
FISCAL YEAR 2022 | 37

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

undertaking over the next fiscal year, designed to improve accessibility of Agency facilities and/

or technology.

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

notified of the defects and are instructed to submit, for approval, a Remediation Plan, 

indicating a definitive timeline in which the vendor will make the respective product 

508-compliant.

The Office 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.

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

Regulation that defines 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 CFR § 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.)

In FY 2022, the SEC met its goal of processing 100% of accommodation requests within 

45 business days, the timeframe specified in the Agency’s policy, which has been approved by 

the EEOC.
38 | AFFIRMATIVE ACTION PLAN

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.

Beginning in FY 2019, the SEC conducted an internal review of the SEC Reasonable 

Accommodation Regulation (SECR 6-80) and SEC Reasonable Accommodation Operating 

Procedures (SECOP 6-80), collected input from SEC stakeholders, negotiated with the SEC’s 

union, and revised the reasonable accommodation policy and procedures. In March 2021, as 

required by regulation, the Equal Employment Opportunity Commission (EEOC) approved 

the SEC’s procedures. The new procedures include a revised timeframe to process requests 

for accommodation—from 20 business days to 45 business days—absent undue hardship.

The SEC published in FY 2022 the revised RA policy and operating procedures.

These policy and operating procedure documents ensure that employees and applicants 

know their right to receive a reasonable accommodation for disability-related limitations 

under the Rehabilitation Act, if needed, to perform the essential functions of their position, 

enjoy equal benefits and privileges of employment, or apply for a job at the SEC. Related 

operational guidance further explains stakeholder responsibilities for the provision of 

disability-related accommodation, how to request an accommodation, and how such 

requests are processed. The procedures also include information about the interactive 

process and how requestors may seek review of decisions when a request has been denied.

A 508-compliant version of each document and form is available on the SEC’s public 

website at SEC.gov, as required under the Section 501 Affirmative Action Regulations.

The documents are also available on the SEC’s internal interactive portal AskHR.AskHR

provides employees with information about reasonable accommodation and the processes 

for making requests. The SEC published additional resources and information for employees, 

supervisors, and managers on its AskHR portal that provides a general overview and insight 

into its reasonable accommodation program process.

Changes to RA procedures necessitated updates to training, job aids, notices, and other 

information sources in FY 2022. Information sessions describing updates, applicable forms, 

and procedures have been made available to manager/supervisors, employees, and all staff 

with responsibilities under the new policy and procedures. The updated RA procedures have 

been incorporated in the mandatory New Supervisors and New Employee trainings, and 

the on-demand trainings available in the SEC’s LEAP training platform made available to 

Agency employees. At least annually, the Agency communicates to the entire SEC workforce 

regarding the reasonable accommodation program to assist managers and employees in their 

understanding of the SEC’s disability accommodation program.

Continued on the next page
FISCAL YEAR 2022 | 39

In FY 2022, the SEC remained in a maximum telework/voluntary return to the office posture 

for its non-essential employees. The SEC’s Temporary Medical Telework (TMT) program 

provides temporary telework to employees with short-term medical conditions that may 

not constitute a covered disability under the Rehabilitation Act of 1973 when supervisory 

officials and the Disability Program Office determine that it is appropriate. Since the SEC 

continued its maximum telework posture, the RA Program office administratively closed 

four (4) TMT requests without decision in FY 2022.

Given the issuance of the newly revised RA policy and procedures, general training 

for managers and supervisors was offered on the Rehabilitation Act, their role and 

responsibilities in the reasonable accommodation process to include the interactive process 

provision, and how to respond appropriately when an individual places them on notice of 

the need for reasonable accommodation. New managers and supervisors are also required 

to attend scheduled training to obtain an in-depth overview for the provision of reasonable 

accommodation. This includes disseminating program-specific information during the New 

Employee Orientation and CLTD 307 Fundamentals of Human Resources Management 

course offered by the SEC University’s College of Leadership and Team Development.

In FY 2022, the SEC converted all in-person CLTD 307 content into a final capstone 

eLearning module to be added to the other CLTD 307 eLearning modules. This capstone 

offers self-paced review and practice opportunities that were previously encompassed by the 

live trainings, and serves to replace any need for live content. All CLTD 307 content is now 

in a fully self-paced eLearning format. CLTD 307 eLearning provides real-time, scenariobased specific illustrations for supervisors and managers to heighten their awareness of the: 

(1) Schedule A hiring authority; (2) SEC’s RA Program; (3) TMT to ensure their awareness 

of their role in hiring and retaining employees with temporary or permanent disabilities; 

(4) types of requests made by employees with disabilities; and (5) roles and responsibilities 

with respect to the Agency’s Reasonable Accommodation Program. This training was 

enhanced by the Reasonable Accommodation Program Office to ensure awareness of the 

SEC’s newly published RA Program policy and operating procedures. In-depth, situationspecific training was provided as-needed to individual managers who supervise employees 

with disabilities. Additional information about CLTD 307 is provided earlier in this 

report, supra.

Moreover, refresher on-demand training course offerings are readily available online for 

employees and managers through the Agency’s learning platform, Learn Engage Achieve 

Platform (LEAP), which provides an effective overview of the Rehabilitation Act and the 

federal and SEC reasonable accommodation process.

Continued on the next page
40 | AFFIRMATIVE ACTION PLAN

The SEC maintains a contract vehicle with Deaf Access Solutions (DAS) for its Sign 

Language Interpretation Program. DAS provides enhanced interpretation solutions to include 

Communication Access Realtime Translation and Federal Relay Service to provide a more 

diverse pool of interpreters who can provide a greater array of support services for the Deaf/

Hard-of-Hearing community.

In FY 2022, to complement the Agency’s reasonable and religious accommodation processes, 

the SEC continued working with the Office of Information Technology to vet and configure 

an automated reasonable and religious accommodation case management solution. The 

system will enable the Agency to monitor trends and manage, track, and enhance reporting 

capabilities on all reasonable and religious accommodation requests, including requests for 

personal assistance services. The system will have a built-in reporting capability to produce 

all reporting and record keeping requirements consistent with 29 CFR § 1614.203(d)(5) and 

Executive Order 13164. The case management system is expected to simplify case tracking, 

help identify systemic delays, improve customer service by allowing employees to request 

reasonable accommodations personally and privately, and allow the Agency to continue to 

meet timeliness standards. The Agency expects to fully deploy the system in FY 2023. In the 

interim, OHR continues 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.
FISCAL YEAR 2022 | 41

Personal Assistance Services Allowing Employees to Participate 

in the Workplace

Pursuant to 29 CFR § 1614.203(d)(5), federal agencies, as an aspect of affirmative action, are 

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

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

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.

As reflected in the section immediately above, and incorporated herein by reference, the 

SECOP 6-80 Reasonable Accommodation Operating Procedures includes information 

regarding the process for requesting PAS, the process for determining whether such services 

are required, and the process for denying PAS requests when it would pose an undue 

hardship to the Agency. Similarly, medical information to include medical confidentiality and 

disclosure provisions and the responsibilities of the Disability Program Officer, the employee, 

and other relevant staff (e.g., supervisors, Reasonable Accommodation Coordinators) 

during the interactive process, as discussed in the Reasonable Accommodations Operating 

Procedures, apply to all requests for PAS. In FY 2022, the materials related to PAS were 

updated to explain eligibility requirements, types of PAS, how to request services, where to 

submit requests, and contact information. Program provisions for requesting and providing 

decisions on PAS reasonable accommodation requests are the same as the process for 

reasonable accommodation described in the new policy and related operating procedures 

and on the SEC public and internal websites. The SEC continues to use the SEC Form 2943 

Request for Personal Assistance Services to capture requests, and data obtained by this form 

will provide the RA Program critical information that may be used to understand program 

adoption and effectiveness going forward.

Continued on the next page
42 | AFFIRMATIVE ACTION PLAN

The SEC has a contract in place to support employees with targeted disabilities needing PAS 

services including reader and nurse services. In FY 2022, the SEC did not receive or process 

any new requests for PAS services. The Agency will continue to monitor its current contract 

for personal assistant and reader services to ensure the consistent delivery of healthcare 

services and will enhance the level of support as required.

During FY 2022, the Agency conducted general training for managers and supervisors on the 

Rehabilitation Act, their role and responsibilities in the reasonable accommodation process 

to include the interactive process provision, and how to respond appropriately when an 

individual places them on notice of the need for reasonable accommodation. New managers 

and supervisors are required to attend scheduled training to obtain in-depth overview for 

the provision of reasonable accommodation. This includes disseminating program-specific 

information during the New Employee Orientation and through the College of Leadership 

& Team Development Fundamentals of Human Resources Management course offered by 

the Agency’s learning office, SEC University. The CLTD 307 training provides real-time, 

scenario-based specific illustrations for supervisors and managers to heighten awareness 

about the RA Program, details general characteristics of available accommodations typically 

requested by employees with disabilities (e.g., PAS) and clarifies assumptions about roles and 

responsibilities with respect to the Agency’s reasonable accommodation program. Moreover, 

refresher training course offerings are readily available for employees and managers through 

the Agency’s SECU learning platform LEAP; the training provides an effective overview of 

the Rehabilitation Act, Americans with Disabilities Act, and the federal and SEC reasonable 

accommodation process.
FISCAL YEAR 2022 | 43

SECTION VI: EEO COMPLAINT AND FINDINGS DATA

EEO Complaint Data Involving Harassment

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

harassment, as compared to the government-wide average? 

Yes 0 No X N/A 0

2.During the last fiscal year, did any complaints alleging harassment based on disability status result 

in a finding of discrimination or a settlement agreement?

Yes 0 No X N/A 0

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

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

During FY 2022, the Agency did not have any findings of discrimination alleging harassment 

based on disability status.

EEO Complaint Data Involving Reasonable Accommodation

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

failure to provide a reasonable accommodation, as compared to the government-wide average? 

Yes 0 No X N/A 0

2.During the last fiscal year, did any complaints alleging failure to provide reasonable 

accommodation result in a finding of discrimination or a settlement agreement?

Yes X No 0 N/A 0

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

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

taken by the Agency.

During FY 2022, the Agency did not have any findings of discrimination involving the failure 

to provide reasonable accommodation.
44 | 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 identified any barriers (policies, procedures, and/or practices) that affect 

employment opportunities for PWD and/or PWTD?

Yes 0 No X

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

Yes 0 No 0 N/A X

3.Identify each trigger and plan to remove the barrier(s), including the identified barrier(s), 

objective(s), responsible official(s), planned activities, and, where applicable, accomplishments.

Not applicable for the FY 2022 reporting period.
FISCAL YEAR 2022 | 45

TABLE B1: TOTAL WORKFORCE—DISTRIBUTION BY DISABILITY [OPM FORM 256 SELF-IDENTIFICATION CODES] 

PAY PERIODS 202122 TO 202222 EMPLOYMENT TENURE TOTAL No Disability [05] Not Identified [01] Disability [02-03, 06-99]

Other PWD1Total PWDPWTDDevelopmental Disability [02]Traumatic Brain Injury [03]Deaf or Serious Difficulty Hearing [19]Blind or Serious Difficulty Seeing [20]Missing Extremities [31]Significant Mobility Impairment [40]Partial or Complete Paralysis [60]Epilepsy or Other Seizure Disorders [82]Intellectual Disability [90]Significant Psychiatric Disorder [91]Dwarfism [92]Significant Disfigurement [93]

TOTAL WORKFORCE

Prior FY

# 4,493 3,879 223 343 48 391 86 0 1 38 7 3 5 6 3 0 19 1 3

% 100% 86.33% 4.96% 7.63% 1.07% 8.70% 1.91% 0.00% 0.02% 0.85% 0.16% 0.07% 0.11% 0.13% 0.07% 0.00% 0.42% 0.02% 0.07%

Current FY

# 4,722 4,005 283 374 60 434 86 1 1 38 7 2 3 6 4 0 20 1 3

% 100% 84.82% 5.99% 7.92% 1.27% 9.19% 1.82% 0.02% 0.02% 0.80% 0.15% 0.04% 0.06% 0.13% 0.08% 0.00% 0.42% 0.02% 0.06%

Difference # 229 126 60 31 12 43 0 1 0 0 0 -1 -2 0 1 0 1 0 0

Ratio 

Change % 0.00% -1.51% 1.03% 0.29% 0.20% 0.49% -0.09% 0.02% 0.00% -0.05% -0.01% -0.03% -0.05% 0.00% 0.01% 0.00% 0.00% 0.00% -0.01%

Net Change % 5.10% 3.25% 26.91% 9.04% 25.00% 11.00% 0.00% 0.00% 0.00% 0.00% 0.00% -33.33% -40.00% 0.00% 33.33% 0.00% 5.26% 0.00% 0.00%

1 “Other PWD” include employees, who did not self-identify on SF-256, and who were coded on Veterans’ Preference for hiring as “CPS - preference based on a compensable service-connected disability of 30% or more” 

or were hired or converted into the competitive service under Schedule A(u). 

Note: Total calculations shown may not match that derived from detail data presented due to rounding.

Source: Datamart FPPS and EEO-AT 2.0 Analytic File for pay period 202222, downloaded on 11/16/2022
46 | EEO PROGRAM STATUS REPORT

TABLE B1: TOTAL WORKFORCE—DISTRIBUTION BY DISABILITY [OPM FORM 256 SELF-IDENTIFICATION CODES] 

PAY PERIODS 202122 TO 202222 continued EMPLOYMENT TENURE TOTAL No Disability [05] Not Identified [01] Disability [02-03, 06-99] Other PWD1 Total PWD

PWTDDevelopmental Disability [02]Traumatic Brain Injury [03]Deaf or Serious Difficulty Hearing [19]Blind or Serious Difficulty Seeing [20]Missing Extremities [31]Significant Mobility Impairment [40]Partial or Complete Paralysis [60]Epilepsy or Other Seizure Disorders [82]Intellectual Disability [90]Significant Psychiatric Disorder [91]Dwarfism [92]Significant Disfigurement [93]

PERMANENT

Prior FY

# 4,389 3,786 219 338 46 384 85 0 1 38 7 3 5 6 3 0 18 1 3

% 100% 86.26% 4.99% 7.70% 1.05% 8.75% 1.94% 0.00% 0.02% 0.87% 0.16% 0.07% 0.11% 0.14% 0.07% 0.00% 0.41% 0.02% 0.07%

Current FY

# 4,452 3,819 223 353 57 410 83 1 1 36 7 2 3 6 3 0 20 1 3

% 100% 85.78% 5.01% 7.93% 1.28% 9.21% 1.86% 0.02% 0.02% 0.81% 0.16% 0.04% 0.07% 0.13% 0.07% 0.00% 0.45% 0.02% 0.07%

Difference # 63 33 4 15 11 26 -2 1 0 -2 0 -1 -2 0 0 0 2 0 0

Ratio 

Change % 0.00% -0.48% 0.02% 0.23% 0.23% 0.46% -0.08% 0.02% 0.00% -0.06% 0.00% -0.03% -0.04% -0.01% 0.00% 0.00% 0.04% 0.00% 0.00%

Net Change % 1.44% 0.87% 1.83% 4.44% 23.91% 6.77% -2.35% 0.00% 0.00% -5.26% 0.00% -33.33% -40.00% 0.00% 0.00% 0.00% 11.11% 0.00% 0.00%

Federal 

Goal % 12.00% 2.00%

1 “Other PWD” include employees, who did not self-identify on SF-256, and who were coded on Veterans’ Preference for hiring as “CPS - preference based on a compensable service-connected disability of 30% or more” 

or were hired or converted into the competitive service under Schedule A(u). 

Note: Total calculations shown may not match that derived from detail data presented due to rounding.

Source: Datamart FPPS and EEO-AT 2.0 Analytic File for pay period 202222, downloaded on 11/16/2022
FISCAL YEAR 2022 | 47

TABLE B1: TOTAL WORKFORCE—DISTRIBUTION BY DISABILITY [OPM FORM 256 SELF-IDENTIFICATION CODES] 

PAY PERIODS 202122 TO 202222 continued EMPLOYMENT TENURE TOTAL No Disability [05] Not Identified [01] Disability [02-03, 06-99] Other PWD1 Total PWD

PWTDDevelopmental Disability [02]Traumatic Brain Injury [03]Deaf or Serious Difficulty Hearing [19]Blind or Serious Difficulty Seeing [20]Missing Extremities [31]Significant Mobility Impairment [40]Partial or Complete Paralysis [60]Epilepsy or Other Seizure Disorders [82]Intellectual Disability [90]Significant Psychiatric Disorder [91]Dwarfism [92]Significant Disfigurement [93]

TEMPORARY

Prior FY

# 104 93 4 5 2 7 1 0 0 0 0 0 0 0 0 0 1 0 0

% 100% 89.42% 3.85% 4.81% 1.92% 6.73% 0.96% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.96% 0.00% 0.00%

Current FY

# 270 186 60 21 3 24 3 0 0 2 0 0 0 0 1 0 0 0 0

% 100% 68.89% 22.22% 7.78% 1.11% 8.89% 1.11% 0.00% 0.00% 0.74% 0.00% 0.00% 0.00% 0.00% 0.37% 0.00% 0.00% 0.00% 0.00%

Difference # 166 93 56 16 1 17 2 0 0 2 0 0 0 0 1 0 -1 0 0

Ratio 

Change % 0.00% -20.53% 18.37% 2.97% -0.81% 2.16% 0.15% 0.00% 0.00% 0.74% 0.00% 0.00% 0.00% 0.00% 0.37% 0.00% -0.96% 0.00% 0.00%

Net Change % 159.62% 100% 1,400.00% 320.00% 50.00% 242.86% 200.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% -100.00% 0.00% 0.00%

1 “Other PWD” include employees, who did not self-identify on SF-256, and who were coded on Veterans’ Preference for hiring as “CPS - preference based on a compensable service-connected disability of 30% or more” 

or were hired or converted into the competitive service under Schedule A(u). 

Note: Total calculations shown may not match that derived from detail data presented due to rounding.

Source: Datamart FPPS and EEO-AT 2.0 Analytic File for pay period 202222, downloaded on 11/16/2022
48 | EEO PROGRAM STATUS REPORT

TABLE B1: TOTAL WORKFORCE—DISTRIBUTION BY DISABILITY [OPM FORM 256 SELF-IDENTIFICATION CODES] 

PAY PERIODS 202122 TO 202222 continued EMPLOYMENT TENURE TOTAL No Disability [05] Not Identified [01] Disability [02-03, 06-99] Other PWD1 Total PWD

PWTDDevelopmental Disability [02]Traumatic Brain Injury [03]Deaf or Serious Difficulty Hearing [19]Blind or Serious Difficulty Seeing [20]Missing Extremities [31]Significant Mobility Impairment [40]Partial or Complete Paralysis [60]Epilepsy or Other Seizure Disorders [82]Intellectual Disability [90]Significant Psychiatric Disorder [91]Dwarfism [92]Significant Disfigurement [93]

SCHEDULE A EMPLOYEES IN THE PERMANENT WORKFORCE2

Prior FY

# 7 0 0 7 0 7 3 0 0 1 0 0 0 0 0 0 2 0 0

% 100% 0.00% 0.00% 100% 0.00% 100% 42.86% 0.00% 0.00% 14.29% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 28.57% 0.00% 0.00%

Current FY

# 5 0 0 3 2 5 0 0 0 0 0 0 0 0 0 0 0 0 0

% 100% 0.00% 0.00% 60.00% 40.00% 100% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Difference # -2 0 0 -4 2 -2 -3 0 0 -1 0 0 0 0 0 0 -2 0 0

Ratio 

Change % 0.00% 0.00% 0.00% -40.00% 40.00% 0.00% -42.86% 0.00% 0.00% -14.29% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% -28.57% 0.00% 0.00%

Net Change % -28.57% 0.00% 0.00% -57.14% 0.00% -28.57% -100.00% 0.00% 0.00% -100.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% -100.00% 0.00% 0.00%

1 “Other PWD” include employees, who did not self-identify on SF-256, and who were coded on Veterans’ Preference for hiring as “CPS - preference based on a compensable service-connected disability of 30% or more” 

or were hired or converted into the competitive service under Schedule A(u). 

2 Schedule A Employees in the Permanent Workforce are those currently serving under an appointment type covered by Schedule A(u). Employees previously converted to the permanent workforce are not counted.

Note: Total calculations shown may not match that derived from detail data presented due to rounding.

Source: Datamart FPPS and EEO-AT 2.0 Analytic File for pay period 202222, downloaded on 11/16/2022

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EXCHANGE COMMISSION

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