AFFIRMATIVE ACTION

PLAN AND REPORT

For the Recruitment, Hiring, Advancement, and

Retention of Persons With Disabilities

PREPARED BY THE OFFICE OF EQUAL EMPLOYMENT OPPORTUNITY
2 | AFFIRMATIVE ACTION PLAN

Some information referenced in this report has been redacted to protect employee privacy.
FISCAL YEAR 2021 | i

CONTENTS

SPECIAL PROGRAM PLAN FOR THE RECRUITMENT, HIRING, ADVANCEMENT, 

AND RETENTION OF PERSONS WITH DISABILITIES 1

Section I: Efforts to Reach Regulatory Goals 1

Section II: Model Disability Program 4

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

Plan to Ensure Sufficient Funding for the Disability Program . . . . . . . . . . . . . . . . 5

Section III: Plan to Recruit and Hire Individuals with Disabilities 6

Plan to Identify Job Applicants with Disabilities . . . . . . . . . . . . . . . . . . . . . . . 6

Plan to Establish Contacts with Disability Employment Organizations . . . . . . . . . . . 9

Progression towards Goals (Recruitment and Hiring) 10

Section IV: Plan to Ensure Advancement Opportunities for Employees with Disabilities 14

Advancement Program Plan 14

Career Development Opportunities 16

Awards 22

Promotions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25

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

Voluntary and Involuntary Separations 33

Accessibility of Technology and Facilities 36

Reasonable Accommodation Program . . . . . . . . . . . . . . . . . . . . . . . . . . . .38

Personal Assistance Services Allowing Employees to Participate in the Workplace . . . . .42

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

EEO Complaint Data Involving Harassment 43

EEO Complaint Data Involving Reasonable Accommodation 43

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

TABLE B1: TOTAL WORKFORCE—DISTRIBUTION BY DISABILITY 45

Prepared by

THE OFFICE OF EQUAL EMPLOYMENT OPPORTUNITY
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FISCAL YEAR 2021 | 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 2021, the locality adjusted salary of a GS-11, step 1, in the Washington, DC area 

was $72,750.

Continued on the next page
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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.

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

for PWD participation; eight or 62.50% 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 8.81% 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 2021, the participation of PWD in the total workforce increased 

from 6.57% to 8.81%; participation increased in both the lower and higher salary clusters.

2.Using the goal of 2% as the benchmark, does your Agency have a trigger involving PWTD by

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

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

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

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

cluster during FY 2021. In the lower salary cluster, none of the eight permanent employees 

are PWTD. The SEC did not achieve the numerical goal for PWTD among higher-salaried 

employees—1.81% of higher-salaried employees are PWTD.
FISCAL YEAR 2021 | 3

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

and/or recruiters.

In FY 2021, the SEC’s Office of Human Resources (OHR) developed the 2022 – 2024 

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 talent pool 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.

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 2021 and particularly during National Disability Employment Awareness 

Month in October 2020 and October 2021, 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 PW(T)D, frequently mentioning the high value such employees bring to the Agency’s mission.
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SECTION II: MODEL DISABILITY PROGRAM

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

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

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

disability hiring and advancement program the Agency has in place.

Plan to Provide Sufficient & Competent Staffing for the Disability Program

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

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

the upcoming year.

Yes X No 0

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

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

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 Xiya Li, Branch Chief

Office of Human Resources

lixiy@sec.gov

Answering questions from the public 

about hiring authorities that take 

disability into account

13 0 0 Xiya Li, Branch Chief

Office of Human Resources

lixiy@sec.gov

Processing reasonable 

accommodation requests from 

applicants and employees

3 0 0 Dia Gonsalves, Disability Program Officer

Office of Human Resources 

gonsalvesd@sec.gov

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

Governance Branch

Office of Information Technology

jonessh@sec.gov

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

Office of Support Operations (OSO)-Office 

of Building Operations (OBO) 

ferrarir@sec.gov

Jinhee Kim, RA, LEED AP, Architect

OSO-OBO

kimjin@sec.gov 

Carla Hairston, NCIDQ, COEE, 

Space Management Specialist 

OSO-OBO

hairstonc@sec.gov

Special Emphasis Program for PWD 

and PWTD

3 0 0 Xiya Li, Branch Chief

Office of Human Resources

lixiy@sec.gov
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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, 

religious accommodations, performance management, 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 Office of Personnel 

Management (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; however, processing employee requests for an exemption from 

the COVID vaccine mandate for federal employees significantly increased the Reasonable 

Accommodation Program’s workload.
6 | AFFIRMATIVE ACTION PLAN

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.

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

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

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

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

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

staffing process.

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

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

Strategy which was extended into FY 2021, the SEC has realized an increase in the overall 

representation of people with disabilities through effective recruitment and outreach efforts 

that identify the Agency as an employer of choice. The SEC noted that in FY 2021, within 

the mission critical occupations (MCO) of accountant, examiner, and IT management, 

applications from PWD remained at the same rates as in FY 2020 or slightly declined.

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

presence in FY 2021, and attended 18 virtual career fairs and events supporting disability 

recruitment efforts in building talent pools for future employment.

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.
FISCAL YEAR 2021 | 7

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

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

permanent workforce.

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

other hiring authorities that take disability into account.

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

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

n EARN—Employer Assistance Resource Network: askearn.org

n JAN—Job Accommodation Network: askjan.org

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

dol.gov/agencies/odep

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

operation-warfighter/

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

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

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

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

The following describes two procedures for processing applications under the Schedule 

A hiring authority for persons with disabilities, one used in response to a specific vacancy 

posting and the other for unsolicited Schedule A applications.

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

Opportunity Announcement (JOA).

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

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

JOA. The SEC defers to the OPM-identified appropriate documentation. Applications 

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

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

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

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

can be selected once the certificate has been issued.

Continued on the next page
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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 application. Building a pool of qualified 

candidates is important to the SEC; as such, the Agency has developed a Schedule A 

Resume Database.

The SEC process for hiring starts with a Staffing Action Request Form (SARF) submitted 

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

Programs Manager compiles a certificate of eligible candidates from the database per 

the job series and refers candidates to hiring managers. 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 2021, 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 advises the hiring manager on the various procedures of 

the Schedule A hiring process and offers it as a course of action where applicable.

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

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

with Disabilities.
FISCAL YEAR 2021 | 9

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 (OWF) program during FY 2021.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 also utilized 

the Warriors Ethos program during FY 2021 to host transitioning service members by 

providing them with a volunteer opportunity to get exposure to the work done at the 

Agency. The program is a non-profit that specializes in helping to transition military 

service members with career planning, professional development, and career placement.

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

DIAC and the Veterans Committee members which help support the Agency’s efforts to 

recruit PWD and PWTD.

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

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

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

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

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

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

transitions back to normal work posture post the COVID-19 pandemic. 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.
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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 2021, the Agency hired 222 permanent employees, of which PWD and PWTD 

represented 11.71% and 1.35%, respectively, of all new hires. As such, the Agency did not 

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

among permanent new hires.See Table B1.

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 2021, the SEC hired and onboarded a total of 222 permanent staff employees.

Among these newly-hired staff members were 167 persons in MCO positions as follows: 

91 attorneys; 22 accountants; 13 securities compliance examiners; 35 IT management 

specialists; and six (6) economists. Eleven of those 167 (6.59%) 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 with their application.

In addition, in FY 2021, 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
FISCAL YEAR 2021 | 11

Triggers were observed for PWD in the hiring of permanent IT management specialists and 

economists as follows: 

n For IT management, 5.71% of new hires were PWD, below their representation in the 

qualified applicant pool (10.70%).

n No PWD were hired for any of the six economist positions although 27 PWD were in 

the QAP (5.72%).

Triggers were also observed for PWTD in the attorney, IT management, and economist 

occupations: 

n For attorneys, the QAP for PWTD was 1.31%; no PWTD (0.00%) were hired as 

permanent staff attorneys.

n Sixty-six PWTD were in the QAP (2.72%) for IT management, and no PWTD 

were hired (0.00%).

n Eleven PWTD were in the QAP (2.33%) for economist positions, and no PWTD 

were hired.

n For securities compliance examiner vacancies posted in FY 2021, no PWD or PWTD 

were found in the QAP. Thus, none were hired.
12 | AFFIRMATIVE ACTION PLAN

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

Differences were identified in the participation of PWD in the qualified internal applicants 

for competitive promotions as compared to the relevant applicant pool (RAP) within the 

attorney occupation. Differences were also identified between the RAP and QAP for PWTD 

within the internal competitive promotion data for the MCOs of securities compliance 

examiner and economist.

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

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

SK-11 and SK-16. Specifically, for attorneys, the RAP included all employees in the 0905 

series. For accountants, the RAP included all employees in the 0510 series. For securities 

compliance examiners, the RAP included all employees in the 1831 and the 0501, 

Financial Administration and Program series. For the 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 5.47%, and PWD represented 

3.97% of the qualified internal applicants. The RAP for PWTD was 1.03%, and PWTD 

were 0.33% of the qualified internal applicants for attorneys.

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

qualified internal applicants for PWTD, but not for PWD. The RAP for PWTD was 1.69%, 

and PWTD represented none of the qualified internal applicants.

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

applicants for PWTD, but not for PWD. The RAP for PWTD was 1.20%, and there were 

no PWTD among qualified internal applicants.
FISCAL YEAR 2021 | 13

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 0 No X

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

examiner, and economist occupations. No differences were observed for selections among 

the accountant or IT management occupations.

For attorneys, the QAP for PWD was 3.97%, and PWD were 2.17% of selections.

For securities compliance examiners, the QAP for PWD was 7.41%, and no PWD 

were selected.

For economists, the QAP was 4.00%, and no PWD were selected.

The selection data also indicate there were no differences between selections and the qualified 

applicant pool for PWTD in any of the mission-critical occupations.
14 | AFFIRMATIVE ACTION PLAN

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
FISCAL YEAR 2021 | 15

In addition to these ongoing efforts, in FY 2021, 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. On February 12, 2021, the SEC submitted its 

compliance report to the EEOC related to the ongoing deficiencies and implemented the 

improvements noted below.

These improvements include posting complaint procedures related to Section 504 and 508 

of the Rehabilitation Act and Architectural Barriers Act on the SEC’s external website. In 

response to the EEOC’s recommendation that the SEC ensure PWDs participate in the SEC’s 

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

for employees with disabilities and has been collaborating with DIAC to communicate this 

opportunity to its membership.

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

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

Offices of Human Resources, Equal Employment Opportunity, and Minority and Women 

Inclusion, and key members of the Disability Interests Advisory Committee. This working 

group began meeting in FY 2021 and, leveraging evidence-based data, made a number 

of recommendations related to the recruitment, hiring, career development, promotion, 

reasonable accommodation, and retention of PWD and PWTD at the SEC. The working 

group explored enhanced marketing of available SEC career development programs, possible 

tailoring of existing SEC advancement-related programs, and creating new development 

programs tailored for employees with disabilities. The working group also explored available 

data related to other employment policies, practices, and processes in order to provide 

recommendations on enhancing the employment life cycle for individuals with disabilities.
16 | AFFIRMATIVE ACTION PLAN

Career Development Opportunities

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

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

certifications needed to succeed in their technical positions and to progress in their careers.

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

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

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 noted below.

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

transformative professional development experience designed to provide employees at 

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

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

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

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

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

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

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

emotions play in leadership outcomes.

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

strengthens the leadership skills of experienced federal employees through a combination 

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

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

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

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

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

organizational performance, workplace relationships, and productivity.

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

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

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

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

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

Continued on the next page
FISCAL YEAR 2021 | 17

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

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

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

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

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

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

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

of peers representing various industries and functions.

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

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

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

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

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

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

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

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

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

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

program. In FY 2021, 58 SEC managers engaged in coaching with an external coach. Due 

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

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

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

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

maintain effective relationships for SEC leaders at all levels).

In FY 2021, the SEC continued the design of a leadership evaluation, accession and 

development 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 

including standardized leadership assessments that screen candidates on essential leadership 

competencies. OHR’s Human Capital Strategy Group is developing the leadership 

assessments with a high level of rigor to ensure they provide a standardized, fair, and legallycompliant approach for selecting SOs. A diverse group of SOs, representing the major SEC 

Divisions and Offices, developed assessment content and structured rating scales to ensure a 

standardized evaluation of candidate performance on specific leadership competencies.

Continued on the next page
18 | AFFIRMATIVE ACTION PLAN

Special advisors from OEEO and OMWI remain involved in the development process, 

reviewing content to ensure program materials and processes support fairness, diversity, and 

inclusion. A targeted communication effort, designed to educate SEC employees and create 

program awareness, will launch in FY 2022. Scheduled Division and Office meetings, LEAP

sessions, and affinity group presentations are planned venues to share program information 

specifically emphasizing that the program offers development opportunities aligned to critical 

SO leadership competencies. In addition, feedback on the leadership assessments highlight 

individual strengths and weaknesses to focus ongoing leadership development for employees 

willing to self-develop in the leadership skills targeted by this program. After a pilot test of 

the assessments, program launch is anticipated later in 2022.

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 transitioned to a permanent program (with 

a target set for the 2022 mentee cohort). To fulfill this commitment, OHR reserved five (5) 

slots in the 2022 Mentoring Program cohort for employees with disabilities and collaborated 

with DIAC to communicate this opportunity to its membership. 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. To this 

end, in FY 2021, the SEC launched a cross-office working group comprised of SOs who are 

champions of disability inclusion, subject matter experts in the Offices of Human Resources, 

Equal Employment Opportunity, and Minority and Women Inclusion, and key members of 

the Disability Interests Advisory Committee. This working group began meeting in FY 2021 

and, leveraging evidence-based data, recommended, inter alia, specific actions to increase the 

participation of employees with disabilities in the Agency’s career development programs.

The working group explored enhanced marketing of available SEC career development 

programs, possible tailoring of existing SEC advancement-related programs, and creating 

new development programs tailored for employees with disabilities. The working group also 

explored available data related to other employment policies, practices, and processes in 

order to provide recommendations on enhancing the employment life cycle for individuals 

with disabilities. Participation among PWD and PWTD in the Agency’s existing career 

development opportunities is provided below.
FISCAL YEAR 2021 | 19

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

competition and/or supervisory recommendation/approval to participate.

Career Development Opportunities

Total Participants PWD PWTD

Applicants 

(#)

Selectees 

(#)

Applicants 

(%)

Selectees 

(%)

Applicants 

(%)

Selectees 

(%)

Internship Programs 1,382 19 4.20% 10.53% 1.16% 5.26%

Fellowship Programs 59 8 0.00% 0.00% 0.00% 0.00%

Mentoring Programs 80 30 10.00% 8.00% 3.75% 4.00%

Coaching Programs NA NA NA NA NA NA

Training Programs 18,493 18,493 11.90% 11.90% 2.25% 2.25%

Detail Programs 68 12 7.35% 0.00% 2.94% 0.00%

Other Career Development Programs NA 114 NA 11.40% NA 0.00%

Notes to help the reader understand the data above: 

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

on a first-come, first-served basis.

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

employees engaged in coaching programs.

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

training in LEAP and completed training opportunities during FY 2021. There is no competition 

for training class registration. All eligible employees who register or apply are invited or selected 

to complete the training course. Applicant and selectee participation records are thus identical.

These Applicant registration and Selectee participation records may include more than one 

training opportunity per employee, representing both mandatory and elective courses. Therefore, 

the total registration and participation data exceed the total number of employees.

Detail Programs summarize information only for Temporary Promotions announced by the 

Agency for competitive selection. These data do not reflect detail opportunities that do not 

include a change to the employee’s personnel record, e.g., a detail to a job in the same pay grade 

and location.

In this report, the Agency included FY 2021 selection data for its leadership development 

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

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

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

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

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

Programs” category.
20 | AFFIRMATIVE ACTION PLAN

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

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

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

a. Applicants (PWD) Yes X No 0

b. Selections (PWD) Yes X No 0

From the Career Development Opportunities table in the section above, data on the 

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

were reviewed.

For the Internship Program, 4.20% of applicants were PWD and PWD were 10.53% of 

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

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

For the Agency’s economist and accountant Fellows Programs, the Agency noted no 

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

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

Fellows hired were PWD (0.00%).

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

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

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

permanent workforce (8.91%). PWD represent 10.00% of those employees who expressed 

interest in the Mentoring Program and 8.00% of those selected for mentoring.

Aggregate PWD participation in training programs approved on standard form 182 

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

rolls: 11.90% of training requiring separate approval on SF-182 were completed by PWD, 

compared to 8.91% 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 8.91% of permanent 

staff were PWD, 7.35% of applicants for temporary promotion were PWD. None of the 

applicants were selected.

Selection data for PWD on Other Career Development Programs indicated higher participation rates of PWD in programs for leadership development than the proportion of PWD 

among permanent staff. PWD were 11.40% of selectees among the consolidated selectees of 

the Excellence in Government, Aspiring Leaders, and Women in Leadership programs and 

8.91% of permanent SEC employees.

Continued on the next page
FISCAL YEAR 2021 | 21

The Agency also evaluated career development data from two institutes the SEC has 

enterprise memberships with, the Practising Law Institute (for attorneys) and Becker (for 

accountants). For the Practising Law Institute, attorneys with disabilities participated 

at higher rates than attorneys without disabilities. The inclusion rate was 90.00% of 

the population of attorneys with disabilities, compared to 64.96% of attorneys without 

disabilities. For Becker, the inclusion rate for accountants with disabilities (13.04%) was 

2.57% lower than the inclusion rate for accountants without disabilities (15.61%).

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 the section above, data on the participation of PWTD in various programs were reviewed for equality of employment opportunity 

in the applications and selections for these programs.

In the Agency’s economist and accountant Fellows Programs combined, 0.00% of applicants 

were PWTD, thus, no PWTD were selected as Fellows in FY 2021.

For the Internship Program, 1.16% of applicants were PWTD, and PWTD were 5.26% 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 

(3.75%) exceeded the percentage of PWTD among permanent staff (1.81%). Thus, no trigger was found among applicants. The participation of PWTD among employees selected for 

mentoring in FY 2021 (4.00%) 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 programs.

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

approved on SF-182 through LEAP slightly above their participation on rolls; 2.25% of 

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

1.81% of permanent employees.

Continued on the next page
22 | AFFIRMATIVE ACTION PLAN

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

those who applied for Temporary Promotion and among those selected. While 2.94% of 

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

staff employees selected.

Selection data for PWTD on Other Career Development Programs showed evidence of a 

trigger. Of 114 selectees among the consolidated selectees for the Excellence in Government, 

Aspiring Leaders, and Women in Leadership programs, no selectees were PWTD (0.00%).

The Agency also evaluated career development data from two institutes the SEC has enterprise memberships with, the Practising Law Institute (for attorneys) and Becker (for accountants). For the Practising Law Institute, attorneys with targeted disabilities participated at 

higher rates than attorneys without targeted disabilities. The inclusion rate was 78.95% 

of the population of attorneys with targeted disabilities, compared to 66.16% of attorneys 

without targeted disabilities. For Becker, the inclusion rate for accountants with targeted 

disabilities was zero (0.00%), substantially lower than the inclusion rate for accountants 

without targeted disabilities (15.56%).

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.

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.

Continued on the next page
FISCAL YEAR 2021 | 23

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

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

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

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

at least one award in each applicable program element.

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

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

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

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

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

each applicable program element.

The Agency found a trigger in the distribution of time-off awards of one to ten hours for 

PWTD. The inclusion rate for PWTD was 21.25%, while the inclusion rate for people with 

no targeted disability was 24.04%. There was no trigger for PWD for time-off awards of one 

to ten hours.

The Agency did not find a trigger in the distribution of time-off awards of 11 to 40 hours 

for PWTD. The inclusion rate for PWTD was 22.50%, while the inclusion rate for persons 

without a targeted disability was 22.89%.

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

$1,000 – $1,999 and $2,000 – $2,999.

For cash awards at the $1,000 – $1,999 level, the inclusion rate for PWD was 31.47%, and 

the inclusion rate for persons without disability was 38.25%. The inclusion rate for PWTD 

was 30.00%, and the inclusion rate for persons with no targeted disability was 37.78%.

For cash awards at the $2,000 – $2,999 level, the inclusion rate for PWD was 7.11%, and 

the inclusion rate for persons without disability was 9.95%. The inclusion rate for PWTD 

was 7.50%, and the inclusion rate for persons with no targeted disability was 9.74%.

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

recommendations, and is actively monitoring them as part of our barrier analysis program.
24 | AFFIRMATIVE ACTION PLAN

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 2021, the Agency implemented a new Performance Incentive Bonus Program. This program has been designed to reward extraordinary and rare levels of performance demonstrated 

on a sustained basis, across multiple projects, or reflected in a significant singular achievement 

that required sustained effort over a period of time.
FISCAL YEAR 2021 | 25

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 0 No X

Internal Selections (PWD) Yes 0 No X

b. Grade GS-15

Qualified Internal Applicants (PWD Yes 0 No X

Internal Selections (PWD) Yes X No 0

c. Grade GS-14

Qualified Internal Applicants (PWD) Yes 0 No X

Internal Selections (PWD) Yes X No 0

d. Grade GS-13

Qualified Internal Applicants (PWD) Yes 0 No X

Internal Selections (PWD) Yes X No 0

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

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

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

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

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

actual RAPs for the individual SK-levels differ.

Of 4,148 qualified internal applications for senior grade level positions, 818 (19.72%) were 

submitted by PWD. No triggers were observed for qualified applicants compared to their 

Relevant Applicant Pools at any level. Among internal selections, differences were observed at 

the GS-15, GS-14, and GS-13 equivalent levels, but not the SES equivalent level. Of the 127 

selections for internal promotions to senior grade levels, 8.66% were PWD, which is lower 

than their availability in the QAP at 19.72%.

At the GS-15 equivalent level, PWD represented 23.35% of qualified applicants, while they 

represented 10.87% of selections.

At the GS-14 equivalent level, PWD represented 16.43% of qualified applicants, while they 

represented 8.06% of selections.

At the GS-13 equivalent level, PWD represented 19.57% of qualified applicants, while no 

selections were PWD.
26 | AFFIRMATIVE ACTION PLAN

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 0 No X

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 X No 0

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 as described in the section on PWD immediately 

above, the Agency presents information on trigger identification for PWTD in promotions to 

senior grade levels. Of 4,148 qualified internal applications for senior grade level positions, 

108 (2.60%) were submitted by PWTD, and 2.36% of selections were PWTD.

Differences were observed in the qualified applicant pools for the GS-15, GS-14, and GS-13 

equivalent levels. The following presents data for each grade level.

At the SES equivalent, SO, grade level, the RAP was 1.25% PWTD, and the participation 

among qualified internal applicants of PWTD was 1.88%. The qualified applicant pool for 

PWTD was 1.88%, and selections for SO positions were [Redacted to protect privacy.] PWTD.

At the GS-15 equivalent level, qualified internal applicants (2.87%) exceeded the 

RAP (1.24%). At this level, selections among PWTD (4.35%) also exceeded qualified 

applicants (2.87%).

At the GS-14 equivalent level, the RAP was 1.49%, while 2.21% of the qualified internal 

applicants were PWTD. There were no selections among PWTD.

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

qualified internal applicants. The RAP was 4.98%, and the participation of PWTD among 

qualified internal applicants was 3.09%. The qualified applicant pool was 3.09%, and no 

PWTD were selected.
FISCAL YEAR 2021 | 27

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

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

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

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

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

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

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

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

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

290 newly-hired staff members in FY 2021 were 183 persons hired into senior grade level 

positions: 4 SOs, 12 into GS-15 equivalent positions, 89 into GS-14 equivalent positions, and 

78 into GS-13 equivalent positions. Eighteen of those 183 (9.84%) newly-hired permanent 

staff in senior grade levels identified as PWD. The following evaluates participation of PWD 

in each senior grade equivalent level.

As described above, the QAP reflects applicants who self-identified with a disability when 

they applied for permanent positions with the SEC that were posted in USAJOBS with a 

closing date during the fiscal year and qualified for the position. The SEC also analyzes data 

on 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 of whom 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 5.75% PWD, and none of the four newly-hired 

permanent SOs identified as PWD.

At the GS-15 equivalent level, the QAP was 15.86% PWD, and 8.33% of the 12 newly-hired 

permanent staff for those positions identified as PWD.

At the GS-14 equivalent levels, the QAP was 10.08% PWD, and 13.48% of the 89 newlyhired permanent staff were PWD.

At the GS-13 equivalent level, the QAP was 9.01% PWD, while 6.41% of the 78 new hires to 

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

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

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

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

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

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

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

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

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

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

The qualified applicant pool for PWTD was 2.32%.

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

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

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

At the SES equivalent level, the QAP was 2.30%; no newly-hired staff members were 

PWTD (0.00%).

At the GS-15 equivalent level, the QAP was 2.84%; no newly-hired staff members were 

PWTD (0.00%).

At the GS-14 equivalent level, the QAP was 2.28% PWTD; 1.12% of the newly-hired 

GS-14 equivalent staff were PWTD.

At the GS-13 equivalent level, the QAP was 2.19% PWTD, no newly-hired staff members 

were PWTD (0.00%).
FISCAL YEAR 2021 | 29

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

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

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

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

a. Executives

Qualified Internal Applicants (PWD) Yes 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.

Among the promotions in FY 2021 were 49 persons promoted to a leadership position at 

the supervisor, manager, or executive level: 2 SOs, 27 managers, and 20 supervisors. The 

following evaluates participation of PWD in each leadership level.

For executives, there were no differences to the disadvantage of PWD in the qualified internal 

applicant pool compared to the RAP, or with respect to selections.

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

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

both of these levels with respect to selections.

For managers, the qualified applicant pool was 18.78%, and selections were 7.41% PWD.

For supervisors, the qualified applicant pool was 25.52%, and selections were 20.00% PWD.
30 | AFFIRMATIVE ACTION PLAN

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

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

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

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

a. Executives

Qualified Internal Applicants (PWTD) Yes 0 No X

Internal Selections (PWTD) Yes 0 No X

b. Managers

Qualified Internal Applicants (PWTD) Yes 0 No X

Internal Selections (PWTD) Yes X No 0

c. Supervisors

Qualified Internal Applicants (PWTD) Yes 0 No X

Internal Selections (PWTD) Yes 0 No X

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

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

Of 49 individuals selected for promotion, three (6.12%) were PWTD. 

At the Executive level, the RAP was 1.25% PWTD, and the participation among qualified 

internal applicants of PWTD was 1.88%. The qualified applicant pool for PWTD was 

1.88%, and selections for SO positions were [Redacted to protect privacy.] PWTD.

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

promotions. The QAP for PWTD was 1.46%, while no selections were PWTD.

There were no triggers observed at the supervisor level.
FISCAL YEAR 2021 | 31

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

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

in the text box.

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

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

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

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

information on trigger identification for PWD new hires into leadership positions, to assess 

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 2021 new hire data for PWD at the executive and manager 

levels. No trigger was found at the supervisor level.

Among the 290 newly-hired staff members in FY 2021 were 18 persons hired into leadership 

positions: four SOs, seven SK-17 managers, and seven supervisors below SK-17. Two of 

those 18 (11.11%) 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 5.75% PWD, and none of the four newly-hired permanent 

executives identified as PWD.

For managers, the QAP was 18.21% PWD, and none of the seven newly-hired managers 

identified as PWD.

For supervisors, the QAP was 14.66%, and 28.57% PWD were newly-hired into the seven 

supervisory positions.
32 | AFFIRMATIVE ACTION PLAN

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

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

in the text box.

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

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

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

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

supervisor levels.

For executives, the QAP was 2.30% PWTD, and no PWTD were hired for executive 

positions in FY 2021.

For managers, the QAP was 3.51% PWTD, and no PWTD were hired for manager positions 

in FY 2021.

For supervisors, the QAP was 3.23% PWTD, and no PWTD were hired for supervisor 

positions in FY 2021.
FISCAL YEAR 2021 | 33

SECTION V: PLAN TO IMPROVE RETENTION OF PERSONS 

WITH DISABILITIES 

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

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

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

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

accommodation program and workplace personal assistance services.

Voluntary and Involuntary Separations

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

into the competitive service after two years of satisfactory service (5 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 2021, one employee was converted to the competitive service

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

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

appointment that was processed within the past two years. Five employees hired in FY 2020 

or FY 2021 are serving on an initial Schedule A appointment that has not reached the twoyear threshold. One employee accepted a new Schedule A appointment in FY 2021. Three 

staff members were newly-hired under Schedule A during FY 2021. 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 2021, confirms that all were converted to the competitive service within 

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

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

a. Voluntary Separations (PWD) Yes X No 0

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 had a trigger for voluntary separations in FY 2021. The inclusion rate on 

voluntary separations was 7.36% for PWD, and 4.42% for persons with no disability. The

largest contributor to this difference, and the only separation type in which there was at least 

a one percent difference relative to persons with no disability, was retirements (3.81% PWD; 

1.94% persons with no disability).

The inclusion rate on involuntary separations was zero (0.00%) among permanent 

employees for both PWD and persons with no disability.

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

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

the trigger below.

a. Voluntary Separations (PWTD) Yes X No 0

b. Involuntary Separations (PWTD) Yes 0 No X

The inclusion rates were calculated as the number of PWTD who separated among all 

PWTD in the workforce, compared to that same proportion among persons with no targeted 

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

those with a disability that is not targeted).

The Agency had a trigger for voluntary separations in FY 2021. The inclusion rate on 

voluntary separations was 8.75% for PWTD, and 4.61% for persons with no targeted 

disability. The largest contributor to this difference, and the only separation type in which

there was at least a one percent difference relative to persons with no targeted disability, was 

retirements (6.25% PWTD; 2.03% persons with no targeted disability).

The inclusion rate on involuntary separations was zero (0.00%) among permanent 

employees for both PWTD and persons with no targeted disability.
FISCAL YEAR 2021 | 35

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

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

The SEC invites all departing employees to complete an exit survey during their last pay period on SEC rolls. This survey asks exiting employees to self-identify if they have a disability 

and whether or not an accommodation was needed or provided. Among 107 employees who 

completed the exit survey in FY 2021, 13 self-identified as having a disability (or 12%)—and 

five of the 13 employees reported that they were provided reasonable accommodation.

In FY 2021, 63% of exit survey respondents who separated and reported a disability indicated they left the SEC due to retirement. No other separation type demonstrated a trigger.

Of them, the most commonly cited primary reason for their departure was eligibility for 

retirement (30.77%, four employees). However, two employees (15.38%) cited promotional opportunities, and another two (15.38%) cited their relationship with their supervisor 

or team lead. Of the remainder, one retiree cited the Agency’s voluntary early retirement 

incentive, one cited pay/compensation, one cited personal circumstances, one cited a career 

opportunity, and one selected “other.”

Of note, departing employees who self-identified as having a disability provided mixed 

results when responding to items on the exit survey related to diversity and inclusion when 

compared to employees who did not report a disability: 63.2% agreed that their workgroup 

was open to diverse viewpoints and backgrounds (compared to 73.7% of employees who 

did not report a disability); 73.7% agreed that their supervisor/team lead treated them 

with respect (versus 85.1%); and 52.7% agreed their co-workers fostered a cohesive work 

environment (versus 86.5%). However, 73.7% of persons with disabilities agreed policies 

and programs promoted diversity in the workplace (versus 64.9% of persons without 

disabilities). The results of the exit survey suggest employees who separated and indicated a 

disability were less satisfied with certain organizational culture issues surrounding diversity 

and inclusion than they were with SEC policies and programs on diversity and inclusion.

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

the exit survey limits the ability to generalize to the broader population about the reasons why 

employees with disabilities leave the Agency.
36 | AFFIRMATIVE ACTION PLAN

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

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

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

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

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

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

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

In FY 2021, the SEC updated the Accessibility page of SEC.gov with applicable complaintfiling 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. The 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 were finalized in FY 2021 and posted on SEC.gov.

Continued on the next page
FISCAL YEAR 2021 | 37

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

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

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

dedicated resources, testing tools, documented test processes, and a remediation process.

The majority of ICT products and tools are tested before they are deployed. If a product 

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

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

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

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/sec-disability-programs-overview). 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 posts information on how to file an EEO complaint under, inter alia, Section 

501 of the Rehabilitation Act at SEC.gov/eeoinfo/eeocomplaints.htm.

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

employees’ and applicants’ rights under the Architectural Barriers Act, including a description 

of how to file a complaint.

Information is posted on SEC.gov: SEC.gov/disability/sec_access.htm. This page contains the 

required notice explaining employees’ and applicants’ rights under the Architectural Barriers 

Act, including how to file a complaint alleging violations of the Architectural Barriers Act.
38 | 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 ICT is 

accessible to internal and external parties, as mandated by the Rehabilitation Act of 1973.

The Agency’s testing and validation process includes dedicated resources, testing tools, 

documented test processes, and a remediation process. The majority of ICT products and 

tools are tested before they are deployed. Upon completion of testing, project teams are 

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

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

508-compliant.

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

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

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

information technologies accessible to all parties.

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

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

508 Complaint Procedures related to accessibility of IT programs and services.

Reasonable Accommodation Program

Pursuant to 29 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.)

In FY 2021, the SEC met its goal of processing 100% of accommodation requests within 

20 business days, the timeframe specified in the Agency’s policy and previously approved by 

the EEOC. This reflects an improvement of 15 percentage points from FY 2020 when the 

Agency timely processed 85% of reasonable accommodation requests.
FISCAL YEAR 2021 | 39

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.

Starting in FY 2019 and throughout FY 2021, the SEC conducted an internal review 

of the SEC Reasonable Accommodation Regulation (SECR 6-80) and SEC Reasonable 

Accommodation Operating Procedures (SECOP 6-80) by collecting input from SEC 

stakeholders and negotiations with the SEC’s union. Subsequently, the SEC revised the 

reasonable accommodation policy and procedures and, as required by regulation and the 

Equal Employment Opportunity Commission, submitted the draft procedures to the EEOC 

for approval. In March 2021, the EEOC approved the draft procedures, which included a 

revised timeframe to process requests for accommodation—from 20 business days to 45 

business days—absent undue hardship. The SEC intends to publish in FY 2022 the revised 

RA policy and operating procedures.

These policy and operating procedure documents ensure that employees and applicants 

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

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

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

operational guidance further explains stakeholder responsibilities for the provision of 

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

requests are processed and includes information about the interactive process, and, how 

requestors may seek review of decisions when a request has been denied. 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, as required under the Section 501 Affirmative 

Action Regulations and its internal interactive portal AskHR in 2022.AskHR provides 

employees with information about reasonable accommodation and the processes for making 

requests. 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.

Changes to RA procedures will likely necessitate updates to training, job aids, notices, and 

other information sources in FY 2022 and beyond. Once the program guidance is finalized 

and implemented, manager/supervisors, employees, and all staff with responsibilities 

under these procedures will be informed of the updates. The updated RA procedures 

will be incorporated in the mandatory New Supervisors and New Employee trainings, 

and the on-demand trainings available in the SEC’s LEAP training platform that will be 

made available to Agency employees. At least annually, an announcement goes out to 

the workforce regarding the reasonable accommodation program to assist managers and 

employees in their understanding of the SEC’s disability accommodation program.

Continued on the next page
40 | AFFIRMATIVE ACTION PLAN

The SEC provides temporary assistance 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 through the SEC 

Temporary Medical Telework (TMT) Program. Since the SEC continued its maximum 

telework posture throughout FY 2021, the RA Program Office did not receive any TMT 

requests to process during this time period. The Agency intends to publish the revised TMT 

policy and related operational procedures in CY 2022.

In FY 2021, the SEC 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 an in-depth overview for 

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

information during the New Employee Orientation and CLTD 307 Fundamentals of 

Human Resources Management course offered by the SEC University’s College of Leadership 

and Team Development.

The SEC also conducted two virtual CLTD 307 trainings in addition to the course’s eLearning modules which provides real-time, scenario-based specific illustrations for supervisors 

and managers to heighten their awareness of the: (1) Schedule A hiring authority; (2) SEC’s 

RA Program; (3) TMT to ensure their awareness of their role in hiring and retaining employees with temporary or permanent disabilities; (4) types of requests made by employees 

with disabilities; and (5) roles and responsibilities with respect to the Agency’s Reasonable 

Accommodation Program. This training was enhanced by the Reasonable Accommodation 

Program Office to ensure awareness of the SEC’s RA Program process and related program 

guidance and regulations under the Rehabilitation Act of 1973 in the pandemic virtual environment. In-depth, situation-specific training was provided as-needed to individual managers who supervise employees with disabilities. Additional information about CLTD 307 is 

provided earlier in this report, supra.

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

employees and managers through the Agency’s learning platform, LEAP, which provides 

an effective overview of the Rehabilitation Act and the federal and SEC reasonable accommodation process.

Year over year, the Agency continues to improve upon current business practices to ensure all 

information technology is accessible to internal and external parties, as mandated by Section 

508 of the Rehabilitation Act of 1973. In late FY 2021, the SEC (through the collaborative

Continued on the next page
FISCAL YEAR 2021 | 41

efforts of OEEO, OMWI, OHR, and the Disability Interests Advisory Committee) 

established a dedicated adaptive technology support contractor to increase assistive 

technology access and aid in the advancement of innovative approaches and accessible 

solutions for persons with disabilities seeking assistance as a reasonable accommodation.

This will provide consistent, dedicated, and timely support for information technology 

accessibility to the PWD and PWTD communities. Additionally, the Agency continues to 

ensure that physical work environments remain compliant with procedures under Section 

504 of the Rehabilitation Action and the Architectural Barriers Act. Updates include an 

explanation of the Rehabilitation Act and Architectural Barriers Act, informal processes for 

providing feedback about accessibility of SEC facilities and technology, contact information 

and specific complaint processes for filing a formal claim related to accessibility, and 

additional resources for individuals to learn more. The SEC’s Administrative Regulation 

and Operating Procedures setting forth the complaint process related to Sections 504 and 

508 and the Architectural Barriers Act were finalized and published on the SEC intranet on 

April 6, 2021, and on SEC.gov.

The SEC implemented a new five-year contract vehicle with Deaf Access Solutions (DAS) for 

its Sign Language Interpretation Program in FY 2021. DAS provides enhanced interpretation 

solutions to include Communication Access Realtime Translation and Federal Relay Service 

to provide a more diverse pool of interpreters who can provide a greater array of support 

services for the Deaf/Hard-of-Hearing community.

Meanwhile, the Agency procured a new reasonable accommodation program case management solution as a repository for case information and report generation. The case 

management system will complement the Agency’s reasonable accommodation process and 

requirements in terms of system functionality, adaptability, and accessibility. The implementation of the system is expected to simplify case tracking, help identify any 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 were expected to 

be completed in CY 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 to be completed in 

calendar year 2022.

In the interim, 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 in 2022.
42 | AFFIRMATIVE ACTION PLAN

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.

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

6-80 Reasonable Accommodation Operating Procedures includes information regarding the process for requesting PAS, the process for determining whether such services are required, and the 

process for denying PAS requests when it would pose an undue hardship to the Agency. 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 2021, 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.

During FY 2021, the Agency conducted general training for managers and supervisors on the 

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

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

places them on notice of the need for reasonable accommodation. New managers and supervisors are required to attend scheduled training to obtain in-depth overview for the provision of 

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

New Employee Orientation and through the College of Leadership & Team Development Fundamentals of Human Resources Management course offered by the Agency’s learning office, SEC 

University. The CLTD 307 training provides real-time, scenario-based specific illustrations for 

supervisors and managers to heighten awareness about the RA Program, details general characteristics of available accommodations typically requested by employees with disabilities (e.g., PAS) 

and clarifies assumptions about roles and responsibilities with respect to the Agency’s reasonable 

accommodation program. Moreover, refresher training course offerings are readily available 

for employees and managers through the Agency’s SECU learning platform LEAP; the training 

provides an effective overview of the Rehabilitation Act, Americans with Disabilities Act, and the 

federal and SEC reasonable accommodation process.
FISCAL YEAR 2021 | 43

SECTION VI: EEO COMPLAINT AND FINDINGS DATA

EEO Complaint Data Involving Harassment

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

harassment, as compared to the government-wide average? 

Yes 0 No X N/A 0

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

in a finding of discrimination or a settlement agreement?

Yes 0 No X N/A 0

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

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

During FY 2021, the Agency did not have any findings of discrimination alleging harassment 

based on disability status.

EEO Complaint Data Involving Reasonable Accommodation

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

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

Yes 0 No X N/A 0

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

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

Yes X No 0 N/A 0

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

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

taken by the Agency.

During FY 2021, the Agency did not have any findings of discrimination involving the failure 

to provide reasonable accommodation. Two 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.

Not applicable for the FY 2021 reporting period.
FISCAL YEAR 2021 | 45

TABLE B1: TOTAL WORKFORCE—DISTRIBUTION BY DISABILITY [OPM FORM 256 SELF-IDENTIFICAPAY PERIODS 202022 TO 202122

EMPLOYMENT 

TENURE

TOTAL

No Disability [05]

Not Identified [01]

Disability 

[02-03, 06-99]

Other PWD

1

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]

TOTAL WORKFORCEPrior FY

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

Current FY

# 4,536 3,904 227 344 61 405 81 0 1 36 7 3 5 6 4 % 100% 86.07% 5.00% 7.58% 1.34% 8.93% 1.79% 0.00% 0.02% 0.79% 0.15% 0.07% 0.11% 0.13% 0.09% 0

Difference # 43 25 4 1 13 14 -5 0 0 -2 0 0 0 0 1 Ratio Change % 0.00% -0.26% 0.04% -0.05% 0.27% 0.23% -0.12% 0.00% 0.00% -0.06% -0.01% 0.00% 0.00% 0.00% 0.02% 0Net Change % 0.96% 0.64% 1.79% 0.29% 27.08% 3.58% -5.81% 0.00% 0.00% -5.26% 0.00% 0.00% 0.00% 0.00% 33.33% 0

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 servic

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

Note: Total calculations shown may not match that derived from detail data presented due to rounding.Source: Datamart FPPS and EEO-AT 2.0 Analytic File for pay period 202122, downloaded on 11/12/2021
46 | AFFIRMATIVE ACTION PLAN TABLE B1: TOTAL WORKFORCE—DISTRIBUTION BY DISABILITY [OPM FORM 256 SELF-IDENTIFICA

PAY PERIODS 202022 TO 202122 continued

EMPLOYMENT 

TENURE

TOTAL

No Disability [05]

Not Identified [01]

Disability 

[02-03, 06-99]

Other PWD1

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]

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

Current FY # 4,423 3,813 216 336 58 394 80 0 1 36 7 3 5 6 3 

% 100% 86.21% 4.88% 7.60% 1.31% 8.91% 1.81% 0.00% 0.02% 0.81% 0.16% 0.07% 0.11% 0.14% 0.07% 0

Difference # 34 27 -3 -2 12 10 -5 0 0 -2 0 0 0 0 0 Ratio Change

% 0.00% -0.05% -0.11% -0.10% 0.26% 0.16% -0.13% 0.00% 0.00% -0.06% 0.00% 0.00% 0.00% 0.00% 0.00% 0

Net Change

% 0.77% 0.71% -1.37% -0.59% 26.09% 2.60% -5.88% 0.00% 0.00% -5.26% 0.00% 0.00% 0.00% 0.00% 0.00% 0

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 servic

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

Note: Total calculations shown may not match that derived from detail data presented due to rounding.Source: Datamart FPPS and EEO-AT 2.0 Analytic File for pay period 202122, downloaded on 11/12/2021
FISCAL YEAR 2021 | 47

TABLE B1: TOTAL WORKFORCE—DISTRIBUTION BY DISABILITY [OPM FORM 256 SELF-IDENTIFICAPAY PERIODS 202022 TO 202122 continued

EMPLOYMENT 

TENURE

TOTAL

No Disability [05]

Not Identified [01]

Disability 

[02-03, 06-99]

Other PWD

1

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]

TEMPORARYPrior FY

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

Current FY

# 113 91 11 8 3 11 1 0 0 0 0 0 0 0 1 % 100% 80.53% 9.73% 7.08% 2.65% 9.73% 0.88% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.88% 0

Difference # 9 -2 7 3 1 4 0 0 0 0 0 0 0 0 1 Ratio Change % 0.00% -8.89% 5.88% 2.27% 0.73% 3.00% -0.08% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.88% 0Net Change % 8.65% -2.15% 175.00% 60.00% 50.00% 57.14% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0

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 servic

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

Note: Total calculations shown may not match that derived from detail data presented due to rounding.Source: Datamart FPPS and EEO-AT 2.0 Analytic File for pay period 202122, downloaded on 11/12/2021
48 | AFFIRMATIVE ACTION PLAN TABLE B1: TOTAL WORKFORCE—DISTRIBUTION BY DISABILITY [OPM FORM 256 SELF-IDENTIFICA

PAY PERIODS 202022 TO 202122 continued

EMPLOYMENT 

TENURE

TOTAL

No Disability [05]

Not Identified [01]

Disability 

[02-03, 06-99]

Other PWD1

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 

SCHEDULE A EMPLOYEES IN THE PERMANENT WORKFORCE2Prior FY # 7 0 0 7 0 7 3 0 0 1 0 0 0 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% 

Current FY # 10 0 0 8 2 10 1 0 0 0 0 0 0 0 0 

% 100% 0.00% 0.00% 80.00% 20.00% 100% 10.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 

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

% 0.00% 0.00% 0.00% -20.00% 20.00% 0.00% -32.86% 0.00% 0.00% -14.29% 0.00% 0.00% 0.00% 0.00% 0.00% 

Net Change

% 42.86% 0.00% 0.00% 14.29% 0.00% 42.86% -66.67% 0.00% 0.00% -100.00% 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 servic

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 PermNote: 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 202122, downloaded on 11/12/2021

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