U.S. SECURITIES AND 

EXCHANGE COMMISSION

FISCAL YEAR 2018

EQUAL EMPLOYMENT 

OPPORTUNITY

AFFIRMATIVE ACTION PLAN FOR THE 

RECRUITMENT, HIRING, ADVANCEMENT, AND 

RETENTION OF PERSONS WITH DISABILITIES

FISCAL YEAR 2018 | iii

CONTENTS

AFFIRMATIVE ACTION 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..

Plan to Ensure Sufficient Funding for the Disability Program .

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

Plan to Identify Job Applicants with Disabilities .

Plan to Establish Contacts with Disability Employment Organizations .

Progression Towards Goals (Recruitment and Hiring) 10

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

Advancement Program Plan 15

Career Development Opportunities 16

Awards 20

Promotions .

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

Voluntary and Involuntary Separations 32

Accessibility of Technology and Facilities 35

Reasonable Accommodation Program .

Personal Assistance Services Allowing Employees to Participate in the Workplace .

Section VI: EEO Complaint and Findings Data .

EEO Complaint Data Involving Harassment 41

EEO Complaint Data Involving Reasonable Accommodation 42

Section VII: Identification and Removal of Barriers .

Prepared by

THE OFFICE OF EQUAL EMPLOYMENT OPPORTUNITY
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FISCAL YEAR 2018 | 1

AFFIRMATIVE ACTION 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 requ

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

of applicants and employees with disabilities

SECTION I: EFFORTS TO REACH REGULATORY GOALS

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

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

federal government

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

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

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

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

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

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

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

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

FY 2018, that salary was $68,036. Participation of PWD and PWTD are presented to assess

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

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

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

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

Continued on the next page
2 | EEO A FFIRMATIVE ACTION PLAN

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

for PWD participation; 35.00% of employees in this cluster were PWD compared to the

12% benchmark

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

achieve the numerical goal involving PWD; 8.64% 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 2.29 percentage points since the end of FY 201

In FY 2018, SEC implemented plans to include permanent and temporary employees hired 

under authorities that take disability into account as PWD pursuant to EEOC regulation

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

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

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

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

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

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

213.3102(u) Appointment of persons with intellectual disabilities, severe physical disabilities,

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

utilization analysis. This action added 40 permanent employees to the PWD workforce data;

39 in the higher salary cluster, and one in the lower salary cluster. Prior year data for such

employees was updated for comparison

As described in Section VII below, the Agency has conducted an annual resurvey of the 

workforce since FY 2015. Data show steady increase in self-identification among employees

after each annual resurvey. Trend data also show positive impact from the changes made to

SF-256 in October 2016 and again from the more inclusive definition described above related 

to Section 501 of the Rehabilitation Act. Between FY 2015 and FY 2018, the participation of

PWD in the total workforce increased from 6.57% to 8.76%, participation increased in bot

the lower and higher salary clusters
FISCAL YEAR 2018 | 3

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

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

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

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

Applying the same salary clusters to PWTD as described in Section I, the SEC achieved the 

numerical goals established for PWTD in both the lower and higher salary clusters during 

FY 2018. In the lower salary cluster, 5.00% of permanent employees are PWTD; 2.01% 

higher salaried employees are PWTD

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

and/or recruiters

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

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. The overall percentage of employees who identify as

PWTD is posted in the Diversity Dashboard sponsored by OMWI and the Diversity Council

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

Analytics (HCRA) dashboard in the second half of FY 2018. 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 plans to use this information to support Human Capital strategic planning efforts

Throughout FY 2018 and particularly during National Disability Employment Awareness Month, 

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 Issues Advisory Committee 

(DIAC). In opening and/or closing remarks, leaders noted the Agency’s goals for recruiting and

hiring PWD, frequently mentioning the high value such employees bring to the Agency’s mission

Relatedly, OHR has developed a 2018–2019 Recruitment Strategy, which describes the 

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

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

n Build a pipeline of qualified Schedule A applicants; and

n Improve Veteran recruitment efforts

Continued on the next page
4 | EEO A FFIRMATIVE ACTION PLAN

The Recruitment Strategy specifically denotes an objective to “Increase workforce 

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

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

accomplished

For specific 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 greater

Beginning in July 2018, OEEO led periodic meetings with a cross-functional working group 

comprised of representatives from OHR and OMWI, including those who support recruiting, 

to discuss the Management Directive 715 Report and the Agency’s progress related to equal 

employment opportunity, participation, and inclusion of employees and applicants for 

employment. For these meetings, OEEO provided up-to-date information from the Agency

workforce data tables and highlighted areas for discussion, including goals and progress 

related to the participation and inclusion of PWD and PWTD

SECTION II: MODEL DISABILITY PROGRAM

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

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 designates talent acquisition resources and FTE to Special Programs classification, 

recruitment, and staffing in support of the disability program
FISCAL YEAR 2018 | 5

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

office, staff employment status, and responsible official

Disability Program Task

Number of Full-Time Equivalent Staff by 

Employment Status

Responsible Official

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

Collateral 

Duty

Processing applications from PWD 

and PWTD

12 0 0 Stephen Brown, Assistant Director, Office 

of Human Resources, brownst@sec.gov

Answering questions from the public 

about hiring authorities that take 

disability into account

12 0 0 Stephen Brown, Assistant Director, Office 

of Human Resources, brownst@sec.gov

Processing reasonable 

accommodation requests from 

applicants and employees

2 1 0 Dia Gonsalves, Disability Program Officer, 

Office of Human Resources, 

gonsalvesd@sec.gov

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

Office of Information Technology,

jonessh@sec.gov

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

Support Operations (OSO)-Office of Building 

Operations (OBO), FerrariR@sec.gov; 

Jillian Bates, RA, LEED AP, Architect, 

OSO-OBO; 

Carla Hairston, Program Analyst, OSO-OBO

HairstonC@sec.gov

Special Emphasis Program for PWD 

and PWTD

2 0 0 Stephen Brown, Assistant Director, Office 

of Human Resources, brownst@sec.gov

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

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

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

Yes X No 0

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

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

reasonable accommodation programs and the responsibilities inherent in responding to 

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

Program Officer and departing Reasonable Accommodation Coordinator and periodically 

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

developments in this area. Additionally, the Disability Program Officer, representing the half

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

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

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

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

general training received

Continued on the next page
6 | EEO A FFIRMATIVE ACTION PLAN

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

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

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

options that include processing applications for PWD. 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 on related policy and procedure post implementation for both HR specialists 

and disability program staff

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 implement the disability 

program successfully
FISCAL YEAR 2018 | 7

SECTION III: PLAN TO RECRUIT AND HIRE INDIVIDUALS WITH 

DISABILITIES

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

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

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

Plan to Identify Job Applicants with Disabilities

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

including individuals with targeted disabilities

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

applicant pools. As outlined in OHR’s 2018–2019 Recruitment Strategy, the SEC will begin

to realize an increase in the overall representation of people with disabilities by using effective 

recruitment and outreach efforts that identify the Agency as an employer of choice

The SEC hosted its third annual Informational and Networking Event for Individuals with 

Disabilities at SEC Headquarters. This event continues to prove successful in building a

pipeline of applicants for future vacancies. Through this event, the SEC is able to reinforce its

commitment to becoming a model employer for PWD by providing guests the opportunity 

to learn more about the SEC’s mission, hear about the Agency’s benefits and reasonable 

accommodations, and network with SEC hiring managers

Despite limited hiring in FY 2018, the Agency maintained a physical recruitment presence

SEC attended over 17 career fairs and events supporting efforts in building pipelines for future 

employment. Most notably, it attended the AmeriCorps Vista Career Fair and the Bowie State

University Veterans Career Fair, which both proved to be successful resources for attracting 

potential candidates. These events allowed the SEC to reach a key constituency and promote a

variety of positions

In FY 2019, the SEC will introduce a more direct and streamlined approach in encouraging 

hiring managers to utilize the Schedule A hiring authority. OHR will present prospective

candidates to every hiring manager seeking to fill vacant positions externally prior to initiating 

general hiring procedures. OHR believes this approach is a win-win for all stakeholders by

providing an opportunity for prospective candidates to be considered first-hand by hiring 

managers and potentially shortening an often lengthy hiring process

OHR will continue to leverage the DIAC for recruitment resources and assistance. Further,

OHR will continue to retain and review applications from people with disabilities for 

future openings and will conduct targeted outreach to connect with qualified candidates by 

collaborating with community-based partners such as nonprofit organizations, national and 

local disability organizations, and federally funded state and local employment programs
8 | EEO A FFIRMATIVE ACTION PLAN

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

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

permanent workforce

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

and other hiring authorities that take disability into account. During FY 2018, the Special

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

OPM’s Shared List of People with Disabilities and the Workforce Recruitment Program

The Special Programs Manager receives notifications and newsletters from the following 

groups and transmits information to OHR staff engaged in recruiting:

n EARN—Employer Assistance Resource Network: askearn.or

n JAN—Job Accommodation Network: askjan.or

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

dol.gov/agencies/ode

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 fo

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

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

Opportunity Announcement (JOA).

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

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

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

HR specialists to determine if the applicant is minimally qualified as identified in the JOA. If the

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

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

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

Continued on the next page
FISCAL YEAR 2018 | 9

The Office of Human Resources also processes unsolicited Schedule A applications. 

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

for a specific vacancy posting, must submit the appropriate documentation as identified by OPM 

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

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

processed until the appropriate documentation is received

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

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

identified on the applicant’s resume. Building a pool of qualified candidates is important to the

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

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

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

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

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

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

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

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

administrative regulations are available upon request

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

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

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

Yes X No 0 N/A 0

OHR developed a 2018–2019 Recruitment Strategy, which describes the Agency’s 

commitment to educating the SEC workforce on special programs for people with disabilities

In addition, OHR and DIAC co-sponsored a Disability Resources Showcase in which all SEC 

employees, including hiring managers, were invited to learn about several disability resources, 

including the Schedule A hiring authority

In FY 2018, periodic training occurred with each hiring manager who requested to fill a 

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

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

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

of action where applicable

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

basis on a variety of topics, including the hiring authorities that take disability into account
10 | EEO A FFIRMATIVE ACTION PLAN

Plan to Establish Contacts with Disability Employment Organizations

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

PWD, including PWTD, in securing and maintaining employment

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

14 organizations that assist PWD in securing and maintaining employment. The Special

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

foster relationships for recruitment events and candidate sourcing

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

the Veterans Committee

In an effort to expand outreach, the SEC piloted the Operation Warfighter Program 

(OWF) during FY 2018. OWF is an internship program created by the Department of

Defense that matches qualified wounded, ill, and injured service members with nonfunded federal internships for them to gain valuable work experience during recovery and 

rehabilitation. SEC is finalizing program policies and procedures and plans to implement

Agency-wide in FY 2019

Progression Towards Goals (Recruitment and Hiring) 

1.Using the goals of 12% for PWD and 2% for PWTD as the benchmarks, do triggers exist for

PWD and/or PWTD among the new hires in the permanent workforce? If “yes”, please describe 

the triggers below

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

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

Hiring Data from FY 2018 were reviewed for evidence of differences in hiring into the 

permanent workforce. In FY 2018, the participation rate for both PWD and PWTD was

8.33%. [Redacted to protect privacy

From these data, the Agency did not achieve a 12% participation rate for PWD among new 

hires in the permanent workforce. In FY 2018, the participation of PWD among permanent

new hires was 8.33

The Agency achieved the numerical goal of 2% participation of PWTD among permanent new 

hires. In FY 2018, the participation of PWTD among permanent new hires was 8.3

The hiring freeze at SEC, implemented early in FY 2017 and continuing through most of FY 

2018, impacted hiring and affected efforts toward increasing the participation of PWD
FISCAL YEAR 2018 | 11

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

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

the triggers below

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

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

FY 2018 data were reviewed for evidence of triggers in the hiring of permanent employees 

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

for three out of five of the MCO positions, accountant, IT management, and economist

PWD were found in the qualified applicant pools for attorneys and securities compliance 

examiners; qualified applicants for attorney also included PWTD. In FY 2018, the SEC

hired relatively few permanent employees, a total of 24 permanent staff employees. Among

these newly hired staff members were 19 persons in MCO positions, nine attorneys, nine IT 

management specialists, and one economist. Two of those 19 (10.53%) newly hired MC

permanent staff were both PWD and PWTD

At the same time, the limited number of qualified PWD and PWTD applicants did not 

result in differences when comparing qualified applicants to permanent new hires in any 

of the Agency’s MCOs. No triggers were found for PWD or PWTD when comparing their

participation among permanent new hires to the qualified applicants pools (QAP) for 

attorney, accountant, securities compliance examiner, IT management, or economist positions

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

occupation was compared to the qualified applicant pool (QAP). The applicant flow data

summarizes the phases of the hiring process through selection for vacancies that were posted 

and closed through USAJOBS during the fiscal year. The data summarized here reflect the

pool of qualified applications for permanent and/or temporary vacancies announced through 

USAJOBS during FY 2018

In contrast, permanent new hires were on boarded during the course of the fiscal year. Some

newly hired staff applied for a vacancy posted in a prior fiscal year or may have elected 

not to volunteer demographic information. Differences may be observed in comparing the

demographic statistics of the QAP and that of new hires on boarded in FY 2018. Triggers

comparing the composition of PWD and PWTD in applicant flow versus new hire data 

should be interpreted with these differences in mind

PWD represent 22.22% and PWTD were 22.22% of newly hired permanent staff attorne

That PWD and PWTD participation among new hires exceeds their participation in the QAP

For attorneys, the QAP was 1.38% PWD, and the QAP for PWTD was 0.59%. There we

12 temporary attorneys hired, and nine newly hired permanent attorneys

Continued on the next page
12 | EEO A FFIRMATIVE ACTION PLAN

None of the newly hired permanent employees in FY 2018 were accountants. There were

nine total new hires, all of whom were temporary. Similarly, none of the QAP for accountant

positions was PWD or PWTD; as such, no difference in participation was observed. For

securities compliance examiner vacancies posted in FY 2018, the QAP was 2.78% PWD and

0.00% PWTD. No permanent staff securities compliance examiners were hired in FY 2018

therefore, there was a difference observed between available PWD in the QAP compared to 

those hired. There was no opportunity to observe a difference in participation among newly

hired staff and the QAP for PWTD

For IT management, nine employees were hired as permanent staff in FY 2018. The QAP was

0.00% for both PWD and PWTD, and none (0.00%) of the newly hired staff were PWD o

PWTD. No difference is observed in these data; participation in the QAP equaled that among

newly hired IT management staff

Finally, for economists, the QAP was 0.00% for PWD and PWTD because no vacancies were

available in applicant flow for economist hiring. There was one permanent new hire, who did

not identify as PWD or PWTD. Four temporary economists were also hired. No differenc

was observed in the participation of PWD or PWTD between the QAP and newly hired 

permanent staff economist

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

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

“yes”, please describe the triggers below

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

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

In the FY 2018 data, differences were identified in the participation of PWD in the 

qualified internal applicants for competitive promotions as compared to the relevant 

applicant pool (RAP) within three of the SEC’s MCOs, i.e., attorney, securities complianc

examiner, and economist. Differences were also identified for PWTD within the internal

competitive promotion data for the MCOs attorney, accountant, securities compliance 

examiner, and IT management

Continued on the next page
FISCAL YEAR 2018 | 13

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 RAP for PWD was 5.25%, and PWD represented 4.27% of the qualifie

internal applicants. The RAP for PWTD was 1.25%, and PWTD were 0.95% of the qualifi

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

and the qualified applicants for attorney internal promotions of PWTD

For accountants, the RAP for PWD was 5.81%, and PWD were 9.09% of the qualifie

internal applicants. Participation of PWD exceeded the RAP for accountants. However

participation on PWTD was lower among the qualified internal applicants than available in 

the RAP for accountants. The RAP for PWTD was 1.01%, and none of the qualified interna

applicants were PWTD (0.00%

For securities compliance examiners, the RAP for PWD was 8.92%, and PWD represented

4.65% of the qualified internal applicants. The RAP for PWTD was 1.54%, and PWTD we

0.00% of the qualified internal applicant

For IT management, the RAP for PWD was 11.48%, and PWD represented 15.38% of th

qualified internal applicants. The RAP for PWTD was 0.74%, and PWTD represented 0.0

of the qualified internal applicants. Relatively larger differences in participation were observed

for both the IT management and securities compliance examiner data compared to the other 

MCOs, especially for PWD

For economists, the RAP was 1.32% for PWD, and none (0.00%) of the qualified interna

applicants were PWD. No PWTD were found in either the RAP or the qualified internal

applicant pool; therefore, no difference was found in the participation of PWTD
14 | EEO A FFIRMATIVE ACTION PLAN

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

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

describe the triggers below

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

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

In the FY 2018 data for internal competitive promotions in MCOs, 4.17% were PW

[Redacted to protect privacy.] In reviewing these data further, a difference was observed when 

comparing participation of PWD among those selected for promotion with their participation 

among the qualified internal applicant pool (QAP) in the attorney, securities compliance 

examiner, and IT management occupations

For PWTD, no participation differences were found, except that for attorneys, PWTD 

participation among those selected for promotion exceeded the QAP. For accountants,

securities compliance examiners, IT management, and economists, no PWTD were available 

in the QAP, and none were selected for promotion

In the attorney occupation, the QAP for PWD was 4.27%, and a smaller proportion, 1.54%

of those promoted were PWD. The attorney QAP for PWTD was 0.95%, and a large

proportion, 1.54%, of those promoted were PWT

The participation of PWD and PWTD among those promoted to accountant positions 

exceeded or equaled their respective QAP. In the accountant occupation, the QAP for PWD

was 9.09% and 0.00% for PWTD. Of the accountants promoted, 14.29% were PWD; n

were PWTD. [Redacted to protect privacy.

In the securities compliance examiner occupation, the QAP for PWD was 4.65% and 0.00

PWTD. None of the employees selected for promotion were PWD or PWTD. [Redacted t

protect privacy.]

In the IT management occupation, the QAP was 15.38% for PWD, and 14.29% of th

selections were PWD. The QAP for PWTD was 0.00%, and 0.00% of selections were P

[Redacted to protect privacy.]

In the economist occupation, neither PWD nor PWTD were found in the QAP, and none were 

selected. There were two selections for economist promotio
FISCAL YEAR 2018 | 15

SECTION IV: PLAN TO ENSURE ADVANCEMENT OPPORTUNITIES FOR 

EMPLOYEES WITH DISABILITIES

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

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, including PWD and 

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

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

to promote opportunities for advancement

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

intranet, which provides employees with information about hiring, compensation 

and benefits, employee development, performance management, and disability 

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

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

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

n The Chief Human Capital Officer 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
16 | EEO A FFIRMATIVE ACTION PLAN

Career Development Opportunities

1. Please describe the career development opportunities that the agency provides to its employee

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 three career 

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

captured along with other training program data in Section IV.2.b bel

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

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

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

participate in this leadership development program. Program participants from across

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

senior leadership success while maintaining authenticity and balance

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

the leadership skills of experienced federal employees through a combination of 

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

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

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

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

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

performance, workplace relationships, and productivity

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

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

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

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

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

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

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

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

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

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

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

Continued on the next page
FISCAL YEAR 2018 | 17

them to progress toward their career goals. SECU established initial career paths in FY 2017

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

2018, OHR and SECU also:

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

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

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

continued into the new fiscal year. The data gleaned from the competency survey will be

used to enhance the value of the new LEAP career path options

n Expanded offerings under the Career Horizons program that provide individualized 

support for employees in creating development plans and pursuing career growth

The Agency supports employees in pursuing leadership development through a variety of 

program offerings, including both individual coaching and a new pilot mentoring program

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

coach. Coaching with an internal certified executive coach is not tracked, nor is demographic

information captured, due to confidentiality

Late in FY 2017, OHR conducted a Leadership Interest Survey to gather data from all SK-15 

and SK-17 managers. Survey data from SEC management staff were analyzed in early FY

2018 to inform SECU’s leadership development offerings going forward. Additionally, OHR’s

Human Capital Strategy Group began a long term, multi-year planning effort for a leadership 

development program similar to the SES Candidate Development Programs offered by other 

federal agencies

Relatedly, in summer 2018, the Agency successfully launched a pilot mentoring program 

leading to the first cohort of 30 participants who will receive mentoring throughout FY 2019

In total, 142 permanent employees submitted a statement of interest in the program. On a

first come, first serve basis, 30 participants were accepted into the mentoring program and 

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

Employees, who expressed interest in the program who were not matched with mentors for 

this program offering were placed on a wait list for a future program offerings. The SEC

held an orientation session for both mentors and participants, and will hold formal events 

throughout FY 2019 to help guide the mentoring relationship toward success

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

provided below
18 | EEO A FFIRMATIVE ACTION PLAN

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

competition and/or supervisory recommendation/approval to participate

Career Development Opportunities1

Total Participants PWD PWTD

Applicants 

(#)

Selectees 

(#)

Applicants 

(%)

Selectees 

(%)

Applicants 

(%)

Selectees 

(%)

Internship Programs 0 0 0.00% 0.00% 0.00% 0.00%

Fellowship Programs 24 13 NA 0.00% NA 0.00%

Mentoring Programs 142 29 5.63% 6.90% 0.00% 0.00%

Coaching Programs NA NA NA NA NA NA

Training Programs1 27,050 27,050 10.69% 10.69% 2.27% 2.27%

Detail Programs NA NA NA NA NA NA

Other Career Development Programs NA NA NA NA NA NA

Notes: With more limited hiring in FY 2018, there was no recruitment or hiring of applicants for Internship programs.

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

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

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

The SECs pilot Mentoring Program was offered on a first come, first serve basis. 

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

opportunities during FY 2018. 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.

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 bo

a. Applicants (PWTD) Yes X No 0

b. Selections (PWTD) Yes 0 No X

From the Career Development Opportunities table in Section IV.B.2 above, data on th

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

were reviewed

Within the Agency’s pilot mentoring program, the Agency noted a difference in the 

participation rate among those who expressed interest in the mentoring program (i.e.

applicants) as compared to participation of PWD in the permanent workforce. While 8.76

of all permanent staff are PWD, PWD represent 5.63% of those employees who expressed

interest in the pilot mentoring program. The Agency will continue to share information about

this program through DIAC and other channels to encourage greater interest among PWD for 

future offerings

Continued on the next page
FISCAL YEAR 2018 | 19

The participation rate of 6.90% PWD among those selected to participate in the pilot

mentoring program (i.e., Selectees) exceeded their participation among those expressin

interest (5.63%). As such, no trigger was noted for the selections into the Agency’s pilo

mentoring program

Aggregate PWD participation in training programs through the Agency’s learning 

management system, LEAP, exceeds their participation on rolls; 10.69% of training

opportunities (both mandatory and elective) were completed by PWD, compared to 8.76%

of permanent employees who are PWD. PWD participation in training was higher than

that among permanent employees; this difference was statistically significant (X2 = 27.85,

p<.0001). No evidence for lower rates of participation for PWD was found in the Agency’

training program

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

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

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

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 bo

a. Applicants (PWTD) Yes X No 0

b. Selections (PWTD) Yes 0 No X

From the Career Development Opportunities table in Section IV.B.2 above, data on the participation of PWTD in various programs were reviewed for equality of employment opportunit

in the applications or selections for these programs

Within the Agency’s pilot mentoring program, the Agency notes a difference in the participation rate among those who expressed interest in the mentoring program (i.e., applicants), a

compared to PWTD among permanent staff. While 2.02% of the Agency’s permanent staff ar

PWTD, no (0.00%) PWTD expressed interest in the pilot mentoring program. The Agency wil

share information about future offerings of this program through DIAC and other channels to 

encourage greater interest among PWTD. Given that no PWTD expressed interest in the program, none were selected. No trigger was noted for selections into the mentoring progr

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

through LEAP at rates just above their participation on rolls; 2.27% of training opportunities

(both mandatory and elective) were completed by PWTD, compared to 2.02% of PWTD

permanent employees. No evidence of a trigger or significant difference was found for the

participation (i.e., selections) of PWTD in training programs da
20 | EEO A FFIRMATIVE ACTION PLAN

Awards

1.Using the inclusion rate as the benchmark, does your agency have a trigger involving PWD and/or

PWTD for any level of the time-off awards, bonuses, or other incentives? If “yes”, please describe 

the trigger(s) in the text box

a. Awards, Bonuses, & Incentives (PWD) Yes X No 0

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

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

employees with disabilities (PWD) 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 (PWTD) 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

For both PWD and PWTD, the Agency found lower inclusion rates in: time-off awards 

of nine (9) hours or more and cash awards of more than $500. No trigger was found

disadvantaging PWD or PWTD in the distribution of time-off awards less than nine (9) 

hours or cash awards of $100 to $500

For time-off awards of more than nine hours, the inclusion rate for PWD was 29.32%, and

the inclusion rate for people with no disability was 32.39%. The inclusion rate for PWT

was 23.86%, and the inclusion rate for people with no targeted disability was 32.2

For cash awards of more than $500, the inclusion rate for PWD was 40.05%, and the

inclusion rate for people with no disability was 52.58%. The inclusion rate for PWTD wa

32.95%, and the inclusion rate for people with no targeted disability was 51.8

For time-off awards of one to nine hours, the inclusions rates were: 38.22% for PWD and

37.69% for persons with no disability. The PWTD inclusion rate was 48.86% and for tho

with no targeted disability, it was 37.51%.Continued on the next pa
FISCAL YEAR 2018 | 21

For cash awards of $100 to $500, the inclusion rate for PWD was 34.29%, and the inclusion

rate for people with no disability was 25.37%; the inclusion rate for PWTD was 44.32%, an

the inclusion rate for people with no targeted disability was 25.78

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

awards as part of our barrier analysis program

2.Using the inclusion rate as the benchmark, does your agency have a trigger involving PWD and/or

PWTD for quality step increases or performance-based pay increases? If “yes”, please describe the 

trigger(s) in the text box

a. Pay Increases (PWD) Yes 0 No X

b. Pay Increases (PWTD) Yes 0 No X

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

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

EEOC instruction for presenting these data. Performance-based awards at the SEC are

also recorded under NOA Codes 885 and 886 for performance rating based lump sum 

awards. In FY 2018, a significant proportion of the employee population received lump

sum payments under NOA Code 885 and/or 886 rather than a pay increase under NOA 

Code 891

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

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

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

having a disability). No difference in performance rating based pay increases was found for

PWD. The inclusion rate for PWD was 71.20%, and for people without disabilities an

those who did not self-identify with a disability, it was 66.46

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

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

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

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

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

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

73.86%, and for people without targeted disabilities (including those with no disability,

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

targeted), it was 66.73
22 | EEO A FFIRMATIVE ACTION PLAN

3.If the agency has other types of employee recognition programs, are PWD and/or PWTD

recognized disproportionately less than employees without disabilities? (The appropriate 

benchmark is the inclusion rate.) If “yes”, describe the employee recognition program and

relevant data in the text box

a. Other Types of Recognition (PWD) Yes 0 No X N/A 0

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

In FY 2018, OEEO analyzed data from the Agency’s gift card recognition program since the 

program’s inception in late FY 2016 through FY 2017. This analysis was completed under

the barrier analysis program’s research into the distribution of discretionary cash and timeoff awards. Among all gift card recipients in this time period, 105 were PWD (12.06%), an

20 were PWTD (2.30%). This participation of PWD and PWTD in the gift card progra

exceeded their participation of permanent staff on rolls (participation rates of permanent staff 

for PWD was 8.76%, and for PWTD was 2.02

Further, inclusion of PWD (27.49%) among gift card recipients, when considered against

the total PWD permanent staff at the end of FY 2018, exceeded that of the combination 

of persons with no disability and those who did not self-identify (18.91%). Similarly th

inclusion rate for PWTD (22.73%) gift card recipients exceeded that of those with no targeted

disability (19.60%). Consistent with analyses conducted on discretionary cash and timeoff awards; lower value gift card awards were used to recognize PWD and PWTD mor

frequently than employees with no disability

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 X No 0

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
FISCAL YEAR 2018 | 23

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

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

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

though the actual RAPs for the individual SK-levels differ

FY 2018 data were reviewed to assess whether triggers exist with regard to promotions to 

senior grade levels. Of 972 qualified internal applications for senior grade level positions, 148

(15.23%) were submitted by PWD. The Agency was successful in supporting PWD in thei

interest in and application for senior grade level positions. There were no triggers identified

among qualified internal applicants to senior grades

Differences were observed among selectees for all senior grade levels. Of the promotions

to senior grade levels, 5.88% were PWD, which is lower than their availability in the

QAP at 15.23%. [Redacted to protect privacy.] The following presents data for eac

grade level equivalent

At the SO level, the RAP, comprised of all employees at grade levels SK-14 and higher, was 

6.69%, and among qualified internal applicants, a larger proportion (14.00%) were P

None of the employees selected for SO positions were PWD

At the SK-15 and SK-17 levels (GS-15 equivalent), the RAP, comprised of employees at grades 

SK-14, SK-15, and SK-16, was 6.74%, while the participation of PWD among qualified

internal applicants was greater at 15.46%. The Agency noted a difference involving interna

selections for senior grade levels at the SK-15 and SK-17 levels; 5.17% of selections were

PWD compared to their participation among qualified internal applicants at 15.46

At the SK-14 and SK-16 levels (GS-14 equivalent), the RAP, comprised of employees at 

grades SK-13, SK-14, and SK-15, was 7.94%, and the participation of PWD among qualified

internal applicants was 13.11%. On the other hand, 7.02% of selections were P

compared to 13.11% of qualified internal applicant

At the SK-13 level (GS-13 equivalent), the RAP, comprised of employees at the SK-12 level, 

was 17.89%, and the participation of PWD among qualified internal applicants was 36.6

Among selections for internal promotions at the SK-13 level, 11.11% were PWD, and

36.67% of the qualified internal applicants were PW
24 | EEO A FFIRMATIVE 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 X No 0

b. Grade GS-15

Qualified Internal Applicants (PWTD) Yes 0 No X

Internal Selections (PWTD) Yes X No 0

c. Grade GS-14

Qualified Internal Applicants (PWTD) Yes X No 0

Internal Selections (PWTD) Yes 0 No X

d. Grade GS-13

Qualified Internal Applicants (PWTD) Yes X No 0

Internal Selections (PWTD) Yes 0 No X

Applying the same comparisons to PWTD as described in Section IV.D.1, the Agency present

information on trigger identification for PWTD in promotions to senior grade levels. Of 972

qualified internal applications for senior grade level positions, 24 (2.47%) were submitted by

PWTD. Of the promotions to senior grade levels, 1.47% were PWTD. [Redacted to prote

privacy.] Overall, the Agency was successful in supporting PWTD in their interest in and 

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

selecting PWTD for those promotions

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

equivalent senior grade levels and among selectees for both the GS-15 and SES equivalent 

senior grade levels. The following presents data for each grade leve

At the SO level, the Agency notes that the RAP was 1.41% PWTD, and the participation

among qualified internal applicants of PWTD was 3.00%. Zero selections for SO position

were PWTD among the qualified internal applicants who were 3.00% PWT

At the SK-15 and SK-17 level (GS-15 equivalent), the RAP was 1.39%, and among the

qualified internal applicants, 3.54% were PWTD. For the internal selections to grade

SK-15 and SK-17, 3.54% of the qualified internal applicant pool was PWTD, and 1.72% o

selections for SK-15 or SK-17 positions were PWTD

Continued on the next page
FISCAL YEAR 2018 | 25

At the SK-14 and SK-16 level (GS-14 equivalent), the Agency observed a difference among 

qualified internal applicants. The RAP was 1.59% while 0.66% of the qualified intern

applicants were PWTD. Selections were 1.75% PWTD; therefore, no difference was foun

among selectees

At the SK-13 level (GS-13 equivalent), the Agency observed a difference involving PWTD 

among qualified internal applicants. The RAP was 5.96%, and the participation o

PWD among qualified internal applicants was 0.00%. The Agency did not have a trigge

involving internal selections. None of the qualified internal applicants were PWTD, and

none were selected

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 bo

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

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

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

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

Applying the same grade equivalencies that were described in Section IV, the Agency presents 

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

newly hired staff members in FY 2018 and persons hired into senior grade level positions, 

9.09% newly hired permanent staff in senior grade levels identified as both PWD and PWT

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

equivalent level

Because no permanent staff PWD employees were hired into senior grade levels for the GS-13, 

GS-14, or SES equivalent positions, participation of PWD was higher among the QAP than 

among newly hired senior grade staff for each of those grade level equivalencies. At the GS-15

equivalent, SK-15 and SK-17 level, there was no trigger for the permanent new hires for either 

PWD or PWTD because 33.33% of the newly hired staff at those levels were both PWD and

PWTD. [Redacted to protect privacy.] The following describes trigger analysis at each grade

equivalent level SES, GS-15, GS-14, and GS-13

Continued on the next page
26 | EEO A FFIRMATIVE ACTION PLAN

As described above, the QAP includes data where the applicant self-identified with a disability 

and qualified for permanent and temporary SEC vacancies that were posted in USAJOBS 

with a closing date during the fiscal year. In contrast, data on new hires on boarded during

the course of the fiscal year includes applicants who applied for a vacancy posted prior to 

the start of the fiscal year. Differences may be observed in the demographic statistics of those

selected versus those on boarded as new hires. Triggers comparing the composition of PWD

and PWTD in applicant flow versus new hire data should be interpreted with these difference 

in mind

At the SO level, the QAP was 4.83% PWD, and none of the newly hired permanent SOs

identified as PWD. [Redacted to protect privacy.] At the SK-15 and SK-17 levels (GS-1

equivalent), the QAP was 1.96% PWD, and 33.33% of the permanent new hires for SK-1

and SK-17 positions identified as PWD. [Redacted to protect privacy.] At the SK-14 an

SK-16 levels, the QAP was 10.65% while none of the permanent new hires to SK-14 and

SK-16 positions identified as PWD. [Redacted to protect privacy.] At the SK-13 level, the QA

was 4.55% while none of the new hires to SK-13 positions identified as PWD. [Redacted t

protect privacy.]

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 bo

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

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

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

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

Applying the same grade equivalencies that were described in Section IV and the data 

reviewed in Section IV above, the Agency presents information on trigger identification for 

PWTD new hires to senior grade levels. Of the newly hired permanent staff in senior grade

levels, 9.09% were PWTD in SK-15 or SK-17 positions. [Redacted to protect privacy

For two of the senior grade level positions, the Agency found a trigger in differences in 

participation of PWTD between qualified applicants and among new hires. Because no

PWTD employees were hired into senior grade level positions in the SO or the SK-14 and 

SK-16 (GS-14 equivalent) positions, participation of PWTD was higher among the QAP than 

among newly hired senior grade staff for each of those grade level equivalencies

Continued on the next page
FISCAL YEAR 2018 | 27

For two of the senior grade level positions, the Agency found no evidence for a trigger 

between qualified applicants and among new hires. At the SK-15 and SK-17 level (GS-15

equivalent), there was no trigger for the permanent new hires for either PWD or PWTD. For

SK-13 (GS-13 equivalent) positions, there was no opportunity to observe a difference for 

PWTD newly hired staff. No PWTD were available in the QAP, and none were selecte

More detail about each senior grade level follows in descending order by level. At the SO level,

the Agency found a difference involving PWTD among new hires. The QAP was 0.97%, an

none of the permanent new hires to SO positions identified as PWTD. [Redacted to protect

privacy.] At the SK-15 and SK-17 levels, the QAP was 1.12%, and of the permanent new hire

to SK-15 and SK-17 positions, 33.33% were PWTD. [Redacted to protect privacy.] At t

SK-14 and SK-16 levels, the QAP was 1.61%, and none of the permanent new hires to SK-14

and SK-16 positions were PWTD. At the SK-13 level, the qualified applicant pool was 0.00

and there were no permanent new hires who were PWTD. [Redacted to protect privacy

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 X No 0

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

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

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

actual RAPs for the specific leadership levels differ

Continued on the next page
28 | EEO A FFIRMATIVE ACTION PLAN

FY 2018 data were reviewed to assess whether triggers exist with regard to promotions to 

supervisory positions. Among the promotions in FY 2018 to a leadership position at the

supervisor, manager, or executive level, 5.88% identified as PWD. The following evaluate

participation of PWD in each leadership level. [Redacted to protect privacy.

For all three leadership levels, the participation of PWD in the qualified internal applicant pool 

exceeds that in the RAP. However, differences were found when comparing PWD selections

into leadership positions to the qualified internal applicant pools at all three leadership levels

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

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

for those promotions

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

permanent managers with supervisory status at the SK-17 level, was 6.33%, and the qualified

internal applicants were 14.00% PWD. Therefore, no trigger was found for qualified interna

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

of the internal selections for SO positions identified as PWD, while 14.00% of the qualified

internal applicants were PWD

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

levels, was 7.34%, and the qualified internal applicant pool was 16.06%. The SK-17 manag

selections noted in internal competitive promotion data included 3.7% PWD. [Redacted t

protect privacy.]

For supervisors, the Agency did not have a trigger involving qualified internal applicants

The RAP, comprised of both supervisory and non-supervisory employees at the SK-12 

through SK-14 levels, was 8.98% PWD, and the qualified internal applicants were 14.94

PWD. There was a difference found for internal selections; 14.94% of the qualified interna

applicants identified as PWD, and 7.22% were selecte
FISCAL YEAR 2018 | 29

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

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

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

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

a. Executives

Qualified Internal Applicants (PWTD) Yes 0 No X

Internal Selections (PWTD) Yes X No 0

b. Managers

Qualified Internal Applicants (PWTD) Yes 0 No X

Internal Selections (PWTD) Yes X No 0

c. Supervisors

Qualified Internal Applicants (PWTD) Yes X No 0

Internal Selections (PWTD) Yes 0 No X

Applying the same grade equivalencies that were described in Section IV, the Agency presents 

information on trigger identification for PWTD internal promotions to supervisory positions

Promotions to the supervisory level included 1.47% PWTD. [Redacted to protect privacy.

The following evaluates participation of PWTD in each leadership level

For the manager and executive levels, the participation of PWTD in the qualified internal 

applicant pool exceeds that in the RAP. Such was not true for the supervisor level where a

difference in participation between the RAP and qualified internal applicants was noted

Further, differences were found when comparing PWTD selections into leadership positions 

to the qualified internal applicant pools for both managers and executives. As found for

senior grade levels, overall, the Agency was successful in supporting PWTD in their interest 

in and application for senior leadership roles and was less successful in selecting PWTD for 

those promotions

For executives, the RAP was 1.52% PWTD and 3.30% of the qualified internal applicant

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

internal selections; no PWTD were among the employees selected for SO positions. [Redacted

to protect privacy.]

For managers, the RAP was 1.13% PWTD and a larger proportion 4.24% of the qualifie

internal applicants were PWTD. The Agency identified a difference involving internal

selections; no PWTD were selected out of manager selections, though 4.24% of the qualified

internal applicants were PWTD. [Redacted to protect privacy.

For supervisors, the RAP was 2.00%, and the Agency noted that a smaller proportion

(1.29%) of the qualified internal applicants were PWTD. However, the Agency found stronge

participation of PWTD among those selected for supervisory positions at 2.06% as compared

to their availability among qualified internal applicants at 1.29
30 | EEO A FFIRMATIVE ACTION PLAN

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

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

the text box

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

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

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

Applying the same grade equivalencies that were described in Section IV, the Agency presents 

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

FY 2018 was used 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). An

anomaly was found in FY 2018 new hire data for PWD at the executive level

Among the newly hired staff members in FY 2018, 22.22% of newly hired permanent staff in

leadership positions were both PWD and PWTD. [Redacted to protect privacy.] The following

evaluates participation of PWD in each leadership level. Because no permanent staff PWD

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

among the QAP than among newly hired leaders. At the manager level, there was no trigger

for the permanent new hires for either PWD or PWTD

As described above, the QAP data where the applicant self-identified with a disability and 

qualified for the position was analyzed. Data in this pool describe vacancies for permanent

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

during the fiscal year. In contrast, data on new hires on boarded during the course of the fiscal

year, some of whom applied for a vacancy posted prior to the start of the fiscal year, was also 

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

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

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

For executives, the QAP was 4.83%, and none of the newly-hired permanent executives

identified as PWD. For managers, PWD participation of 40.00% among newly hire

managers exceeds their participation in the QAP at 2.40%. [Redacted to protect privacy.] Fo

supervisors, no PWD were newly hired into supervisory positions, while 1.56% of the QAP

were PWD
FISCAL YEAR 2018 | 31

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

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

in the text box

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

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

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

Differences were found in FY 2018 new hire data for PWTD at the executive level, but no 

differences were found at the manager or supervisor levels. Of the newly hired permanent staff

in leadership positions 22.22% were both PWD and PWTD in manager positions. [Redacte

to protect privacy.]

For executives, the qualified applicant pool was 0.97% PWTD. However, no PWTD wer

selected as new hires for executive positions in FY 2018. For managers, the qualified applicant

pool was 1.60% PWTD, and 40.00% of the newly-hired permanent managers were PW

For supervisors, the qualified applicant pool was 0.00% PWTD, and none of the newly-hired

permanent supervisors were PWTD. The manager and supervisor data do not suggest the

presence of a trigger
32 | EEO A FFIRMATIVE ACTION PLAN

SECTION V: PLAN TO IMPROVE RETENTION OF PERSONS 

WITH DISABILITIES 

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

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

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

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

accommodation program and workplace personal assistance services

Voluntary and Involuntary Separations

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

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

“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. Ten employees were converted to the competitive service under the

Schedule A hiring authority during FY 2018. Seven of those employees were converted within

two years of first entering on duty with the SEC. Three employees were successfully converted

to the competitive service during FY 2018 after serving multiple Schedule A appointments; 

these employees were converted within two years of being placed into their most recent 

Schedule A appointment

2.Using the inclusion rate as the benchmark, did the percentage of PWD among voluntary

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

the trigger below

a. Voluntary Separations (PWD) Yes X No 0

b. Involuntary Separations (PWD) Yes X No 0

FY 2018 data on voluntary and involuntary separation 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). FY 2018

data show that PWD separated at higher rates than those with no disability

Continued on the next page
FISCAL YEAR 2018 | 33

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

disabilities. The inclusion rate for PWD was 4.19%, and for people without disabilities

including those who did not self-identify, the inclusion rate was 3.92%. For involuntar

separations, the percentage of PWD exceeded that of persons without disabilities. The

inclusion rate for PWD was 0.52%, and for people without disabilities, including those who

did not self-identify, the inclusion rate was 0.05

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

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

trigger below

a. Voluntary Separations (PWTD) Yes 0 No X

b. Involuntary Separations (PWTD) Yes 0 No X

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

in the workforce, compared to that same proportion among persons with no disability (this 

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

disability that is not targeted)

No evidence of differentially higher separation among PWTD was found in FY 2018 data

For voluntary separations, the percentage of employees with no targeted disability exceeded 

that of PWTD. The inclusion rate for PWTD was 1.14%, and for people without targete

disabilities, it was 4.00

For involuntary separations, the percentage of persons without targeted disabilities exceeded 

that of PWTD. The inclusion rate for PWTD was 0.00%, and for people without targete

disabilities, the inclusion rate was 0.09
34 | EEO A FFIRMATIVE ACTION PLAN

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

the agency using exit interview results and other data sources

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

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

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

or Office, by occupation, by grade, and by age. The most influential trend observed in these

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

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

has similarly documented the age profile of the U.S. population of PWD (Source: bls.g

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

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

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

small volume represents a proportion of the PWD employee population, such that exploring 

the involuntary separations may be informative. With that caveat, OEEO plans to gather data

about the reasons for removing involuntarily separated PWD to uncover any preventive action 

or support needed for current and future employees

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 83 employees who

completed the exit survey in FY 2018, seven self-identified as having a disability (8.43%

Among exiting employees who reported a disability in FY 2018, two reported that they were 

provided reasonable accommodation

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

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

reasons why those employees left the Agency. To this end, in FY 2018 the Agency analyzed

information from the exit survey across two fiscal years to support more general conclusions 

about why employees with disabilities left the SEC

Continued on the next page
FISCAL YEAR 2018 | 35

Across FY 2017 and FY 2018, 60% of employees who separated and reported a disability 

indicated they left the SEC due to retirement. Of note, all departing employees who selfidentified as having a disability were slightly more positive when responding to items on

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

report a disability: 90% agreed that their workgroup was open to diverse viewpoints and 

backgrounds (compared to 79% of employees who did not report a disability); 90% agreed 

that their supervisor/team lead treated them with respect (versus 81%); 80% agreed their 

co-workers fostered an cohesive work environment (versus 79%); and 80% agreed policies 

and programs promoted diversity in the workplace (versus 70%). The results of the exit

survey suggest employees who separated and indicated a disability were more satisfied with 

SEC diversity and inclusion efforts than other separated employees

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

and PWTD described more fully in Section VII, infra.

Accessibility of Technology and Facilities

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

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 requi

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

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

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

description of how to file a complaint

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

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

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

§§ 200.601 to 200.670, Enforcement of Nondiscrimination on the Basis of Handica

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

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

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

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

Continued on the next page
36 | EEO A FFIRMATIVE ACTION PLAN

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

sec.gov/disability/sec_access.htm and sec.gov/accessibility/sec-accommodationprocedures.pdf. SEC is in the process of updating the Accessibility page of SEC.gov

applicable complaint-filing procedures under both Sections 504 and 508 of the Rehabilitation 

Act and the Architectural Barriers Act. Updates will include 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.A draft SEC Operating Procedure setting forth the complaint

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

finalized in FY19, and posted on SEC.gov thereafter.

Every SEC vacancy announcement posted to USAJOBS includes information about obtaining 

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

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

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

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

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

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

contacting the Disability Program at the SEC

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

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

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 specific to the accessibility of facilities under the Architectural Barriers Act is not 

currently consolidated into one specific notice or resource. Such information can be gathered

from a variety of sources

Information about the SEC’s Disability Program and accommodation procedures is posted 

on SEC.gov (sec.gov/disability/sec_access.htm and sec.gov/accessibility/sec-accommodationprocedures.pdf). These resources provide information on accessibility in work

modifications and appropriate response to other requests, including requests to make the SEC 

program accessible to disabled members of the public. The SEC posts information on how to

file an EEO complaint at sec.gov/eeoinfo/eeocomplaints.htm. In line with the Agency’s plans f

implementing the required and recommended elements of Section 501 of the Rehabilitation Act,

Continued on the next page
FISCAL YEAR 2018 | 37

the Agency will update the SEC website with applicable procedures under the Architectural 

Barriers Act related to the accessibility of facilities

Such updates are intended to address the required notice explaining employees’ and 

applicants’ rights under Section 508 and the Architectural Barriers Act as well as other policy 

and procedural changes to support reasonable accommodation for employees and applicants 

for employment. Updates will include contact information and specific complaints processes

for issues related to accessibility under both Section 508 of the Rehabilitation Act and the 

Architectural Barriers Act

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

Regarding the accessibility of technology, the Agency developed a Technology Strategic 

Plan to cover the years 2018–2020. The plan’s technology priorities include improvements

to the information technology (IT) operational environment and technology delivery 

model to provide high levels of system and infrastructure reliability and availability. Some

initiatives within the plan will help provide high-quality user support and best-in-class 

infrastructure that benefit PWD and PWTD. These initiatives also support accessibility to

SEC’s technology for employees, applicants, and members of the public

The Agency will conduct a review of plans for the IT operational environment found 

in the Technology Strategic Plan against the required and recommended elements for 

technology accessibility embedded in Section 508. The Agency will revise current policy

and procedure, as appropriate, related to accessibility of facilities as required by the 

Architectural Barriers Act during FY 2019
38 | EEO A FFIRMATIVE ACTION PLAN

Reasonable Accommodation Program

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

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 wit

repetitive accommodations, such as interpreting services.

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

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

the provision of adjustable height tables (AHTs), in FY 2018, 72% of initial requests for 

accommodation were processed within 20 business days

SEC is currently engaged in a system design of an automated electronic case management 

system for processing RA requests

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

FY 2018 for capturing data related to processing RA requests. From those data, the SEC notes

a significant improvement in processing timeliness for those requests closed out during the 

year. The time frame for processing initial requests for RA during FY 2018 was 13.2 days, 

greater than 40% decrease from the 22.3 days reported in FY 201

Data reviewed on requests for specific types of RA identified the need for additional focus on 

requests for AHT. In FY 2018, that focus led to notable improvement in processing efficiency for

AHT as a RA. During FY 2018 requests for AHT were processed in 11 days, an almost 50%

improvement over the processing time of 21.6 days reported for such requests in FY 201

RA requests, excluding requests for AHT, were processed in 14 days during FY 2018, which 

also represents a significant (>37% decrease) improvement over the 22.3 days reported for

such requests in FY 2017.
FISCAL YEAR 2018 | 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

After a steady increase in participation over the past six years, in FY 2018 the Agency 

achieved the goals established under Section 501 of the Rehabilitation Act for both PWTD 

and PWD at the lower salary levels and for PWTD among higher salaried employees. In FY

2018, OEEO and OHR established a strong cross functional approach to supporting PWD 

and PWTD in the Agency’s workforce, while leveraging OMWI’s strong EAG network

In recognition of this partnership, leaders in OHR and OEEO were invited to share their 

thoughts in a cross Agency panel discussion at the July meeting of the Federal Exchange on 

Employment with Disabilities (FEED)

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

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

employees in making such a request, the Agency has made available a comprehensive resource 

guide, “Requesting Accommodations at SEC,” for everyone involved in the accommodations 

process. It explains how persons with disabilities should request accommodations, how

requests are processed, and, as applicable, how requestors may seek review of decisions where 

a request has been denied

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

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

officials and the Disability Program Office decide that it is appropriate to do so. In FY 2018,

the SEC processed 112 Temporary Medical Telework (TMT) requests, processed 151 RA 

requests, of which 38 were requests for telework as a reasonable accommodation

All new SEC managers participate in mandatory training regarding the reasonable 

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

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

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

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

Employee Handbook and made available on the AskHR portal

Continued on the next page
40 | EEO A FFIRMATIVE ACTION PLAN

In FY 2018, the SEC revisited and revised the business requirements to implement an 

electronic case management system that would allow employees to request reasonable 

accommodations personally and privately. While the project was delayed in FY 2018, OHR

did create RA and TMT Request and Agreement forms to simplify the process for employees 

making requests; to ensure current, accurate, and complete information is obtained to reduce 

processing times; and to improve the reliability of records indicating customer approval 

of the reasonable accommodation(s) provided. On September 26, 2018, OHR’s Disability

Program Office hosted a Conversation with OHR information session to introduce the 

new procedures for submitting RA requests to all interested employees. This session was

announced and marketed to all employees and managers through SEC Today. This session

also discussed the anticipated launch of procedures for requesting personal assistance services 

(PAS) described below

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

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

with the Chief Human Capital Officer 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

Further, the Disability Program Office updated the Agency’s RA policy to include requests 

for PAS. The revised policy was sent to EEOC for approval during FY 2018 and the EEOC

provided written comments on February 5, 2019. During FY 2019, the Agency will review

the electronic case management system’s business requirements, the new policy, and related 

procedural changes that support RA for employees and applicants for employment. This

review will address coverage of required and recommended elements defined under Section 

501 of the Rehabilitation Act. Changes to RA procedures will likely necessitate updates to

training, job aids, notices, and other information sources in FY 2019 and beyond

Finally, to understand better how the Agency can support PWD and PWTD, OHR updated 

the exit survey. As of September 2018, the Agency’s survey of departing staff, who selfidentified as PWD asks: “What accommodations, personal assistance, or other support could

improve the inclusion and advancement of individuals with disabilities at the SEC?” 
FISCAL YEAR 2018 | 41

Personal Assistance Services Allowing Employees to Participate 

in the Workplace

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

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

The Disability Program Office updated the Agency’s RA policy to include requests for PAS

The revised policy was sent to EEOC for approval during FY 2018 and the EEOC provided 

written comments on February 5, 2019. While that policy was under revision and review in

FY 2017, the Agency entered into a contract to support employees needing PAS. In FY 2018,

OHR developed procedures for employees to submit confidential requests for PAS through 

AskHR. The new form used to capture requests will provide information that may be used to

understand program adoption and effectiveness going forward. The Agency announced the

new PAS form and procedures to employees on October 1, 2018

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 2018, the Agency did not have any findings of discrimination alleging harassment 

based on disability status
42 | EEO A FFIRMATIVE ACTION PLAN

EEO Complaint Data Involving Reasonable Accommodation

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

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

Yes 0 No X N/A 0

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

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

Yes 0 No X N/A 0

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

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

taken by the agency

During FY 2018, the Agency did not have any findings of discrimination involving the failure 

to provide reasonable accommodation

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
FISCAL YEAR 2018 | 43

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

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

Trigger 1

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

workforce and in promotions to higher level positions when this study was initiated based on data from FY 

2014. The participation rate of PWTD in the SEC’s workforce was less than 1% in FY 2014 based on the thencurrent Standard Form 256 (SF-256) Self Identification of Disability. Participation of PWTD in the permanent 

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

SF-256 to 2.02% in FY 2018.

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

and among higher salaried employees as documented in responses to earlier sections is below the goal of 

12% established by Section 501 of the Rehabilitation Act. The participation rate of higher salaried employees 

is 8.64%. 

Participation of PWD, and sometimes PWTD, among new hires and internal competitive promotions to 

mission critical, senior grade level, and leadership positions and among those who were selected for career 

development is below their availability in the relevant or qualified applicant pools. Further, the participation rate 

of PWD and PWTD among employees receiving higher value awards and for PWD among those separating 

from the Agency in both FY 2017 and FY 2018 exceeded that expected based on their participation in the total 

workforce and in comparison to persons with no disability.

Barrier(s) No barrier has been identified.

Objective(s)

While the Agency has not identified specific policies, practices, or procedures that represent a barrier that 

affects employment opportunity for PWD or PWTD, representatives of OEEO and OHR agreed to take action 

toward enhancing equal employment opportunity for persons with targeted disabilities in the following areas:

• Develop and implement policies and procedures specific to the recruitment, hiring, advancement, and 

retention of persons with disabilities (PWD) or persons with targeted disabilities (PWTD) that are aligned 

with the federal government-wide flexibilities and requirements for affirmative action;

• Enhance consistency and structure in the posting, screening, and interview processes for selection;

• Create awareness on the part of hiring managers and subject matter experts (or others involved in the 

Agency’s recruitment and selection processes) about the requirements for, and flexibilities available 

under, government-wide programs supporting PWD and PWTD; and employment programs, especially 

reasonable accommodation and disability programs, supportive of PWD and PWTD.

The objective of these efforts will be to continue to implement action plans developed to address the 

experience of PWTD and expand those plans to cover PWD in line with EEOC regulations. Additional action 

will focus on:

• Analysis of quantitative and qualitative data, including employee perceptions among the population 

of PWD and PWTD;

• Implementing the recommended and required actions under Section 501 of the Rehabilitation Act 

of 1973;

• Implementing, as feasible, revisions to the workforce data tables presenting information on PWD and 

PWTD, as per instruction from EEOC; and

• Reviewing and updating agreed-upon action plans to address the broader population of PWD and/or 

to cover Section 501 regulatory changes.

Responsible Official(s)

Performance Standards Address the Plan?

Title Name (Yes or No)

Chief Human Capital Officer, OHR Jamey McNamara Yes

Director, OEEO Peter J. Henry Yes

Barrier Analysis Process Completed?

(Yes or No)

Barrier(s) Identified?

(Yes or No)

No No
44 | EEO A FFIRMATIVE ACTION PLAN

Sources of Data

Sources 

Reviewed?

(Yes or No) Identify Information Collected

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

PWTD from FY 2011 – FY 2018

Demographic information related to retention for separated 

and on rolls PWD 

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

identify any trends in complaints filed by PWD or PWTD

Grievance Data (Trends) Yes Grievances filed by persons with disability between FY 2012 

and FY 2018

Findings from Decisions (e.g., EEO, Grievance, 

MSPB, Anti-Harassment Processes)

No Not applicable

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

compare responses from persons with disabilities to those 

with no disability

Responses from PWD and PWTD to a Workplace 

Experience Survey conducted at the SEC during FY 2018 

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

data from FY 2016 through FY 2018

Focus Groups No

Interviews Yes Interviews with subject matter experts in OHR and OMWI 

and subject matter experts in disabled student service offices 

at Gallaudet University and Rochester Institute of Technology

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

OPM)

Yes Reports and regulations related to the employment of PWD 

and PWTD in the federal workforce offered by OPM, EEOC, 

DOL/ODEP, EARN, and other agencies and supporting 

organizations

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

practices, and procedures applicable to recruitment and 

retention of persons with disabilities

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

procedures applicable to people with disabilities, including 

those with targeted disabilities

Selection case files (hiring and promotions) from FY 2014 

and FY 2015

Research literature, collective bargaining agreement 

language, and reports to better understand career 

development, promotion, retention, or recruiting and hiring 

processes related to PWD and PWTD

Information about best practices in recruiting PWD in the 

federal government and private industry
FISCAL YEAR 2018 | 45

Target 

Date

(mm/dd/yyyy)

Planned 

Activities

Sufficient Staffing 

& Funding

(Yes or No)

Modified Date

(From)

(mm/dd/yyyy)

Completion 

Date

(mm/dd/yyyy)

11/30/2017 OEEO will conduct a Workplace Experience 

Survey of the Agency workforce to explore 

employee perceptions among the population 

of PWD and PWTD as well as those without 

disabilities on, among other topics, the 

recruitment, hiring, promotion, recognition, 

and retention of talent. This action was 

completed on November 6, 2017.

Yes 11/6/2017

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

working group with representatives from 

OEEO and OHR to develop action plans 

and implement required and recommended 

activity under Section 501 of the Rehabilitation 

Act of 1973. This action was completed on 

November 2, 2017.

Yes 11/02/2017

03/31/2019 To help determine the reasons for removal of 

PWD, OEEO review files from any specifically 

related EEO activity and interview the 

supervisors of PWD who were involuntarily 

separated in FY 2017 and FY 2018. This 

action was completed by March 31, 2019.

Yes 03/31/2019

09/30/2019 In collaboration with internal and contracted 

IT support, OEEO will identify a feasible 

approach(es) to address the set of B 

workforce data tables as per current 

instruction for the FY 2019 report.

Yes 02/28/2019

03/31/2020 OEEO will summarize and interpret the 

research results the basis for identifying 

any areas of opportunity for improvement 

in ensuring equal employment opportunity 

among PWD and PWTD in the workforce.

Yes 12/31/2019

05/31/2020 To the extent areas needing improvement in 

supporting PWD and/or PWTD are found, the 

SEC will begin to develop an action plan to 

help foster equal employment opportunity.

Yes 03/31/2020

09/30/2020 OEEO will begin to design an evaluation 

plan to monitor results based on the work 

completed on this study.

Yes
46 | EEO A FFIRMATIVE ACTION PLAN

Fiscal Year Accomplishments

2018 The following provides detail about OEEO’s analytic work in support of this analysis during FY 2018.

1. OEEO conducted a Workplace Experience Survey of the Agency workforce to explore employee 

perceptions of, among other topics, promotional opportunity, recruitment, and hiring for leadership 

positions. OEEO analyzed 1,360 responses and narrative comments from 469 employees. Among 

the respondents were 90 responses from employees who self-identified as having a disability other 

than those targeted and 34 responses from PWTD. Analyses compare responses on a variety of index 

and item level results. PWD and PWTD reported more favorable perceptions in the areas of: interview 

processes, availability of information about the EEO process and related policies, supervisory relations, 

work team inclusion, and training for success within occupation.

2. In line with implementation of Section 501 requirements, OEEO facilitated the Agency’s decision to 

include persons hired under authorities that take disability into account as PWD. This action allowed the 

Agency to target support, development, and retention efforts toward two persons hired under Schedule A, 

part u and 38 veterans, who received hiring preference based on a service connected disability, as PWD. 

3. OEEO used a series of self-service workforce data summary tools to review the demographic 

composition and disability status data within specific occupations of the entire workforce, newly hired 

staff, AFD, and separations by critical organizational characteristics.

4. OEEO analyzed the increase in self-identification from five-year trend data. Analysis uncovered the 

positive impact of annual employee demographic resurveys and more inclusive definitions of PWD and 

PWTD between FY 2013 and FY 2018. Specifically, we observed a 0.93% point increase in self-identified 

PWD after the first annual employee resurvey in FY 2015, an additional 0.90% point increase after the 

changes to SF-256, and a 0.66% point increase as a result of the resurvey in FY 2018.

5. OEEO analyzed the number and percent of complaint records filed by PWD between FY 2013 and FY 

2017. Results were concerning in the relative volume of complaint activity filed by PWD. The inclusion 

rate of PWD among formal or informal EEO complaint related activity was three times that of persons 

with no disability. Further, complaint activity for PWD was more likely to lead to the formal stage. 

6. With respect to retention, OEEO investigated turnover data for PWD and PWTD among those who 

separated the Agency in FY 2016 through FY 2018. These data revealed that PWD separations were more 

frequently due to retirement as compared to separations among persons with no disability; almost half of the 

PWD separations (48.00%) were coded for retirement, compared to about one third (34.75%) of separations 

among persons with no disability. Further review of these data established a correlation between age, 

disability, and retirement. PWD represent more than twice the proportion of the separations for employees 

over the age of 60 (17.24%) as compared to their participation among separations for persons under 40 

(6.44%). On average, PWD in the Agency workforce are older (PWD average age = 49.32; No Disability 

average age = 46.88, t = - 4.68, p<.001), and, therefore, more likely to be eligible for retirement.

As further explored below, OEEO and OHR established a strong cross functional approach to supporting 

PWD and PWTD in the Agency’s workforce, while leveraging OMWI’s EAG network. In recognition of this 

partnership, leaders in OHR and OEEO were invited to share their thoughts in a cross Agency panel discussion 

at the July meeting of the Federal Exchange on Employment with Disabilities (FEED).

OHR and OEEO jointly sponsored a resurvey of the workforce in July and August 2018 following successful 

resurvey efforts in prior years. OHR provided each employee individualized information showing their current 

demographic and disability coding. Pre- and post-analysis of the resurvey effort showed that 57 employees had 

their disability information change in some way with a net increase of 22 PWD (6.8%) and six PWTD (7.4%).

To understand better how the Agency can support PWD and PWTD, OHR updated the exit survey. 

As of September 2018, the Agency’s survey of departing staff, who self-identify as PWD asks: “What 

accommodations, personal assistance, or other support could improve the inclusion and advancement of 

individuals with disabilities at the SEC?” OHR plans to use and share the information with other stakeholders, 

including OEEO and DIAC in support of current and future employees with disabilities.

OHR continued to make significant enhancements to the SEC’s training and development programs, which 

provide support for the career growth of PWD. As described above in Part J, Section IV, the SEC added to the 

offerings within its career development program.

• OHR developed and worked with NTEU to finalize a Competency Assessment Survey to inform 

workforce planning efforts and shape the future of SEC-wide training and development programs. 

The survey was launched in September 2018, and data collection continued into the new fiscal year.

• In early FY 2018, OHR-SECU implemented development plans for specific occupations or combinations 

of occupations in the Agency’s learning management system, LEAP. The development plan for 

examiners and accountants includes suggested developmental activities and training classes focused 

on specific technical knowledge and skill. Further, LEAP provides career path information based on the 

career ladders and occupational series to enable employees to identify the next step in development 

within occupation or to find lateral transfer opportunities based on competency profile similarity. These 

tools support employees in pursuing career growth within the Agency.

• SECU expanded offerings under the Career Horizons program that provide individualized support for 

employees in creating development plans and pursuing career growth.
FISCAL YEAR 2018 | 47

Fiscal Year Accomplishments

2018 (continued) In recognition of the critical importance of mentoring to support career development, the Agency considered 

options for and developed a pilot mentoring program. In June and July of 2018, a pilot was successfully 

launched leading to the first cohort of 30 participants. An orientation session for both mentors and participants 

was held on September 28, 2018. Throughout FY 2019, mentors will meet with participants on a periodic basis. 

Formal events are planned to help guide the mentoring relationship toward success. To encourage participation 

among PWD, DIAC shared information about the mentoring program with their membership by quarterly 

meetings and their shared mailing list.

• In total, 142 permanent employees submitted a statement of interest in the program. Among them, eight 

(5.63%) were PWD, for an inclusion rate of 2.09%. By way of comparison, the inclusion rate of persons 

with no disability and those who did not self-identify among applicants was 3.37%.

• On a first come, first serve basis, 30 participants were accepted into the mentoring program (29 

permanent and one temporary employee) and matched with volunteer mentors with either or both deep 

technical expertise and leadership experience. The 29 permanent employee participants include two 

(6.90%) PWD, for an inclusion rate of 0.52%. The inclusion rate of persons with no disability among 

participations was 0.68%. 

OHR will partner with OMWI and DIAC to improve PWD participation in future mentoring program offerings.

2017 In January 2017, the EEOC issued revised regulations under the federal government’s obligation to engage 

in affirmative action for people with disabilities that modified Section 501 of the Rehabilitation Act of 1973. 

This revision addresses the hiring, retention, and career opportunity for persons with disabilities and those 

with targeted disabilities. OEEO had previously initiated barrier analysis focused on persons with targeted 

disabilities. 

Representatives from OEEO and OHR implemented a number of actions responsive to the recommendations 

from the original study of the SEC’s PWTD workforce, including:

• Reviewing best practices and recommendations from OPM and the EEOC regarding the employment of 

PWD and PWTD;

• Publishing revised policy on Requirements for Screening and Interviewing Job Candidates that requires 

documentation for each hiring action;

• Developing an enhanced communication plan, including open information sessions, on the requirements 

under the revised policy for screening and interviewing job candidates (these sessions improve 

transparency and further educate SEC employees on available career opportunities and resources);

• Conducting training open to all employees and mandatory training for anyone involved in the hiring or 

promotions process;

• Increasing the quality of interaction between HR specialists and hiring managers toward more strategic 

conversation and the consideration of hiring options that take disability into account;

• Reviewing OHR’s FY 2017 Strategic Recruitment Plan;

• Resurveying the workforce in July and August of 2017 to encourage review of employee data and selfidentification of disability;

• Continuing to evaluate workforce and applicant flow data to determine progress towards removing the 

potential barriers for PWTD, including reviewing the impact of revised disability and targeted disability 

categories in the revised SF-256 as they influence participation of PWD and PWTD;

• Verifying the hiring and assignment of a Special Programs Manager within OHR focused on supporting 

the recruitment, hiring, development, and retention of PWD and PWTD; and

• Developing an enhanced communications plan, in concert with DIAC, which included hosting guest 

speakers, events, and open information sessions supporting the population of PWD and PWTD.

In Quarter (Q2) and Q4 of FY 2017, representatives from OEEO and OHR worked together on transitioning 

to the new October 2016 version of SF-256 Self-Identification of Disability. OHR recoded employees on rolls 

against the categories of disability on the new form in Q2 of FY 2017. OHR and OEEO jointly sponsored a 

resurvey of the workforce in July and August 2017 (Q4). As part of this resurvey effort, OHR provided each 

employee individualized information showing their current demographic and disability coding. The resurvey 

encouraged employees to verify and update their disability information. Employees could update their personal 

information through either employee self-service or with individualized support from OHR for personnel 

processing. The resurvey of the workforce included a broad-based outreach and communications campaign to 

all employees, to include messaging describing the value of self-identification, as suggested by OPM’s Office 

of Diversity and Inclusion. Pre- and post-analysis of the resurvey effort showed that 76 employees had their 

disability information change in some way with a net increase of 20 persons with disabilities (7%) and three 

persons with targeted disabilities (3%).

Further, to support the accurate reporting of information about PWD and PWTD from FPPS, OEEO contracted 

with a service provider to develop an automated tool that extracts, accurately codes, summarizes, and provides 

reporting on demographic information about employees and applicants for employment. This tool, the Equal 

Employment Opportunity–Analytic Tool (EEO-AT), was used to generate the data for workforce data tables 

in this report as well as the responses to data-related questions. The EEO-AT provides for more efficient and 

accurate summary data, more effective interface with FedSEP, and greater facility for OEEO to respond to 

anticipated and future changes to reporting demographic information. 
48 | EEO A FFIRMATIVE ACTION PLAN

Fiscal Year Accomplishments

2016 OHR engaged in the following recruitment/outreach initiatives:

• Partnered with the Department of the Army’s Wounded Warriors Program and Department of Labor 

to successfully implement a Disability Hiring Event, which resulted in the direct hire of two persons 

with disabilities;

• Participated in two Career Fairs: EOP Career Fair and Veterans’ Resource Expo;

• Partnered with George Mason University and implemented the MASON Life Program at the SEC and 

sponsored internships for students with intellectual and physical disabilities;

• Partnered with DIAC to solicit participation in career fairs and leverage their professional networks/

partnerships with other organizations;

• Explored recruiting strategies among various federal and state rehabilitation centers and affinity 

groups; and

• Attended and sponsored the New Perspectives training conference. 

OHR completed the following:

• Training managers and supervisors to ensure they are aware of how the Schedule A hiring authority is 

used by the SEC to hire persons with severe disabilities and the role of managers/supervisors in the 

recruitment and hiring process;

• Surveying disability organizations at universities near the SEC Home Office and Regional Offices to 

obtain information to improve recruitment of applicants with disabilities;

• Using the Hiring Checklist in strategic conversations with hiring managers to ensure they are aware of 

flexibilities available to hire persons with disabilities;

• Implementing and monitoring compliance with the Agency’s selection policy memorandum outlining the 

requirements for screening and interviewing job candidates (published on September 26, 2016); and

• Developing and refining targeted recruitment strategy and performance metrics to measure effectiveness 

of the Agency’s outreach efforts to applicants with disabilities.

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

planned activities

Updates to the EEOC’s timelines, instructions, and requirements under MD-715 2.0 extended

the timeline for implementing feasible changes to workforce data tables providing information 

on PWD and PWTD in collaboration with a shared service provider. The modified date is

September 30, 2019
FISCAL YEAR 2018 | 49

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

toward eliminating the barrier(s)

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

years, the Agency achieved the goals established under Section 501 of the Rehabilitation Act 

for both PWTD and PWD at the lower salary levels and for PWTD among higher salaried 

employees by the end of FY 2018. Because of the relatively small size of the PWD and PWTD

populations, small changes in workforce participation, year over year, can have large impacts 

on the observed rates of change. Nonetheless, the SEC notes the following indications of

growth within this employee population. From FY 2013 to FY 2018

n The permanent workforce of PWTD experienced net growth of 16 persons or 22.22%,

which outpaces the 9.47% net growth in the total permanent workforce over that same

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

to 2.02%. PWTD among higher salaried employees increased from 1.54% to 2.01% 

to 87 PWTD employees)

n The permanent PWD workforce experienced net growth of 159 persons or 71.30

Participation of PWD rose from 5.60% in the total workforce to 8.76% and from 5.1

to 8.62% among higher salaried employees, with an additional 175 persons in higher

salaried jobs identified as PWD

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

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

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

growth and consider effects of underreporting on these statistics

Data from SF-256s collected prior to October 2016 were recharacterized in line with the 

definitions found in the revised form in order to estimate over-time trends. Accordingly, the

numbers of employees who are reported in this trend analysis as PWTD and/or PWD in 

prior years may underestimate the workforce due to the addition of disability and targeted 

disability categories
50 | EEO A FFIRMATIVE ACTION PLAN

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

agency intends to improve the plan for the next fiscal year

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

improvement. Starting in FY 2016 and through FY 2018, representatives of OEEO and OHR

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

employment opportunity. These actions were completed in FY 2018. The Agency will b

implementing additional required and recommended actions during FY 2019 and beyond

OFFICE OF EQUAL EMPLOYMENT OPPORTUNITY

U.S. Securities and Exchange Commission

100 F Street NE

Washington, DC 20549