U.S. SECURITIES AND 

EXCHANGE COMMISSION

FISCAL YEAR 2020

AFFIRMATIVE ACTION 

PLAN AND REPORT

For the Recruitment, Hiring, Advancement, and 

Retention of Persons With Disabilities

PREPARED BY THE OFFICE OF EQUAL EMPLOYMENT OPPORTUNITY
Some information referenced in this report has been redacted to protect employee privacy. 
FISCAL YEAR 2020 | i

Prepared by

THE OFFICE OF EQUAL EMPLOYMENT OPPORTUNITY

CONTENTS

SPECIAL PROGRAM PLAN FOR THE RECRUITMENT, HIRING, ADVANCEMENT,

AND RETENTION OF PERSONS WITH DISABILITIES 1

Section I: Efforts to Reach Regulatory Goals 1

Section II: Model Disability Program 5

Plan to Provide Sufficient & Competent Staffing for the Disability Program. . . . . . . . . .5

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) 11

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

Advancement Program Plan 15

Career Development Opportunities 16

Awards 22

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

Section V: Plan to Improve Retention of Persons with Disabilities . . . . . . . . . . . . . . .32

Voluntary and Involuntary Separations 32

Accessibility of Technology and Facilities 34

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 52
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FISCAL YEAR 2020 | 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), EEOC regulations (29 C.F.R.§ 1614.203(e)) and MD-715 require 

agencies to describe how their plan will improve the recruitment, hiring, advancement, and retention 

of applicants and employees with disabilities. All agencies, regardless of size, must complete this Part 

of the MD-715 report.

SECTION I: EFFORTS TO REACH REGULATORY GOALS

EEOC regulations (29 C.F.R.§ 1614.203(d)(7)) require agencies to establish specific numerical 

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

federal government.

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

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

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

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

The following background information is provided to assist the reader in reviewing 

this report:

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

persons with targeted disabilities (PWTD) employed, or seeking employment, with the 

Securities and Exchange Commission (SEC). As required by the U.S. Equal Employment 

Opportunity Commission (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 2020, the locality adjusted salary of a GS-11, step 1, in the Washington, DC area 

was $72,030.

Continued on the next page
2 | AFFIRMATIVE ACTION PLAN

n 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.

n As in prior years, and consistent with EEOC regulations, 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 C.F.R.§ 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.

n This action added 41 permanent employees to the PWD workforce data. The analyses 

described below reflect this change. Prior year data for such employees was updated for 

comparison.

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

for PWD participation; 53.33% 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, as 8.62% of employees in this cluster were PWD 

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

participation rate represents an increase of 2.27 percentage points since the end of FY 2015.

Between FY 2015 and FY 2020, the participation of PWD in the total workforce increased 

from 6.57% to 8.70%; participation increased in both the lower and higher salary clusters.
FISCAL YEAR 2020 | 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 X No 0

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

The SEC did not achieve the numerical goal established for PWTD in the lower salary cluster 

during FY 2020. In the lower salary cluster, none of the 16 permanent employees are PWTD.

The reason this trigger occurred in the lower salary cluster was because PWTD moved into 

the higher salary cluster in FY 2020. However, the numerical goal for PWTD among higher 

salaried employees remains six one hundredths of a percent below the goal: 1.94% of higher 

salaried employees are PWTD.

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

and/or recruiters.

In FY 2020, the SEC’s Office of Human Resources (OHR) developed an updated 2020 

– 2022 Recruitment Strategy (Recruitment Strategy) which describes the support and 

collaboration necessary from senior leadership, the Office of Equal Employment Opportunity 

(OEEO), and Office of Minority and Women Inclusion (OMWI) to recruit a diverse candidate 

base. The Recruitment Strategy specifically states that the SEC’s objective is to “Increase 

workforce representation for people with disabilities and people with targeted disabilities.” 

The Recruitment Strategy identified two goals towards this objective: (1) build a pipeline of 

qualified Schedule A applicants; and (2) improve veteran recruitment efforts. Specific strategies 

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

For particular hiring actions, OHR continues to address special hiring authorities, including 

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

numerical goals. A checklist is used by OHR Staffing specialists when vacant positions 

are identified to ensure hiring managers understand all 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.

More generally, the hiring goals for PWTD (i.e., 2% of the total workforce) are communicated to hiring managers during quarterly Office of Human Resources Steering Committee 

meetings. Additionally, metrics for disability hiring are published monthly and at the end of 

the year by the SEC’s Office of the Chief Operating Officer (OCOO). The overall percentage 

of employees who are PWTD is posted in the Diversity Dashboard sponsored by OMWI and 

the SEC’s Diversity Council.

Continued on the next page
4 | AFFIRMATIVE ACTION PLAN

To augment these information sources, OHR continues to provide 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.

Throughout FY 2020 and particularly during National Disability Employment Awareness 

Month in October 2019 and October 2020, the Agency hosted events that focused on 

inclusion of persons with a disability. As described later, these events were often sponsored 

and/or hosted by the Disability Interests Advisory Committee (DIAC). In opening and/or 

closing remarks, leaders noted the Agency’s goals for recruiting and hiring PWTD, frequently 

mentioning the high value such employees bring to the Agency’s mission.
FISCAL YEAR 2020 | 5

SECTION II: MODEL DISABILITY PROGRAM

Pursuant to 29 C.F.R.§1614.203(d)(1), agencies must ensure sufficient staff, training and resources 

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

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

disability hiring and advancement program the Agency has in place.

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 FTE to Special Programs 

classification, recruitment, and staffing in support of the disability program.

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 

13 0 0 Kai Petty, Lead HR Specialist

Office of Human Resources

pettyka@sec.gov

Answering questions from the public 

about hiring authorities that take 

disability into account

13 0 0 Kai Petty, Lead HR Specialist

Office of Human Resources

pettyka@sec.gov

Processing reasonable 

accommodation requests from 

applicants and employees

2 0 0 Dia Gonsalves, 

Disability Program Officer 

Office of Human Resources

gonsalvesd@sec.gov

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

Office of Information Technology

jonessh@sec.gov

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

Office of Support Operations (OSO)-Office 

of Building Operations (OBO) 

FerrariR@sec.gov

Jinhee Kim, RA, LEED AP, Architect,

OSO-OBO 

KimJin@sec.gov

Carla Hairston; NCIDQ, COEE, Space 

Management Specialist OSO-OBO

HairstonC@sec.gov

Special Emphasis Program for PWD 

and PWTD

4 0 0 Xiya Li, Branch Chief

Office of Human Resources

lixiy@sec.gov

Kai Petty, Lead HR Specialist

Office of Human Resources

pettyka@sec.gov
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

Staff received on-the-job training from the Disability Program Officer and the full-time 

Reasonable Accommodation Coordinator and periodically attended training programs 

and reviewed recent case law to stay current with developments in this area. The Disability 

Program Officer completed courses specific to recruiting, accommodating disabilities, 

hiring, and retaining PWD and PWTD via OPM’s HR University and the SEC’s Learning 

Management System, LEAP, in addition to the general training received.

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

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

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

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

practices in the future.

Changes are planned in line with implementation of requirements and recommendations 

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

specific training for both HR specialists and disability program staff on related policy and 

procedures post implementation.

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 2020 | 7

SECTION III: PLAN TO RECRUIT AND HIRE INDIVIDUALS WITH 

DISABILITIES

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

recruitment and hiring of individuals with disabilities. The questions below are designed to identify 

outcomes of the Agency’s recruitment program plan for PWD and PWTD.

Plan to Identify Job Applicants with Disabilities

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

including individuals with targeted disabilities.

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

applicant pools. Since focusing on these efforts under OHR’s 2018 – 2019 Recruitment 

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

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

an employer of choice.

Despite the mandatory telework posture due to the COVID-19 pandemic, the Agency 

maintained a strong recruitment presence in FY 2020, and attended 15 in-person and virtual 

career fairs and events supporting efforts in building pipelines for future employment.

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

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

for persons with disabilities. This streamlined approach required all external hiring requests 

be 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 will continue to leverage the DIAC for recruitment resources 

and assistance. Further, OHR will continue to retain and review applications from people 

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

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.
8 | AFFIRMATIVE ACTION PLAN

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

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

permanent workforce.

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

other hiring authorities that take disability into account.

The SPPC receives notifications and newsletters from the following groups and transmits 

information to OHR staff engaged in recruiting:

n EARN—Employer Assistance Resource Network: askearn.org

n JAN—Job Accommodation Network: askjan.org

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

dol.gov/odep/

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

operation-warfighter/

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

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

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

hiring 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 2020 | 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 Special Programs Manager will 

proactively contact the prospective applicant if the individual did not submit the 

required documentation. The application will not be processed until the appropriate 

documentation is received.

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

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

and abilities identified on the applicant’s resume. 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. When a SARF is received by OHR, the Special Programs Manager 

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

candidates to hiring managers. In some cases, the Special Programs Manager conducts 

a one-on-one consultation with the hiring manager to discuss the 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 January 2017.

The Agency’s administrative regulations are available upon request.

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

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

If “no”, describe the Agency’s plan to provide this training.

Yes X No 0 N/A 0

In FY 2020, periodic training occurred with each hiring manager who requested to fill a 

position. The hiring checklist used by the staffing specialists contains a section on Schedule 

A that is discussed in-depth during the one-on-one hiring conversation between the staffing 

specialist and the hiring manager. The specialist trains the hiring manager on the various procedures of the Schedule A hiring process and offers it as a course of action where applicable.

In FY 2020, the Agency successfully hired nine veterans with a service-connected disability 

directly into the competitive service. DIAC and the Disability Program Office 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.
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 Special Programs Manager continued to maintain established partnerships with 

organizations that assist PWD and PWTD in securing and maintaining employment. The 

Special Programs Manager 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 Program (OWF) during FY 2020. 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 SEC plans to finalize 

program policies and procedures for implementation agency-wide in FY 2021.

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

and the Veterans Committee, members of 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, the National Treasury Employees Union (NTEU), OMWI, 

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. The DIAC and OHR continue to 

work collaboratively with SEC program offices and employee affinity groups to improve 

workplace diversity for the PWD and PWTD communities.
FISCAL YEAR 2020 | 11

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 2020, the Agency hired 256 permanent employees, of which PWD and PWTD 

represented 7.03% and 0.78%, respectively, of all new hires in FY 2020. As such, the 

Agency did not achieve the numerical goals of 2% participation of PWTD and 12% 

participation of PWD among permanent new hires.

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

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

the triggers below.

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

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

In FY 2020, the SEC hired and onboarded a total of 256 permanent staff employees.

Among these newly-hired staff members were 195 persons in MCO positions as follows: 

123 attorneys; 19 accountants; 22 securities compliance examiners; 25 IT management 

specialists; and 6 economists. Seven of those 195 (3.59%) of newly-onboarded 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 onboarded. 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. In addition, in FY 

2020, 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.Continued on the next page
12 | AFFIRMATIVE ACTION PLAN

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

management specialists, and economists as follows: 

n PWD represent 3.25% of the 123 newly-hired attorneys—below their participation rate 

of 5.16% in the qualified applicant pool (QAP).

n For IT management, 4.00% of new hires were PWD, below their representation in the 

QAP (13.30%).

n No PWD were hired for any of the six economist positions although 28 PWD were in 

the QAP (5.30%).

n On the other hand, PWD represent 5.26% of newly-hired accountants, above their 

participation rate in the qualified applicant pool (2.37%).

n Triggers were also observed for PWTD in the attorney, IT management, accountant, 

and economist occupations.

n For attorneys, the QAP for PWTD was 1.19%; no PWTD (0.00%) were hired as 

permanent staff attorneys.

n Forty-six PWTD were in the QAP (2.93%) for IT management, and no PWTD were 

hired (0.00%).

n Fourteen PWTD were in the QAP (2.65%) for economist positions, and no PWTD 

were hired.

n One PWTD was found in the QAP for accountants (0.34%), and no PWTD were hired.

n For securities compliance examiner vacancies posted in FY 2020, no PWD or PWTD 

were found in the QAP. Thus, none were hired.
FISCAL YEAR 2020 | 13

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 2020 data, 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 four of the SEC’s MCOs, i.e., attorney, accountant, securities compliance 

examiner, and IT management. Differences were also identified between the RAP and QAP 

for PWTD within the internal competitive promotion data for the MCOs of attorney, 

accountant, securities compliance examiner, and IT management.

The RAP was 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 information technology management 

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

occupation, the RAP included all employees in the 0110 series.

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

applicants for both PWD and PWTD. The RAP for PWD was 5.36%, and PWD represented 

2.75% of the qualified internal applicants. The RAP for PWTD was 1.10%, and PWTD 

were 0.00% of the qualified internal applicants for attorneys.

For accountants, the Agency did not observe a difference between the RAP and qualified 

internal applicants among PWD or PWTD.

For securities compliance examiners, the Agency observed a difference between the RAP and 

qualified internal applicants for PWD, but not for PWTD. The RAP for PWD was 7.04%, 

and PWD represented 3.51% of the qualified internal applicants.

For IT management, the Agency did not observe a difference between the RAP and qualified 

internal applicants for PWD or PWTD.

For economists, the Agency observed differences between the RAP and qualified internal 

applicants for PWD and PWTD. The RAP was 2.53% PWD, and there were no PWD 

among qualified internal applicants. The RAP for PWTD was 1.27%, and there were no 

PWTD among qualified internal applicants.
14 | AFFIRMATIVE ACTION PLAN

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 IT management occupations, but no 

differences were observed for selections across the attorney, accountant, securities compliance 

examiner, or economist occupations. Among IT management specialists, the QAP for PWD 

was 2.23%, and no PWD were represented among selections.

The selection data also indicate a difference for PWTD in the accountant and IT 

management occupations, but no differences were observed for selections across the 

attorney, securities compliance examiner, or economist occupations. Among IT management 

specialists, the QAP for PWTD was 14.76% PWD, and no PWTD were selected. Among 

accountants, the QAP for PWTD was 4.88%, and no PWTD were selected.
FISCAL YEAR 2020 | 15

SECTION IV: PLAN TO ENSURE ADVANCEMENT OPPORTUNITIES FOR 

EMPLOYEES WITH DISABILITIES 

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

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

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

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

programs designed to ensure advancement opportunities for employees with disabilities.

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.

n 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.

n 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.

n 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.

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

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

postings or support available to the workforce. These more targeted communications 

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

processes for requesting participation or enrollment.

Continued on the next page
16 | AFFIRMATIVE ACTION PLAN

In addition to these ongoing efforts, in FY 2020, the SEC made steady progress to address 

recommendations by the EEOC (through its technical assistance review) to improve the 

SEC’s EEO and Disability Programs. These improvements, which were commended by 

the EEOC, included: issuing compliant reasonable accommodation procedures; posting 

reasonable accommodation procedures on the SEC’s external website; posting personal 

assistance services procedures on the SEC’s external website; and posting Section 504 and 

508 of the Rehabilitation Act and Architectural Barriers Act notices on the SEC’s external 

website. The SEC continues to focus on enhancements with respect to advancement 

opportunities for persons with disabilities. On February 12, 2021, the SEC submitted its 

compliance report to the EEOC related to the ongoing deficiencies.

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, 

etc.), as well as in leadership development, to SEC senior leaders and non-supervisory staff 

alike. Among the variety of learning and development offerings, the SEC offers the five career 

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

captured along with other training program data in Section IV below.

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

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

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

participate in this leadership development program. Program participants from across 

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

of senior leadership success while maintaining authenticity and balance.

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

strengthens the leadership skills of experienced federal employees through a combination 

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

projects, executive coaching, and government-wide networking. This program is offered 

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

levels. SEC’s EIG Fellows attend facilitated sessions at SEC Headquarters to share 

what they are learning and to explore how this information can be applied to improve 

organizational performance, workplace relationships, and productivity.

Continued on the next page
FISCAL YEAR 2020 | 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; understanding government policy, process, and 

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

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 formal 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 agencywide mentoring program. In FY 2020, 71 SEC employees 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: Managing Yourself in 

the Virtual Environment and Building Effective Relationship Networks (this latter course 

is designed to enhance relationship-building and maintain effective relationships for SEC 

leaders at all levels).

In FY 2020, the SEC initiated the development of the Senior Officer (SO) Cohort Program, 

which places an agency-wide emphasis on ensuring that SO applicants across the Agency 

have the leadership skills needed to excel in an SO position. The program will improve the 

process for identifying and selecting future leaders by creating a centralized, agency-wide 

selection program that initially screens candidates on essential leadership competencies in 

a fair and legally-compliant manner. OHR’s Human Capital Strategy Group is developing

Continued on the next page
18 | AFFIRMATIVE ACTION PLAN

the SO Cohort Program with a high level of rigor to ensure it provides a standardized, fair, 

and legally-compliant approach for selecting SOs. Special advisors from OEEO and OMWI 

provided technical assistance so that program materials and processes emphasize and support 

fairness, diversity, and inclusion. In FY 2021 OHR will launch a communication campaign 

to educate SEC employees on the program and create awareness, specifically emphasizing 

that the program offers an inclusive, open opportunity to advance for those employees 

willing to self-develop in the leadership skills targeted by this program.

In FY 2020, the Agency launched the second offering of the SEC Mentoring Program 

which was advertised SEC wide. On September 23, 2019, 103 employees registered interest 

in participating in the second mentoring cohort. On a first-come, first-serve basis, 30 

participants were accepted into the Mentoring Program and matched with volunteer mentors 

with deep technical expertise and/or leadership experience. The SEC held an orientation 

session for both mentors and mentees on October 28 and 29, 2019. Thereafter, the SEC held 

formal events facilitated by the Office of the Chief Operating Officer and SEC University 

experts each quarter throughout FY 2020 (these career development events were offered 

virtually once SEC personnel transitioned to full-time telework due to the pandemic) to 

help guide the mentoring relationship toward success. The second cohort of the Mentoring 

Program celebrated its Capstone event in June 2020.

In FY 2020, the EEOC conducted a technical evaluation of the SEC’s EEO and 

Disability Programs, and recommended, inter alia, that the SEC develop and implement 

a comprehensive plan to support employees with disabilities in career development and 

advancement opportunities, pursuant to 29 C.F.R.§ 1614.203(d)(1)(iii). Specifically, the 

EEOC recommended that the SEC ensure that a number of participants in its mentoring 

program be PWD and PWTD.

In response to the EEOC’s feedback, the SEC committed to reserving a number of slots in the 

next cycle of the Mentoring Program as it transitions to a permanent program (with a target 

set for the 2022 mentee cohort). In addition, the SEC recognized that ensuring advancement 

opportunities for PWD and PWTD remains an area of opportunity and has increased efforts 

to ensure full compliance with this regulation.

In FY 2021, the SEC is launching a cross-office working group comprised of subject 

matter experts in the Offices of the Chief Operating Officer, Human Resources, Equal 

Employment Opportunity, and Minority and Women Inclusion which will consult with 

the Disability Interests Advisory Committee and other disability inclusion champions to 

drive a comprehensive plan related to advancement opportunities for PWD and PWTD.

Enhanced marketing and possible tailoring of existing and developing SEC advancementrelated programs and creating new programs will be collectively explored. Participation 

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

provided below.
FISCAL YEAR 2020 | 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 Opportunities1

Total Participants PWD PWTD

Applicants 

(#)

Selectees 

(#)

Applicants 

(%)

Selectees 

(%)

Applicants 

(%)

Selectees 

(%)

Internship Programs 526 [Redacted 

to protect 

privacy.] 

7.79% 33.33% 2.85% 33.33%

Fellowship Programs 165 17 0.61% 0.00% 0.61% 0.00%

Mentoring Programs 93 30 13.98% 13.33% 3.23% 3.33%

Coaching Programs NA NA NA NA NA NA

Training Programs 727 727 11.00% 11.00% 2.06% 2.06%

Detail Programs 65 13 6.15% 0.00% 1.54% 0.00%

Other Career Development Programs NA NA NA NA NA NA

Notes to help the reader understand the data above:

1 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 2020. 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.

 The SEC does not currently have “Other Career Development Programs.” 

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 in Section IV above, data on the 

participation of PWD and PWTD in applications and selections for various programs 

were reviewed.

For the internship program, 7.79% of applicants were PWD and PWD were 33.33% of 

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

of PWD among applicants, there was no trigger for internships.

Continued on the next page
20 | AFFIRMATIVE ACTION PLAN

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 (8.70%). PWD represent 13.98% of those employees who expressed 

interest in the Mentoring Program and 13.33% of those selected for mentoring. The 

participation rate of PWD among those selected to participate in the Mentoring Program 

for FY 2020 almost approximates those that express interest in the training program.

Aggregate PWD participation in training programs approved on standard form 182 

through the Agency’s learning management system, LEAP, exceeds their participation on 

rolls: 11.00% of training requiring separate approval on SF-182 were completed by PWD, 

compared to 8.70% of permanent employees who are PWD. No trigger was found for 

applications or selections.

Data about detailed employees show evidence of differences disadvantaging PWD among 

those who applied for details and among those selected. While 8.70% of permanent 

staff were PWD, 6.15% of applicants for temporary promotion were PWD. None of the 

applicants were selected.

For other Career Development Opportunities, demographic data specific to disability status 

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

focus communication efforts to encourage participation of PWD and PWTD as described 

above, supra.
FISCAL YEAR 2020 | 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 in Section IV 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.

Similar to the PWD data for the Agency’s economist and accountant Fellows programs combined, the Agency noted a difference between the participation of PWTD among (external) 

applicants for these programs and eventual selections for positions. While 0.61% of applicants were PWTD, none of the Fellows hired (0.00%) were PWTD.

For the internship program, 2.85% of applicants were PWTD, and PWTD were 33.33% of 

selections. As selections had a substantially higher percentage of PWTD than the percentage 

of PWTD among applicants, there was no trigger for internships.

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

(3.23%) exceeded the percentage of PWTD among permanent staff (1.91%). Thus, no trigger was found among applicants. The participation of PWTD among employees selected for 

mentoring in FY 2020 (3.33%) approximated 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 program.

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

approved on SF-182 through LEAP at rates slightly above their participation on rolls; 2.06% 

of training opportunities requiring special approval were completed by PWTD, compared to 

1.91% of PWTD 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 1.54% of 

applicants for temporary promotion were PWTD, PWTD represent 1.91% of permanent 

staff employees. No PWTD 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 did not find a trigger in the distribution of time-off awards at any level (less than 

10 hours or 10 – 40 hours).

For cash awards, the Agency found a trigger for PWD for cash awards of $2,000 – $2,999.

There were no triggers for PWD at any other cash award level.

Continued on the next page
FISCAL YEAR 2020 | 23

For cash awards at the $2,000 – $2,999 level, the inclusion rate for PWD was 7.10%, 

and the inclusion rate for people with no disability was 8.74%.

The Agency found triggers for PWTD at the cash award levels of $500 and under, 

$1,000 – $1,999, and $2,000 – $2,999.

For cash awards of $500 and under, the inclusion rate for PWTD was 16.47%, and the 

inclusion rate for people with no targeted disability was 18.75%. For cash awards of 

$1,000 – $1,999, the inclusion rate for PWTD was 28.24%, and the inclusion rate for 

people with no targeted disability was 35.28%. For cash awards of $2,000 – $2,999, the 

inclusion rate for PWTD was 5.88%, and the inclusion rate for people with no targeted 

disability was 8.66%.

The Agency has researched the observed differences in the distribution of discretionary 

awards, made recommendations, and is actively monitoring them 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

In FY 2020, the Agency did not offer other formal recognition programs for which 

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

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

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

Awards program or any of the several honors programs offered by Division Directors.
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 0 No X

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 0 No X

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

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

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

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

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

though the actual RAPs for the individual SK-levels differ.

We reviewed FY 2020 data to assess whether triggers exist with regard to promotions to 

senior grade levels. Of 1,952 qualified internal applications for senior grade level positions, 

363 (18.60%) were submitted by PWD. There was a difference between qualified applicants 

(5.81%) and the RAP (7.00%) at the SES equivalent level. There were no triggers identified 

among qualified internal applicants to the GS-15, GS-14, or GS-13 equivalent senior grades.

Among internal selections, a difference was observed at the GS-14 equivalent level, but not 

the SES, GS-15 or GS-13 equivalent levels. Of the 106 selections for internal promotions 

to senior grade levels, 13.21% were PWD, which is lower than their availability in the 

QAP at 18.60%. This difference was primarily driven by the GS-14 equivalent level. PWD 

represented 15.91% of selections at the GS-14 equivalent level, while they were 21.97% of 

qualified applicants.
FISCAL YEAR 2020 | 25

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 0 No X

c. Grade GS-14

Qualified Internal Applicants (PWTD) Yes 0 No X

Internal Selections (PWTD) Yes 0 No X

d. Grade GS-13

Qualified Internal Applicants (PWTD) Yes X No 0

Internal Selections (PWTD) Yes X No 0

Applying the same comparisons to PWTD described previously, the Agency presents 

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

1,952 qualified internal applications for senior grade level positions, 50 (2.56%) were 

submitted by PWTD, and 3.77% of selections were PWTD.

Differences were observed in the qualified applicant pools for the SES and GS-13 equivalent 

senior grade levels and among selectees at the GS-13 equivalent level. The following presents 

data for each grade level.

At the SES equivalent, SO, grade level, the RAP was 1.44% PWTD, and the participation 

among qualified internal applicants of PWTD was 0.00%. No selections for SO positions 

were PWTD as there were no PWTD in the qualified applicant pool.

At the GS-15 equivalent level, qualified internal applicants (1.87%) exceeded the RAP (1.43%).

At this level, selections among PWTD (2.27%) exceeded qualified applicants (1.87%).

At the GS-14 equivalent level, the RAP was 1.55% while 2.58% of the qualified internal 

applicants were PWTD. Selections among PWTD (6.82%) exceeded the qualified applicant 

pool (2.58%).

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

qualified internal applicants. The RAP was 5.63%, and the participation of PWTD among 

qualified internal applicants was 4.32%. None of the PWTD qualified internal applicants 

were selected.
26 | AFFIRMATIVE ACTION PLAN

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 0 No X

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

The Agency presents information on trigger identification for PWD new hires to senior 

grade levels. Among the 256 newly-hired staff members in FY 2020 were 207 persons hired 

into senior grade level positions: five SOs, 11 into GS-15 equivalent positions, 105 into 

GS-14 equivalent positions, and 86 into GS-13 equivalent positions. Sixteen of those 207 

(7.73%) newly-hired permanent staff in senior grade levels identified as PWD. The following 

evaluates participation of PWD in each senior grade equivalent level.

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, and new hires onboarded 

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 who were onboarded from open, continuous postings.

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

onboarded as new hires. Triggers comparing the composition of PWD and PWTD (see 

Question 5 immediately below) in applicant flow versus new hire data should be interpreted 

with these differences in mind.

At the SES equivalent level, the QAP was 1.67% PWD, and none of the five newly-hired 

permanent SOs identified as PWD.

At the GS-15 equivalent level, the QAP was 10.94% PWD, and 9.09% of the 11 newlyhired permanent staff for those positions identified as PWD.

At the GS-14 equivalent levels, the QAP was 8.76% PWD, and 9.52% of the 105 newlyhired permanent staff were PWD.

At the GS-13 equivalent level, the QAP was 11.69% PWD, while 5.81% of the 86 new hires 

to GS-13 equivalent positions identified as PWD.
FISCAL YEAR 2020 | 27

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

The Agency presents information on trigger identification for PWTD new hires to senior grade 

levels. The participation rate for PWTD was 0.97%.

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

hires at the GS-13, GS-14, and GS-15 equivalent levels. The Agency did not have a trigger at 

the SES equivalent level because no PWTD were found among the qualified applicants for SES/

SO positions, thus no trigger was identified at that level.

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

At the GS-15 equivalent level, the QAP was 2.13%; no newly-hired staff members were 

PWTD (0.00%).

At the GS-14 equivalent level, the QAP was 2.98% PWTD; 1.90% of the newly-hired GS-14 

equivalent staff were PWTD.

At the GS-13 equivalent level, the QAP was 3.96% PWTD, no newly-hired staff members 

were PWTD (0.00%).
28 | AFFIRMATIVE ACTION PLAN

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 0 No X

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 2020 data are relevant for assessing whether triggers exist with regard to promotions to 

supervisory or managerial positions. Among the promotions in FY 2020 were 58 persons 

promoted to a leadership position at the supervisor, manager, or executive level: 10 SOs, 

22 managers, and 26 supervisors. The following evaluates participation of PWD in each 

leadership level.

For the executive, manager, and supervisor levels, there were no differences to the 

disadvantage of PWD in the qualified internal applicant pool compared to the RAP.

For executives, the Agency did not have a trigger involving internal selections. The qualified 

applicant pool was 4.46% PWD, and selections were 10.00% PWD.

For managers, the Agency had a trigger involving internal selections. The qualified applicant 

pool was 10.13%, and selections were 4.55% PWD.

For supervisors, the Agency also had a trigger involving internal selections. The qualified 

applicant pool was 14.45%, and selections were 11.54% PWD.
FISCAL YEAR 2020 | 29

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 X No 0

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 0 No X

The Agency presents information on trigger identification for PWTD internal promotions 

to supervisory positions. None of the 38 promotions were PWTD. The following evaluates 

participation of PWTD in each leadership level.

For Executives, there was a difference between the participation of PWTD in the qualified 

internal applicant pool compared to the RAP. There were no qualified applicants and the 

relevant applicant pool was 1.54% PWTD. There was no trigger for selections. No PWTD 

were selected, as there were no qualified applicants.

For Managers, there was no difference between the participation of PWTD in the qualified 

internal applicant pool compared to the RAP. The RAP was 1.13% PWTD and 1.27% 

of the qualified internal applicants were PWTD. The Agency identified a difference in 

participation for PWTD involving internal selections. No PWTD were selected, while PWTD 

were 1.27% of the qualified applicant pool.

For Supervisors, no triggers were identified among qualified internal applicants or selections.
30 | AFFIRMATIVE ACTION PLAN

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 X No 0

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

The Agency presents information on trigger identification for PWD new hires into leadership 

positions, after assessing whether differences exist with regard to applicants and new hires in 

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

A difference was found in FY 2020 new hire data for PWD at the executive and manager 

levels. No trigger was found at the supervisor level.

Among the 256 newly-hired staff members in FY 2020 were 18 persons hired into leadership 

positions: five SOs, two SK-17 managers, and 11 supervisors below SK-17. [Redacted to 

protect privacy.] 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 1.00% PWD, and none of the five newly-hired permanent 

executives identified as PWD.

For managers, the QAP was 4.92% PWD, and neither of the two newly-hired managers 

identified as PWD.

For supervisors, the QAP was 12.78%, and 18.18% PWD were newly-hired into [Redacted 

to protect privacy.] supervisory positions.
FISCAL YEAR 2020 | 31

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

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

in the text box.

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

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

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

No differences were found in the new hire data for PWTD at the executive or manager 

levels, but a difference was found at the supervisor level.

For executives, no PWTD (0.00%) were found in the qualified applicant pool, so there was 

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

executive positions in FY 2020.

For managers, no PWTD (0.00%) were found in the qualified applicant pool, so there was 

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

manager positions in FY 2020.

None of the 11 (0.00%) newly-hired permanent staff in supervisor positions identified as 

PWTD. The QAP was 1.94% [Redacted to protect privacy.].
32 | AFFIRMATIVE ACTION PLAN

SECTION V: PLAN TO IMPROVE RETENTION OF PERSONS 

WITH DISABILITIES 

To be a model employer for persons with disabilities, agencies must have policies and programs in 

place to retain employees with disabilities. In this section, agencies should: (1) analyze workforce 

separation data to identify barriers to retaining employees with disabilities; (2) describe efforts to 

ensure accessibility of technology and facilities; and (3) provide information on the reasonable 

accommodation program and workplace personal assistance services.

Voluntary and Involuntary Separations

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

into the competitive service after two years of satisfactory service (5 C.F.R.§ 213.3102(u)(6)(i))? 

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

Yes X No 0 N/A 0

The 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 2020, [Redacted to protect privacy.] employees were 

converted to the competitive service under the Schedule A hiring authority within two years 

of their most recent Schedule A appointment. [Redacted to protect privacy.] employees are 

currently serving on their most recent Schedule A appointments that were processed within 

the past two years. [Redacted to protect privacy.] employees hired in FY 2019 are serving on 

an initial Schedule A appointment, and [Redacted to protect privacy.] staff members were 

newly-hired under Schedule A during FY 2020. 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 

2020, confirms that all were converted to the competitive service within two years of their 

most recent Schedule A appointment.
FISCAL YEAR 2020 | 33

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 or involuntary separations in FY 2020. The 

inclusion rate on voluntary separations was lower for PWD (3.07%) than for persons with 

no disability (3.68%). Likewise, the inclusion rate on involuntary separations was lower for 

PWD (0.00%) than for persons with no disability (0.05%).

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 

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 or involuntary separations in FY 2020. The 

inclusion rate on voluntary separations was lower for PWTD (2.33%) than for persons with 

no disability (3.68%). Likewise, the inclusion rate on involuntary separations was lower for 

PWTD (0.00%) than for persons with no disability (0.05%).
34 | AFFIRMATIVE ACTION PLAN

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

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

Not applicable. The Agency did not have a trigger with respect to separations for PWD or 

PWTD in FY 2020.

Accessibility of Technology and Facilities

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

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

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

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

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

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

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

description of how to file a complaint.

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

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

resource. Such information can be gathered from a variety of sources, including 17 C.F.R.

§§ 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.

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.

Continued on the next page
FISCAL YEAR 2020 | 35

The SEC recently updated the Accessibility page of SEC.gov with applicable complaint-filing 

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

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

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

technology to SEC, contact information and specific complaint processes for filing a formal 

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

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

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

be finalized in FY 2021, and will be posted on SEC.gov thereafter.

Every SEC vacancy announcement posted to USAJOBS includes information about obtaining 

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

Programs Manager serving as the Selective Placement Program Coordinator is posted on 

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

hiring PWD (SEC.gov/ohr/sec-disability-program-page.html). This page includes a link to 

an online form (SEC.gov/forms/ada4applicants#no-back) for requesting accommodations 

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

contacting the Disability Program at the SEC.

The SEC also currently posts information on how to 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.
36 | AFFIRMATIVE ACTION PLAN

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 Information 

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

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

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

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

completion of testing, project teams are 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. Further, all Agency Contracting Officer 

Representatives (CORs) were required to complete Section 508 training in FY 2020.

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.
FISCAL YEAR 2020 | 37

Reasonable Accommodation Program

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

make available to all job applicants and employees, reasonable accommodation procedures.

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

accommodations during the reporting period. (Please do not include previously approved 

requests with repetitive accommodations, such as interpreting services.)

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

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

the provision of adjustable height tables (AHTs), in FY 2020, 74% of initial requests for 

accommodation were processed within 20 business days.

The timeframe for processing RA requests in FY 2020 was affected by a number of 

organizational, environmental, and business process changes that impacted the Agency’s ability 

to meet timeliness goal. Organizationally, the Agency maintained sufficient funding to acquire 

and implement approved accommodations for individuals with disabilities. At the end of FY 

2019, the Agency experienced significant attrition of two key staff members with familiarity 

with the functions relative to processing requests for reasonable accommodation during this 

period. Since then, the Agency has ensued rigorous staffing activities through competitive 

staffing and detail opportunity procedures to regain adequate staffing levels to effectively 

administer the reasonable accommodation program. In FY 2020, the program hired additional 

staff to administer the RA program and respond to the RA program requests increasing its 

staffing level by one full-time equivalent (FTE) which include two federal employees (one 

staffer was on detail to another office from June to December 2020), and one contractor who 

provides administrative support for the RA program, along with the Disability Program Officer 

who also manages a diverse portfolio of other HR programs.

At the start of FY 2020, the Agency instituted several initiatives to mitigate barriers impacting 

reasonable accommodation timeliness. The limited production of certain ergonomic items 

(e.g., AHT desk-mounted solace equipment) resulted in extended lead time and required that 

the Agency temporarily change its vendor to meet the Agency’s requirements. Also, the local 

distributor for the previous vendor servicing the entire Agency changed and manufacturer 

response time for the delivery and installation of equipment was impacted. In March 2020, as 

a result of the COVID-19 pandemic, the Agency instituted mandatory telework agency-wide, 

with limited exceptions. This prevented the Agency from delivering and installing ergonomic 

equipment that was purchased prior to the mandatory telework posture.

Continued on the next page
38 | AFFIRMATIVE ACTION PLAN

Notwithstanding this, the SEC continued to provide reasonable accommodations to 

include PAS reader and personal assistant services, assistive technology and equipment, and 

ergonomic equipment to PWDs and PWTDs during the current mandatory telework status.

The Agency provided non-installation equipment (e.g., task chairs, monitors, keyboards, 

etc.) to employees’ residences. Additionally, the Agency provided employees with a onetime stipend of up to $335.00 to help defray the costs of certain IT and telework expenses 

incurred during the mandatory telework posture. Moreover, the Agency established interim 

workplace flexibilities with additional work scheduling options to assist employees with 

balancing work and personal obligations during the COVID-19 pandemic.

In FY 2020, the SEC initiated the procurement process to establish new contract vehicles 

via five-year blanket purchase agreements (BPA) for its Sign Language Interpretation and 

Ergonomic Furniture and Equipment Services. Implementation of the new vendor for the 

Sign Language Interpretation Services remains underway and is scheduled for FY 2021.

A new BPA for the ergonomic program was established in FY 2020 and will provide 

more efficient and timely acquisition of vendor services and products. Under the previous 

contractual arrangement, the vendor typically required a 4 – 6 week lead time for the 

manufacturing of the product. After this time, the Agency works with the vendor to schedule 

coordinated delivery and installation of the product. This typically requires an additional 

1 – 2 weeks. Under the new contract, the vendor typically requires a 4-week lead time which 

includes delivery. With this arrangement, the Agency anticipates a 2-week improvement 

in its ability to implement the ergonomic furniture and equipment. Furthermore, items 

will continue to be shipped to the manufacturer installer’s warehouse and delivery and 

installation will be scheduled by the Agency. Therefore, onsite storage of equipment in 

Regional Offices is a non-issue. For Agency Headquarters offices, ergonomic furniture and 

equipment will continue to be stocked in inventory.

The SEC initiated frequent consultations with medical experts at the Federal Occupational 

and Health (FOH) to complete medical reviews of employees with a wide range of 

conditions in an effort to improve their ability to do their jobs and maintain a high level of 

productivity. In FY 2020, requests to FOH were processed in 24.3 days on average. While 

timeliness of FOH opinions improved by 13.1% in FY 2020, environmental factors further 

impacted the Agency’s overall timeliness. Specifically, the impact of the ongoing COVID-19 

pandemic affected the procurement process for the purchase of items for employees with 

disabilities and delayed scheduled installation of assistive technology and ergonomic 

equipment throughout the SEC.

Continued on the next page
FISCAL YEAR 2020 | 39

The Agency will continue ongoing efforts to procure a new HR service delivery platform 

to automate the reasonable accommodation program case management process in FY 

2021. The implementation of the 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 address the timeliness standards set by the 

new SEC policy which increased the processing timeframe to 45 business days, absent undue 

hardship. Multiple competing priorities delayed the implementation of the case management 

system in FY 2020. During Q1 FY 2020, the Agency met with a potential vendor that 

included a system demonstration of a Commercial Off-The-Shelf (COTS) product to identify 

a solution that complements the Agency’s reasonable accommodation program process and 

requirements in terms of system functionality, adaptability, and accessibility. To advance RA 

program maturity and success, system requirements analyses are expected to be completed 

in calendar year 2021 and full design and implementation of the system, which includes 

finalizing RA electronic system requirements, conducting user acceptance testing, and 

training the SEC workforce on the new interactive processing portal is expected in calendar 

year 2022.

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

in FY 2020 for capturing data related to processing RA requests. The time frame for processing initial requests for RA during FY 2020 was 21.5 days; RA requests, excluding AHT were 

processed in 26.7 days; and requests for AHTs were processed in 11.5 days, respectively.

2.Describe the effectiveness of the policies, procedures, or practices to implement the Agency’s 

reasonable accommodation program. Some examples of an effective program include timely 

processing requests, timely providing approved accommodations, conducting training for 

managers and supervisors, and monitoring accommodation requests for trends.

The interactive portal, AskHR, on the Agency’s intranet provides employees with 

information about reasonable accommodation and the processes for making requests. To 

support employees in making such a request, the Agency will replace the resource guide 

Disability Accommodation Procedures with a new RA policy and operational procedures in 

FY 2021. This new guidance will be available on the interactive portal for everyone involved 

in the accommodations process. It explains how persons with disabilities should request 

accommodations, how requests are processed, and, as applicable, how requestors may seek 

review of decisions where a request has been denied.

Continued on the next page
40 | AFFIRMATIVE ACTION PLAN

The SEC provides temporary accommodations to employees with short-term medical 

conditions even when the condition does not constitute a covered disability when supervisory 

officials and the Disability Program Office decide that it is appropriate to do so. In FY 2020, 

the SEC processed 51 Temporary Medical Telework (TMT) requests, processed 104 RA 

requests, of which 26 were requests for telework as a reasonable accommodation.

All new SEC managers participate in mandatory training regarding the reasonable 

accommodation process as part of the CLTD 307 Fundamentals of Human Resource 

Management training. Additionally, the SEC’s New Employee Orientation includes a 

presentation on the following programs and processes: RA, TMT, Telework, and Leave 

(i.e., annual/sick, advance leave, FMLA, etc.). This information is included in the New 

Employee Handbook and made available on the AskHR portal.

The Agency will continue ongoing efforts to procure a new HR service delivery platform 

to automate the reasonable accommodation program case management process in FY 

2021. The implementation of the 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 address the timeliness standards set by the 

new SEC policy which increased the processing timeframe to 45 business days, absent undue 

hardship. To advance RA program maturity and success, system requirements analyses 

are expected to be completed in calendar year 2021 and full design and implementation of 

the system which includes finalizing RA electronic system requirements, conducting user 

acceptance testing, and training the SEC workforce on the new interactive processing portal 

is expected in calendar year 2022.

Additionally, OHR continues to find ways to strengthen the current manual tracking process, 

including tracking timeliness for processing RA requests, and meeting on a monthly basis 

with the CHCO to review and discuss timeliness and processing of all RA cases. The Agency 

will continue its efforts to implement the business requirements for the electronic case 

management system.

Requests and information relative to Personal Assistance Services remain available on the 

AskHR interactive portal. The SEC intends to publish in FY 2021 the new RA policy and 

operational procedures approved by the EEOC (in August 2019). During FY 2020, the 

Agency continued the review of the electronic case management system’s business requirements, the new policy, and related procedural changes that support RA for employees and 

applicants for employment. Furthermore, changes to RA procedures will likely necessitate 

updates to training, job aids, notices, and other information sources in FY 2021 and beyond.
FISCAL YEAR 2020 | 41

Personal Assistance Services Allowing Employees to Participate 

in the Workplace

Pursuant to 29 C.F.R.§ 1614.203(d)(5), federal agencies, as an aspect of affirmative action, are 

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

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

1.Describe the effectiveness of the policies, procedures, or practices to implement the PAS 

requirement. Some examples of an effective program include timely processing requests for 

PAS, timely providing approved services, conducting training for managers and supervisors, 

and monitoring PAS requests for trends.

In FY 2019, the Agency revised its Reasonable Accommodation Policy and related Operating 

Procedures. This guidance replaces the current resource guide Disability Accommodation 

Procedures with a new RA policy and related operating procedures to include information 

related to PAS, under SECR 6-80, Reasonable Accommodation Program. The Commission 

is finalizing these documents internally and will disseminate and train appropriate staff 

on the revised policy and procedures (and forms), and post a 508-compliant version of 

these documents on its public website at SEC.gov in FY 2021, as required under the new 

Section 501 Affirmative Action Regulations. In early FY 2021, the SEC published additional 

resource information for employees, supervisors, and managers on its AskHR portal that 

provides a general overview and insight into its reasonable accommodation program process.

The SECR 6-80 Reasonable Accommodation Program Policy and 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. Program provisions for requesting and providing 

decision 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.

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

services. In FY 2020, the SEC did not receive or process any requests (new or modifications) 

for PAS services. Consequently, the employee utilization rate remains at the FY 2019 level.

The Agency will continue to monitor its current contract for personal assistant and reader 

services to ensure the consistent delivery of health care services and will enhance the level of 

support as required.

Continued on the next page
42 | AFFIRMATIVE ACTION PLAN

During FY 2020, 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 (CLTD 307) Fundamentals of Human 

Resources (HR) 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 RA programs, 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, Learn Engage Achieve 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 2020 | 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 X No 0 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 2020, the Agency did not have any findings of discrimination alleging harassment 

based on disability status. Two formal complaints that included allegations of harassment 

based on disability were settled.

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 2020, the Agency did not have any findings of discrimination involving the failure 

to provide reasonable accommodation. Three formal complaints that included allegations 

involving the failure to provide reasonable accommodations resulted in settlement agreements.
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.

Analyses of Persons with Disability and Targeted Disability in the Workforce

STATEMENT OF CONDITION THAT WAS A TRIGGER FOR A POTENTIAL BARRIER:

Provide a brief narrative describing the condition at issue. 

How was the condition recognized as a potential barrier?

There was a lower-than-expected participation rate of Persons with Targeted Disabilities (PWTD) in the total workforce and in promotions 

to higher level positions when this study was initiated based on data from FY 2014. The participation rate of PWTD in the SEC’s workforce 

was less than 1% in FY 2014 based on the then-current Standard Form 256 (SF-256) Self Identification of Disability. Participation of 

PWTD in the permanent workforce has increased based on the revised categories reflected in the new October 2016 version of the 

SF-256 to 2.02% in FY 2018.

In FY 2018 data, the participation rate of Persons with Disabilities (PWD) in the total permanent workforce and among higher salaried 

employees as documented in responses to earlier sections is below the goal of 12% established by Section 501 of the Rehabilitation Act. 

The participation rate of higher salaried employees is 8.64%. 

Participation of PWD, and sometimes PWTD, among new hires and internal competitive promotions to mission critical, senior grade level, 

and leadership positions and among those who were selected for career development is below their availability in the relevant or qualified 

applicant pools. 

In contrast, the participation rate of PWD among those separating from the Agency in both FY 2017 and FY 2018 exceeded that expected 

based on their participation in the total workforce and in comparison to persons with no disability.
FISCAL YEAR 2020 | 45

Source of the Trigger Specific Workforce Data Table 

Workforce Data Table (if so identify the table) Redacted Table B1 and employment lifecycle data

EEO Complaint(s)

Grievance(s)

Climate Assessment Survey

Exit Interview(s)

Anecdotal

Other 

EEO Group(s) Affected by Trigger 

EEO Group

Persons with Disability X

Persons with Targeted Disability X

Barrier Analysis Process 

Source of the Trigger

Source 

Reviewed?

(Yes or No)

Identify Information Collected

Workforce Data Tables Yes Workforce data tables and participation rates for PWD and 

PWTD from FY 2011 – FY 2018.

Demographic information related to retention for separated and 

on rolls PWD.

Complaint Data (Trends) Yes EEO complaint activity filed between FY 2012 – FY 2017 to 

identify any trends in complaints filed by PWD or PWTD.

Climate Assessment Survey (e.g., FEVS) Yes Federal Employee Viewpoint Survey data to compare responses 

from persons with disabilities to those with no disability.

Responses from PWD and PWTD to a Workplace Experience 

Survey conducted at the SEC during FY 2018.

Exit Interview Data Yes Responses provided by PWD to the Agency’s exit survey data 

from FY 2016 through FY 2018.

Focus Groups No

Interviews Yes Interviews with subject matter experts in OHR and OMWI 

and subject matter experts in disabled student service offices 

at Gallaudet University and Rochester Institute of Technology.

Interviews with the managers of PWD involuntarily 

separated during FY 2018 to uncover any preventable 

reasons for separation.

Reports (e.g., Congress, EEOC, MSPB, GAO, 

OPM)

Yes Reports and regulations related to the employment of PWD and 

PWTD in the federal workforce offered by OPM, EEOC, DOL/

ODEP, EARN, and other agencies and supporting organizations.
46 | AFFIRMATIVE ACTION PLAN

Source of the Trigger

Source 

Reviewed?

(Yes or No)

Identify Information Collected

Other (Please Describe) Yes Laws and federally mandated hiring and promotions policies, 

practices, and procedures applicable to recruitment and 

retention of persons with disabilities.

The Agency’s hiring and promotions policies, practices, and 

procedures applicable to people with disabilities, including 

those with targeted disabilities.

Selection case files (hiring and promotions) from FY 2014 and 

FY 2015.

Research literature, collective bargaining agreement language, 

and reports to better understand career development, 

promotion, retention, and recruiting and hiring processes related 

to PWD and PWTD.

Information about best practices in recruiting PWD in the federal 

government and private industry.

Status of Barrier Analysis Process 

Barrier Analysis Process Completed?

(Yes or No)

Barrier(s) Identified?

(Yes or No)

Yes No

Statement of Identified Barrier(s) 

Barrier Name* (required) Description of Policy, Procedure, or Practice

No barrier was identified. While the Agency has not identified specific policies, practices, 

or procedures that represent a “barrier that affects employment 

opportunity for PWD or PWTD,” representatives of OEEO and OHR 

agreed to take action toward enhancing equal employment opportunity 

for persons with (targeted) disabilities in the following areas:

• Develop and implement policies and procedures specific to the 

recruitment, hiring, advancement, and retention of persons with 

disabilities and persons with targeted disabilities that are aligned 

with the federal government wide flexibilities and requirements for 

affirmative action;

• Enhance consistency and structure in the posting, screening, and 

interview processes for selection; and

• Create awareness on the part of hiring managers and subject 

matter experts (or others involved in the Agency’s recruitment and 

selection processes) about the requirements for, and flexibilities 

available under, government wide programs supporting PWD and 

the affirmative action plan for PWTD; and employment programs, 

especially reasonable accommodation and disability programs, 

supportive of PWD and PWTD.
FISCAL YEAR 2020 | 47

Objective(s) and Dates for EEO Plan 

Date 

Initiated

(mm/dd/yyyy)

Target 

Date

(mm/dd/yyyy)

Sufficient 

Staffing & 

Funding

(Yes or No)

Modified 

Date From

(mm/dd/yyyy)

Date 

Completed

(mm/dd/yyyy)

Objective

10/01/2015 10/31/2020 Yes 09/30/2020 11/30/2020 The objective of these efforts will 

be to continue to implement action 

plans developed to address the 

experience of PWTD and expand 

those plans to cover PWD in line 

with the revised EEOC regulations. 

Additional action will focus on:

• Analysis of quantitative and 

qualitative data, including 

employee perceptions 

among the population of 

PWD and PWTD;

• Implementing the recommended and required 

actions under Section 501 

of the Rehabilitation Act 

of 1973;

• Implementing, as feasible, 

revisions to the workforce 

data tables presenting 

information on PWD and 

PWTD, as per instruction 

from EEOC; and

• Reviewing and updating 

agreed-upon action plans 

to address the broader 

population of PWD and 

PWTD and/or to cover 

Section 501 regulatory 

changes.

Responsible Official(s) 

Title Name

Performance Standards 

Address the Plan? 

(Yes or No)

Chief Human Capital Officer, OHR Jamey McNamara Yes

Director, OEEO Peter J. Henry Yes
48 | AFFIRMATIVE ACTION PLAN

Planned Activities toward Completion of Objective 

Target 

Date

(mm/dd/yyyy)

Planned 

Activities

Sufficient 

Staffing & 

Funding

(Yes or No)

Modified 

Date From

(mm/dd/yyyy)

Completion 

Date

(mm/dd/yyyy)

11/30/2017 OEEO will conduct a Workplace Experience Survey

of the Agency workforce to explore employee 

perceptions among the population of PWD and 

PWTD as well as those without disabilities on, 

among other topics, the recruitment, hiring, 

promotion, recognition, and retention of talent.

Yes 11/6/2017

01/31/2018 The Agency will establish a cross-functional working 

group with representatives from OEEO and OHR to 

develop action plans and implement required and 

recommended activity under Section 501 of the 

Rehabilitation Act of 1973.

Yes 11/02/2017

03/31/2019 OEEO will gather data to determine the reasons 

for removal of PWD by reviewing data on file 

from any specific EEO activity and interviewing 

the supervisors of PWD who were involuntarily 

separated in FY 2017 and FY 2018.

Yes 3/31/2019

10/31/2020 OEEO will implement feasible changes to the 

workforce data tables providing information on 

PWD and PWTD in collaboration with a contracted 

service provider.

Yes 09/30/2019 11/30/2020
FISCAL YEAR 2020 | 49

Report of Accomplishments 

Fiscal Year Accomplishments

FY 2020 All planned actions toward the objective defined in this section are complete. This particular study is now closed.

During FY 2020, OEEO completed the work to design and implement changes to the workforce data tables under 

EEOC’s instruction to federal agencies for workforce analysis. Revised tables that required significant manual 

intervention were included in the Agency’s FY 2019 MD-715 Report. 

In parallel with developing and submitting the FY 2019 MD-715 Report, OEEO worked to improve the functionality 

and design of its equal employment opportunity—analytic tool (EEO-AT). These improvements added automation 

and standardized structure to the processing of workforce data tables, significantly reducing the workload 

associated with preparing workforce data tables, including those presenting information on persons with disabilities. 

Tool development was completed near the close of the fiscal year. User testing and resolution were completed in 

late October and early November. The improved EEO-AT II was used to generate and verify information presented 

in this report, including extensive analysis of persons with disability and persons with targeted disability shared in 

other sections of this report, supra. A fully functional set of analyses are now available. Technical documentation of 

analytic methods, data definitions, and standard operating procedures for this tool will continue in FY 2021. 

During FY 2020, OEEO and the SEC also completed the following actions in support of the SEC’s Affirmative 

Action Plan for the Recruitment, Hiring, Advancement and Retention of Persons with Disabilities in the workforce.

• The Disability Interests Advisory Committee took action through the Employment Lifecycle subcommittee 

focused on member interests. To inform this action, OEEO shared information with this subcommittee about 

the Agency’s PWD workforce, led group exercises to uncover and define opportunities to expand support 

for PWD, and provided the resulting suggestions for action by DIAC members, by other supporting process 

owners in OHR and Office of Support Operations, and by Agency leadership in general.

• During FY 2020, the Diversity Council and the SEC Chairman solicited input from each EAG to inform 

Agency response to observed differences in the employee experience from FEVS data. DIAC’s suggestions 

for concrete action for the Diversity Council were informed by OEEO’s prior barrier analysis work and the 

data-driven insights from the Employee Lifecycle subcommittee described above. DIAC’s contribution, in 

turn, informed specific near and longer term initiatives, which notably captured and called out actions to 

enhance equality of opportunity for the Agency’s disability community.

• In late FY 2020, OEEO worked with OMWI, OHR, and DIAC on plans for a fireside chat hosted by 

Commissioner Roisman and DIAC’s executive sponsor, which took place during the 2020 National Disability 

Employment Awareness Month. During this impactful session, Commissioner Roisman led a discussion with 

senior leaders who self-identify as persons with a disability. The discussion included: personal disclosure 

in connection with the OEEO-led UN-covering Taskforce initiative, an overview of each leader’s personal 

experiences and journey toward success, and the value of relationships and strong supportive community. 

The session design and format conform to OEEO’s research-based suggestions for strong senior leader 

support and modeling disability inclusion.

• The Agency focused greater attention on accessibility in the workplace. Specifically, the SEC continues to 

provide consistent, dedicated, and timely support for information technology accessibility to the PWD and 

PWTD communities.

• The Agency’s RA Program office continues to engage with the OHR, Talent Acquisition Group to assist 

newly-selected employees who self-identity themselves as PWD or PWTD to determine the accessibility 

options, if any, they may need so that solutions can be identified and made available when the employee 

reports for duty at the SEC.

• The Agency conducted scenario-based training with specific illustrations for supervisors and managers to 

heighten their awareness about the Rehabilitation Act and the SEC’s RA program and provides general 

characteristics of available accommodations (offerings such as PAS) typically requested by employees 

with disabilities. The training also clarifies assumptions about roles and responsibilities with respect to the 

Agency’s reasonable accommodation program.

• The Agency updated its external website to ensure public accessibility of its reasonable accommodation 

procedures and personal assistance services guidance on the SEC.gov website for PWD and PWTD.

• The Agency published additional resource information for employees, supervisors, and managers on the 

Agency’s interactive internal portal, AskHR, which provides a general overview and insight into its reasonable 

accommodation program process.

• The Agency strengthened partnerships with stakeholders to include SEC program offices, NTEU, OMWI, 

DIAC, and employee affinity groups to identify sustainable actions to improve the Agency’s Diversity and 

Inclusion initiatives for the PWD and PWTD communities.

• The Agency continued to provide reasonable accommodations to include PAS reader and personal assistant 

services, assistive technology and equipment, and ergonomic equipment to PWDs and PWTDs during 

the current mandatory telework status. The Agency provided non-installation equipment (e.g., task chairs, 

monitors, keyboards) to employees at their place of residence.
50 | AFFIRMATIVE ACTION PLAN

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

planned activities.

During FY 2020, OEEO completed the work to design and implement changes to the 

workforce data tables under EEOC’s instruction to federal agencies for workforce analysis.

A fully functional tool to generate workforce data tables is now available. All planned 

actions toward the objective defined in this section are complete.

This study is now closed.

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

activities toward eliminated the barrier.

Actions defined for this objective are now complete. This particular study is now closed.

Additional exploration and analysis supporting the SEC’s Affirmative Action Plan for 

Persons with Disabilities will be considered under the prioritization framework for 

inclusion in the SEC’s research agenda.

As described in other sections above, after a steady increase in participation over the 

past several years, the Agency achieved the goals established under Section 501 of the 

Rehabilitation Act for both PWTD and PWD at the lower salary levels. Because of the 

relatively small size of the PWD and PWTD populations, small changes in workforce 

participation, year over year, can have large impacts on the observed rates of change.

Nonetheless, the SEC notes the following indications of growth within this employee 

population. From FY 2013 to FY 2020:

n The permanent workforce of PWTD experienced net growth of 14 persons or 19.44%, 

which outpaces the 12.83% net growth in the total permanent workforce over that same 

time period. Participation of PWTD in the total permanent workforce rose from 1.81% 

to 1.91%. PWTD, among higher salaried employees, increased from 1.54% to 1.94%.

n The permanent PWD workforce experienced net growth of 168 persons or 75.34%.

Participation of PWD rose from 5.14% in the total workforce to 8.70% and from 

4.93% to 8.62% among higher salaried employees.

Trend data over time revealed that increased participation resulted from greater selfidentification based on employee resurveys, changes to categories defining PWD, and a 

general increase in the proportion of SEC staff in higher salaried jobs. OEEO will continue 

to monitor the PWD and PWTD workforce participation for signs of continued or 

accelerated growth and consider effects of underreporting on these statistics.
FISCAL YEAR 2020 | 51

6.If the planned activities did not correct the trigger(s) and/or barrier(s), please describe how the 

Agency intends to improve the plan for the next fiscal year.

Triggers from the original study of PWTD continue to require focused attention toward 

improvement. Starting in FY 2016 and through FY 2019, representatives of OEEO and 

OHR initiated and completed actions intended to address the recommendations to improve 

employment opportunities for PWTD. These actions were completed in FY 2019.

This study of Persons with Targeted Disabilities is now closed.
52 | AFFIRMATIVE ACTION PLAN TABLE B1: TOTAL WORKFORCE—DISTRIBUTION BY DISABILITY [OPM FORM 256 SELF-IDENTIFICATION CODES] PAY PERIODS 201922 TO 202021

EMPLOYMENT 

TENURE

TOTAL

No Disability [05]

Not Identified [01]

Disability 

[02-03, 06-99]

1 Other PWD

Total PWD

PWTD

Developmental 

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 WORKFORCEPrior FY # 4,365 3,776 212 336 41 377 85 0 1 38 8 3 5 6 3 1 16 1 3

% 100% 86.51% 4.86% 7.70% 0.94% 8.64% 1.95% 0.00% 0.02% 0.87% 0.18% 0.07% 0.11% 0.14% 0.07% 0.02% 0.37% 0.02% 0.07%

Current 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%

Difference # 128 103 11 7 7 14 1 0 0 0 -1 0 0 0 0 -1 3 0 0Ratio Change

% 0.00% -0.18% 0.10% -0.07% 0.13% 0.06% -0.04% 0.00% 0.00% -0.02% -0.02% 0.00% 0.00% -0.01% 0.00% -0.02% 0.05% 0.00% 0.00%

Net Change

% 2.93% 2.73% 5.19% 2.08% 17.07% 3.71% 1.18% 0.00% 0.00% 0.00% -12.50% 0.00% 0.00% 0.00% 0.00% -100.00% 18.75% 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 202021, downloaded on 11/12/2020
FISCAL YEAR 2020 | 53

TABLE B1: TOTAL WORKFORCE—DISTRIBUTION BY DISABILITY [OPM FORM 256 SELF-IDENTIFICATION CODES] PAY PERIODS 201922 TO 202021 continued

EMPLOYMENT 

TENURE

TOTAL

No Disability [05]

Not Identified [01]

Disability 

[02-03, 06-99] 1 Other PWD

Total PWD

PWTD

Developmental 

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]

PERMANENTPrior FY

# 4,266 3,686 208 331 41 372 84 0 1 38 7 3 5 6 3 1 16 1 3% 100% 86.40% 4.88% 7.76% 0.96% 8.72% 1.97% 0.00% 0.02% 0.89% 0.16% 0.07% 0.12% 0.14% 0.07% 0.02% 0.38% 0.02% 0.07%

Current 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%

Difference # 123 100 11 7 5 12 1 0 0 0 0 0 0 0 0 -1 2 0 0Ratio Change % 0.00% -0.14% 0.11% -0.06% 0.09% 0.03% -0.03% 0.00% 0.00% -0.02% 0.00% 0.00% 0.00% 0.00% 0.00% -0.02% 0.04% 0.00% 0.00%Net Change % 2.88% 2.71% 5.29% 2.11% 12.20% 3.23% 1.19% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% -100.00% 12.50% 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).

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 202021, downloaded on 11/12/2020
54 | AFFIRMATIVE ACTION PLAN TABLE B1: TOTAL WORKFORCE—DISTRIBUTION BY DISABILITY [OPM FORM 256 SELF-IDENTIFICATION CODES] PAY PERIODS 201922 TO 202021 continued

EMPLOYMENT 

TENURE

TOTAL

No Disability [05]

Not Identified [01]

Disability 

[02-03, 06-99]

1 Other PWD

Total PWD

PWTD

Developmental 

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]

TEMPORARYPrior FY # 99 90 4 5 0 5 1 0 0 0 1 0 0 0 0 0 0 0 0

% 100% 90.91% 4.04% 5.05% 0.00% 5.05% 1.01% 0.00% 0.00% 0.00% 1.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Current 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%

Difference # 5 3 0 0 2 2 0 0 0 0 -1 0 0 0 0 0 1 0 0Ratio Change

% 0.00% -1.49% -0.19% -0.24% 1.92% 1.68% -0.05% 0.00% 0.00% 0.00% -1.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.96% 0.00% 0.00%

Net Change

% 5.05% 3.33% 0.00% 0.00% 0.00% 40.00% 0.00% 0.00% 0.00% 0.00% -100.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 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 202021, downloaded on 11/12/2020
FISCAL YEAR 2020 | 55

TABLE B1: TOTAL WORKFORCE—DISTRIBUTION BY DISABILITY [OPM FORM 256 SELF-IDENTIFICATION CODES] PAY PERIODS 201922 TO 202021 continued

EMPLOYMENT 

TENURE

TOTAL

No Disability [05]

Not Identified [01]

Disability 

[02-03, 06-99] 1 Other PWD

Total PWD

PWTD

Developmental 

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 WORKFORCE2Prior FY

# 4 0 0 3 1 4 2 0 0 2 0 0 0 0 0 0 0 0 0% 100% 0.00% 0.00% 75.00% 25.00% 100% 50.00% 0.00% 0.00% 50.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Current 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%

Difference # 3 0 0 4 -1 3 1 0 0 -1 0 0 0 0 0 0 2 0 0Ratio Change % 0.00% 0.00% 0.00% 25.00% -25.00% 0.00% -7.14% 0.00% 0.00% -35.71% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 28.57% 0.00% 0.00%Net Change % 75.00% 0.00% 0.00% 133.33% -100.00% 75.00% 50.00% 0.00% 0.00% -50.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 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 202021, downloaded on 11/12/2020
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OFFICE OF EQUAL EMPLOYMENT OPPORTUNITY

U.S. Securities and Exchange Commission

100 F Street NE

Washington, DC 20549