Securities and Exchange Commission FY 2017

Affirmative Action Plan

for the Recruitment, Hiring, Advancement, and 

Retention of Persons with Disabilities

...

11

...

SECTION I: EFFORTS TO REACH REGULATORY GOALS ....................................... 2

SECTION II: MODEL DISABILITY PROGRAM............................................................. 4

A. PLAN TO PROVIDE SUFFICIENT & COMPETENT STAFFING FOR DISABILITY PROGRAM .......................................................................... 4

B. PLAN TO ENSURE SUFFICIENT FUNDING FOR THE DISABILITY PROGRAM .............................................................................................. 5

SECTION III: PROGRAM DEFICIENCIES IN THE DISABILITY PROGRAM................ 6

SECTION IV: PLAN TO RECRUIT AND HIRE INDIVIDUALS

WITH DISABILITIES ..................................................................................................... 6

A. PLAN TO IDENTIFY JOB APPLICANTS WITH DISABILITIES ..................................................................................................................

B. PLAN TO ESTABLISH CONTACTS WITH DISABILITY EMPLOYMENT ORGANIZATIONS.............................................................................. 8

C. PROGRESSION TOWARDS GOALS (RECRUITMENT AND HIRING) ............................................................................................................ 9

SECTION V: PLAN TO ENSURE ADVANCEMENT

OPPORTUNITIES FOR EMPLOYEES WITH DISABILITIES...................................... 11

D. PROMOTIONS ....................................................................................................................................................................................... 15

SECTION VI: PLAN TO IMPROVE RETENTION OF PERSONS

WITH DISABILITIES ................................................................................................... 21

A. VOLUNTARY AND INVOLUNTARY SEPARATIONS .................................................................................................................................. 21

B. ACCESSIBILITY OF TECHNOLOGY AND FACILITIES.................................................................................................................................. 23

C. REASONABLE ACCOMMODATION PROGRAM....................................................................................................................................... 25

D. PERSONAL ASSISTANCE SERVICES ALLOWING EMPLOYEES TO PARTICIPATE IN THE WORKPLACE...................................................... 26

SECTION VII: EEO COMPLAINT AND FINDINGS DATA .......................................... 26

A. EEO COMPLAINT DATA INVOLVING HARASSMENT............................................................................................................................... 26

B. EEO COMPLAINT DATA INVOLVING REASONABLE ACCOMMODATION................................................................................................ 27

SECTION VIII: IDENTIFICATION AND REMOVAL OF BARRIERS ..........................

6

A. ADVANCEMENT PROGRAM PLAN ......................................................................................................................................................

B. CAREER DEVELOPMENT OPPORTUNITIES ............................................................................................................................................. 12

C. AWARDS ................................................................................................................................................................................................ 13

27
Securities and Exchange Commission FY 2017

Affirmative Action Plan

for the Recruitment, Hiring, Advancement, and 

Retention of Persons with Disabilities

2

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

persons with targeted disabilities (PWTD), EEOC regulations (29 C.F.R. § 1614.203(e)) 

and MD-715 require agencies to describe how their affirmative action 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 

numerical goals for increasing the participation of persons with reportable and targeted 

disabilities in the federal government.

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

involving PWD by grade level cluster in the permanent workforce? If "yes", 

describe the trigger(s) in the text box.

a. Cluster GS-1 to GS-10 (PWD) Answer:No

b. Cluster GS-11 to SES (PWD) Answer:Yes

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

targeted disabilities (PWTD) calculated in two ways 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 statistics in the totality of the 

circumstances. First, this report shares results based on established crosswalks 

between General Schedule (GS) grades and the SEC’s alternative pay plan SK grade 

levels. For the GS to SK levels, the grade levels, with corresponding numbering in the 

SK structure, are the same as in the General Schedule. Hence, an SK-11 is the same 

as a GS-11. The SEC’s Senior Officer ranks are the SEC’s highest level leadership, in 

the same manner as is the Senior Executive Service at other Agencies.

Second, this review presents cluster results based on locality adjusted salary, as 

specified in the revised regulations implementing Section 501 of the Rehabilitation 

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

DC area. For FY 2017, that salary was $66,510.

The Agency did not identify an anomaly involving PWD in the SK-01 to SK-10 grade 

level cluster in the permanent workforce; 22.30% of permanent employees in this 

cluster were PWD compared to the 12% benchmark.

The Agency noted an anomaly involving PWD in the SK-11 to SO grade level cluster; 

6.63% of employees in these higher grade levels were PWD compared to the 12% 

benchmark.

For employees with salaries below a GS-11, step 1, the Agency did not have a trigger 

involving PWD; 31.82% 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 

noted a difference involving PWD; 7.03% of employees in this cluster were PWD 

compared to the 12% benchmark.
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Securities and Exchange Commission FY 2017

* For GS employees, please use two clusters: GS-1 to GS-10 and GS-11 to SES, 

as set forth in 29 C.F.R. § 1614.203(d)(7). For all other pay plans, please use the 

approximate grade clusters that are above or below GS-11 Step 1 in the 

Washington, DC metropolitan region.

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) Answer:No

b. Cluster GS-11 to SES (PWTD) Answer:Yes

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

managers and/or recruiters.

Applying the same comparisons to PWTD as described in section I.1, the SEC 

presents information on trigger identification among PWTD in the permanent 

workforce.

In the SK-01 to SK-10 grade level cluster in the permanent workforce, 8.78% of 

permanent employees in this cluster were PWTD compared to the 2% benchmark. 

The Agency noted a difference involving PWTD in the SK-11 to SO grade level 

cluster; 1.56% of permanent employees in this cluster were PWTD compared to the 

2% benchmark.

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

have a variance involving PWTD; 4.55% of employees in this cluster were PWTD 

compared to the 2% benchmark.

For employees with salaries above a GS-11, step 1, the Agency noted a difference 

involving PWTD; 1.78% of employees in this cluster were PWTD compared to the 2% 

benchmark. The Agency notes that the one area for PWTD in which a variance was 

found was a difference very small in magnitude. This difference was found not to be 

statistically significant.

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

managers during quarterly Office of Human Resources Steering Committee meetings. 

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

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

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

and the Diversity Council.

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:

• Build a pipeline of qualified Schedule A applicants; and

• Improve Veteran recruitment efforts.

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
4

Securities and Exchange Commission FY 2017

Section II: Model Disability Program

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

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

administer the reasonable accommodation program and special emphasis program, and 

oversee any other disability hiring and advancement program the agency has in place.

A. PLAN TO PROVIDE SUFFICIENT & COMPETENT STAFFINGFOR 

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.

Answer: Yes

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

# of FTE Staff by 

Employment Status Responsible Official

(Name, Title, Office, Email)

Full Time Part Time 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 2 1 Dia Gonsalves, Disability

Program Officer, Office of 

Human Resources, 

gonsalvesd@sec.gov

for those applicants with a service-connected disability of 30% or greater.

Beginning in April 2017, OEEO led monthly meetings with a cross-functional working 

group comprised of representatives from OHR and OMWI, including those who 

support recruiting, to discuss the MD-715 and the Agency’s progress related to equal 

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

employment. For these monthly 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.

In FY 2017, OEEO developed an automated reporting tool, the Equal Employment 

Opportunity – Analytic Tool (EEO-AT) that will improve the efficiency and accuracy of 

information shared with the working group in FY 2018 and going forward.

In FY 2018, the material shared through these various channels will be updated to 

include the broader goal for PWD (i.e., 12% of the workforce) and to report separately 

on participation of PWD and PWTD for higher and lower level jobs. Information shared 

in the quarterly Office of Human Resources Steering Committee meetings and metrics 

in the monthly dashboard published by the Agency’s Office of the Chief Operating 

Officer will also be updated to reflect the defined goals for PWD and PWTD.

The Agency designates talent acquisition resources and FTE to Special Programs 

classification, recruitment, and staffing in support of the disability program
5

Securities and Exchange Commission FY 2017

Disability Program Task # of FTE Staff by 

Employment Status Responsible Official

(Name, Title, Office, Email)

Full Time Part Time Collateral Duty

Section 508 Compliance 1 0 0 Remi Pavlik-Simon, Policy 

and Administration Branch, 

Office of Information 

Technology 

PavlikSimonR@sec.gov

Architectural Barriers Act 

Compliance

0 0 3 Ray Ferrari, RA, LEED AP, 

Architect, FerrariR@sec.gov

Jillian Bates, RA, LEED AP, 

Architect, Carla Hairston, 

Program Analyst

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(s) that disability program staff have received. If “no”, describe the 

training(s) planned for the upcoming year.

Answer: Yes

B. PLAN TO ENSURE SUFFICIENT FUNDING FOR THE DISABILITY 

PROGRAM

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.

Answer: Yes

The two full-time employees who work on the disability program staff came to the 

Agency with significant experience in the federal government’s reasonable 

accommodation programs and the responsibilities inherent in responding to 

reasonable accommodation requests. They periodically attend training programs and 

review recent case law to stay apprised of the current developments in this area.

Additionally, the Disability Program Manager and Disability Program Officer complete 

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.

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.

In the coming year, changes are planned in line with implementation of requirements 

and recommendations under Section 501 of the Rehabilitation Act, as amended.

Those changes will require more focused and specific training on related policy and 

procedure post implementation for both HR Specialists and disability program staff.

The Agency was resourced adequately during the reporting period to meet the needs 

to successfully implement the disability program.
6

Securities and Exchange Commission FY 2017

Section III: Program Deficiencies in the Disability Program

In Part G of its FY 2017 MD-715 report, the agency identified the following program 

deficiencies involving its disability program:

Program Deficiencies Agency Comments

Are 90% of accommodation requests 

processed within the frame set forth 

in the agency procedures for 

reasonable accommodation?

(Please see Part H.)

Section IV: Plan to Recruit and Hire Individuals with Disabilities

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

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

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

A. 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 has taken 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 organically realize an increase in the overall representation of people with 

disabilities by using effective recruitment and outreach efforts that brand the Agency 

as an employer of choice.

The following provides detail on recruitment-related activity during FY 2017 to identify 

and encourage applications from potentially qualified PWD and PWTD.

The Agency attended the National Federation of the Blind Job Fair, Careers & the 

Disabled Magazine’s Career Expo, Corporate Gray Military Job Fair, and Hiring Our 

Heroes & the American Legion Job Fair. These events allowed the SEC to reach a 

key constituency and promote a variety of positions.

The SEC also hosted its second annual Informational and Networking Event for 

Individuals with Disabilities at SEC Headquarters. The event provided 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. The SEC 

hosted this event in an effort to continue building a pipeline of applicants for future 

vacancies and educate prospective applicants on the SEC recruitment, hiring, and RA 

processes. After this event, OHR shared contact information for attendees with hiring 

managers for their consideration.

The SEC created an internal resume database for applicants with disabilities that is 

accessible to hiring managers for all hiring actions.

The SEC plans to continue these efforts in FY 2018.

In FY 2018, OHR will continue to leverage the Disability Issues Advisory Committee 

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.
7

Securities and Exchange Commission FY 2017

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

authorities that take disability into account (e.g., Schedule A) to recruit PWD 

and PWTD for positions in the permanent workforce.

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

disability into account (e.g., Schedule A), explain how the agency (1) 

determines if the individual is eligible for appointment under such authority and

(2) forwards the individual's application to the relevant hiring officials with an 

explanation of how and when the individual may be appointed.

The 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.

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.

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)

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 2017, the Special Programs Manager identified potential candidates from 

the Workforce Recruitment Program database for Schedule A hiring.

The Special Programs Manager sourced potential candidates for open positions from 

the OPM’s Shared List of People with Disabilities.

The Special Programs Manager is registered to receive notifications and newsletters 

from the following groups and transmits information to OHR staff engaged in 

recruiting:

• EARN – Employer Assistance Resource Network: http://askearn.org.

• JAN – Job Accommodation Network http://askjan.org

• ODEP – Office of Disability Employment Policy, Department Of 

Labor: http://www.dol.gov/odep/
8

Securities and Exchange Commission FY 2017

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

authorities that take disability into account (e.g., Schedule A)? If “yes”, describe 

the type(s) of training and frequency. If “no”, describe the agency’s plan to 

provide this training.

Answer: Yes

B. PLAN TO ESTABLISH CONTACTS WITH DISABILITY EMPLOYMENT 

ORGANIZATIONS

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

PWD, including PWTD, in securing and maintaining employment.

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.

OHR has 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 2017, new SEC managers participated in mandatory training as part of the LD 

307 Fundamentals of Human Resource Management training. Specific sections in the 

Fundamentals of HR Management highlight special hiring authorities, including 

Schedule A, and requests for reasonable accommodation in the job application 

process. The Disability Program Officer presents this training content.

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.

The SEC’s Special Programs Manager makes a concerted effort to establish and 

maintain contact with 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 

Disability Interests Advisory Committee and the Veterans Committee.

In addition to outreach and recruitment efforts conducted by OMWI and described 

elsewhere in this report, OHR took steps to ensure the SEC has a pipeline of talent in 

the disability and veteran communities by:

• Building relationships with over 10 professional organizations that 

handle disability and veteran affairs;

• Hosting onsite networking events for potential candidates;

• Attending several disability- and veteran-focused career fairs and events; and

• Strengthening partnerships with internal affinity groups in an effort to 

bring awareness to SEC personnel regarding disability and veteran hiring

initiatives.

To improve its outreach to veterans, including those with disabilities, the SEC 

participated in two Vets on Wall Street events and is in the process of implementing 

an Operation Warfighter (OWF) internship program. The SEC also addressed
9

Securities and Exchange Commission FY 2017

C. 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) Answer:Yes

b. New Hires for Permanent Workforce (PWTD) Answer:Yes

2. Using the qualified applicant pool as the benchmark, do triggers exist forPWD 

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) Answer:Yes

b. New Hires for MCO (PWTD) Answer:No

FY 2017 data that underlie Tables B7 and B8 was reviewed for evidence of triggers in 

the hiring of permanent employees into MCO positions. Triggers did not exist in the 

Accountant, IT Management, Attorney, or Economist MCOs. No triggers were found in 

permanent new hires for PWTD. A difference was found for PWD in the Securities 

Compliance Examiner occupation.

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

Table B8 for each occupation was compared to the qualified applicant pool in the data 

from Table B7. As described above (see Part E, Section II.C.2, supra), the applicant 

flow data in Table B7 summarizes the phases of the hiring process through selection 

for vacancies that were posted and closed through USAJOBS during the fiscal year.

The data in Table B7 and the qualified applicant pool data summarized here reflect 

the pool of applications deemed qualified for permanent and/or temporary vacancies 

announced through USAJOBS during FY 2017.

In contrast, Table B8 presents data on permanent new hires onboarded during the 

course of the fiscal year. Some newly-hired staff applied for a vacancy posted in a 

prior fiscal year. Differences may be observed in comparing the demographic statistics 

of the qualified applicant pool in Table B7 and that of new hires onboarded in Table 

B8. Triggers comparing the composition of PWD and PWTD in applicant flow versus 

new hire data should be interpreted with theses difference in mind.

For Economists, the qualified applicant pool was 0.00% for PWD and PWTD.

[Redacted to protect privacy] No trigger was evident in these data. For Attorneys, the 

qualified applicant pool was 1.38% PWD, and the qualified

professional veteran-focused organizations and veterans’ hiring events.

Data from FY 2017 presented in Table B8 was reviewed for evidence of differences in 

hiring into the permanent workforce. From these data, the Agency did identify an 

anomaly in the participation rate for PWD among new hires in the permanent 

workforce. In FY 2017, the participation of PWD among permanent new hires was 

5.30% as compared to the goal of 12%.

The Agency also noted a difference in the participation of PWTD among new hires. In 

FY 2017, the participation of PWTD among permanent new hires was 0.76% as 

compared to the goal of 2%.

The Agency notes that the hiring freeze, implemented early in FY 2017, impacted the 

efforts towards filling open positions and affected results toward increasing the 

participation of PWD and PWTD.
10

Securities and Exchange Commission FY 2017

3. Using the relevant applicant pool as the benchmark, do triggers exist forPWD 

and/or PWTD among the qualified internal applicants for any of the missioncritical occupations (MCO)? If “yes”, please describe the triggers below.

a. Qualified Applicants for MCO (PWD) Answer:Yes

b. Qualified Applicants for MCO (PWTD) Answer:Yes

In the FY 2017 data presented in Table B9, 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, Accountant, and Securities Compliance Examiner.

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

same MCO 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; and for the Information 

Technology Management occupation, the RAP included all employees in the 2210 

series.

Differences were also identified for PWTD within the internal competitive promotion 

data for the MCOs Attorney, Accountant, and Securities Compliance Examiner.

No internal competitive promotions were processed for Economists or IT 

Management; therefore, no anomaly was found for PWD or PWTD in those 

occupations.

For Attorneys, the RAP for PWD was 4.39%, and PWD represented 2.53% of the 

qualified internal applicants. The RAP for PWTD was 1.38%, and PWTD were 0.00% 

of the qualified internal applicants for Attorneys. For Accountants, the RAP for PWD 

was 5.87%, and PWD were 0.00% of the qualified internal applicants. The RAP for 

PWTD was 1.11%, and PWD were 0.00% of the qualified internal applicants. For 

Securities Compliance Examiners, the RAP for PWD was 6.94%, and PWD

applicant pool for PWTD was 0.88%. [Redacted to protect privacy] PWD were 5.08% 

of newly-hired permanent attorneys, and PWTD were 1.69% of permanent new hires. 

No trigger was found in these data.

For Accountants, the qualified applicant pool for PWD was 0.71%, and PWD were 

11.11% of permanent new hires. [Redacted to protect privacy] The qualified 

applicant pool was 0.00% for PWTD, and PWTD were 0.00% of permanent new 

hires. Again, no trigger is found in these data.

For IT Management, no applicant flow data were collected from postings during FY 

2017; therefore, the qualified applicant pool was 0.00% PWD, and PWD were 12.5% 

of new hires. [Redacted to protect privacy] The qualified applicant pool was 0.00% 

PWTD, and none of the permanent new hires were PWTD. [Redacted to protect 

privacy] For Securities Compliance Examiners, a difference was identified for PWD. 

The qualified applicant pool was 3.13% PWD, and no permanent new hires were 

PWD. No anomaly was evident in new hires for Securities Compliance Examiners. 

The qualified applicant pool for PWTD was 0.00%, and none of permanent new hires 

were PWTD. [Redacted to protect privacy]
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Securities and Exchange Commission FY 2017

4. Using the qualified applicant pool as the benchmark, do triggers exist forPWD 

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) Answer:Yes

b. Promotions for MCO (PWTD) Answer:No

Section V: Plan to Ensure Advancement Opportunities for 

Employees with Disabilities

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

advancement opportunities for employees with disabilities. Such activities might include 

specialized training and mentoring programs, career development opportunities, awards 

programs, promotions, and similar programs that address advancement. In this section, 

agencies should identify, and provide data on programs designed to ensure advancement 

opportunities for employees with disabilities.

A. ADVANCEMENT PROGRAM PLAN

Describe the agency's plan to ensure PWD, including PWTD, have sufficient opportunities for 

advancement.

represented 2.56% of the qualified internal applicants. The RAP for PWTD was 

1.16%, and PWTD were 0.00% of the qualified internal applicants.

For Economists, there were no internal vacancies posted. [Redacted to protect 

privacy] 

For IT Management, there were no internal vacancies posted. [Redacted to protect 

privacy]

In the FY 2017 data presented in Table B9, 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 Securities 

Compliance Examiner occupation. The QAP for PWD was 2.56%, and 0.00% of those 

promoted were PWD. The QAP for PWTD was 0.00%, and 0.00% of those promoted 

were PWTD. [Redacted to protect privacy]

In the Attorney occupation, there were no differences among those selected for 

internal promotions. The QAP for PWD was 2.53%, and 8.33% of those selected for 

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

promotions. [Redacted to protect privacy] 

In the Accountant occupation there were no triggers among internal promotions. 

The QAP was 0.00% for PWD and PWTD, which drove a result of 0.00% among 

internal promotions for PWD and PWTD. [Redacted to protect privacy] 

In the Economist and IT Management occupations there were no internal promotions 

during FY 2017, so no triggers were identified.

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 and career development 

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

promote opportunities for advancement.

• OHR implemented and maintains a new, user-friendly, interactive portal, AskHR, 

on the SEC’s intranet, which provides employees with information about hiring,
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Securities and Exchange Commission FY 2017

B. CAREER DEVELOPMENT OPPORTUNITIES

1. Please describe the career development opportunities that the agency provides 

to its employees.

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

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

careers. Classroom-style and e-Learning programs offer an extensive array of 

learning opportunities in technical areas (e.g., courses on Hedge Funds, Mutual 

Funds, and Credit Derivatives, etc.) as well as in leadership development to SEC 

senior leaders and non-supervisory staff alike.

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 2017, OHR implemented 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 them to progress toward their career goals. SECU 

established initial career paths based on prior projects to define competency 

requirements for a variety of occupations. In FY 2018, OHR and SECU will gather 

additional data to support the competency development of professional and 

leadership positions to enhance the value of the new LEAP career path options.

Relatedly, in FY 2018, the Agency will solicit input and consider options for the design 

of a mentoring program that will support the career development of all employees, 

including PWD and PWTD, into and within leadership levels.

Among the many career development options for SEC employees, the Agency offered 

four career development programs in FY 2017: Women in Leadership, Excellence in 

Government Fellows Program, Aspiring Leaders, and Upward Mobility. Data about 

applicants and participants in these programs is presented in Table B12.

2. 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 applicants and the applicant pool for selectees.) If "yes", 

describe the trigger(s) in the text box.

a. Applicants (PWD) Answer:Yes

b. Selections (PWD) Answer:Yes

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.

• 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.

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

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

circulates job postings and 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.
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Securities and Exchange Commission FY 2017

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

the career development programs identified? (The appropriate benchmarks are 

the relevant applicant pool for applicants and the applicant pool for selectees.) 

If "yes", describe the trigger(s) in the text box.

a. Applicants (PWTD) Answer:Yes

b. Selections (PWTD) Answer:Yes

C. AWARDS

From the FY 2017 data presented in Table B12, this report summarizes information 

on career development data in three groups: career development programs for 

employees in grades SK-05 to SK-12, career development for SK-13 to SK-14, and 

career development for SK-15 to SK-17.

The following summarizes comparisons between the participation of PWD and PWTD 

in first, the relevant applicant pool (RAP) and the applicants for career development 

programs and second, between the applicants for and selections/participants in career 

development programs for employees in these grade levels.

In the SK-05 to SK-12 programs, the Agency did find an outlier among PWD 

applicants for career development. The RAP was 15.18% PWD, and applications 

from PWD were 13.89%. The Agency also noted a difference among PWD 

participants; PWD were 7.14% of participants, and 13.89% of applicants.

In the SK-13 to SK-14 programs, the Agency did not have a trigger among applicants 

for career development. The RAP was 6.89% PWD, and applications from PWD were 

10.34%. The Agency noted a difference among PWD participants. PWD were 1.72% 

of participants, and 10.34% of applicants.

In the SK-15 to SK-17 programs, there was an anomaly among applicants for career 

development. The RAP was 4.99% PWD, and applications from PWD were 0.00%. 

The Agency did not find a trigger among PWD participants. PWD were 0.00% of 

participants, and 0.00% of applicants.

Applying the same comparisons to PWTD as described in section IV.2.b, this report 

presents information on participation in career development programs among PWTD. 

In the SK-05 to SK-12 programs, the Agency did not find a trigger among PWTD 

applicants for career development. The RAP was 5.43% PWTD, and PWTD were 

11.11% of applicants. The Agency did note an anomaly among PWTD participants.

PWTD were 0.00% of participants, and 11.11% of applicants.

In the SK-13 to SK-14 programs, the Agency did not find a trigger among applicants. 

The RAP was 1.62% PWTD, and PWTD were 3.45% of applicants. The Agency did 

note a difference among PWTD participants. PWTD were 0.00% of participants, and 

3.45% of applicants.

In the SK-15 to SK-17 group, the Agency did note a difference among applicants. The 

RAP was 1.35%, and 0.00% of applicants were PWTD. The Agency did not have an 

anomaly among PWTD participants. PWTD were 0.00% of participants and 0.00% of 

applicants.
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Securities and Exchange Commission FY 2017

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) Answer:Yes

b. Awards, Bonuses, & Incentives (PWTD) Answer:Yes

In the FY 2017 data reflected in Table B13, the Agency presents information on 

awards distributed to employees during the year as part of its Employee Recognition 

Program.

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 anomalies in: time-off awards of 9 hours 

or more and cash awards of more than $500. A difference was found for PWD in timeoff awards of 9 hours or less but not for PWTD. No trigger was found for either PWD 

or PWTD in the distribution of cash awards of $100 to $500.

For time-off awards of 9 hours or less, the inclusion rate for PWD was 24.22%, and 

the inclusion rate for people with no disability was 27.43%, indicating an anomaly. The 

inclusion rate for PWTD was 29.63%, and the inclusion rate for people with no 

targeted disability was 27.15%.

For time-off awards of more than 9 hours, the inclusion rate for PWD was 27.33%, 

and the inclusion rate for people with no disability was 30.46%. The inclusion rate for 

PWTD was 25.93%, and the inclusion rate for people with no targeted disability was 

30.32%.

For cash awards of more than $500, the inclusion rate for PWD was 37.58%, and the 

inclusion rate for people with no disability was 46.13%. The inclusion rate for PWTD 

was 29.63%, and the inclusion rate for people with no targeted disability was 45.81%. 

There was no trigger identified in cash awards of $100 to $500. The inclusion rate for 

PWD was 26.71%, and the inclusion rate for people with no disability was 21.38%.

The inclusion rate for PWTD was 34.57%, and the inclusion rate for people with no 

targeted disability was 21.52%.

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) Answer:Yes

b. Pay Increases (PWTD) Answer:Yes

To address the question posed here, the following summarizes data from 

performance-based pay increases distributed under the Agency’s Performance 

Management Program. Data summarized here include those personnel actions coded 

under nature of action (NOA) Code 891, Regular Performance Pay, in accordance 

with EEOC instruction for presenting this data. Performance-based awards at theSEC
15

Securities and Exchange Commission FY 2017

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

sum awards. In FY 2017, 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).

For PWD, the Agency found a variance in these performance rating based pay 

increases. The inclusion rate for PWD was 72.98%, and for people without disabilities 

and those who did not self-identify with a disability, it was 74.96%.

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

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

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

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

with a disability that is not targeted) who received such a performance-based pay 

increase.

For PWTD, the Agency found a trigger in performance rating based pay increases. In 

these performance rating based pay increases, the inclusion rate for PWTD was 

74.07%, 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 74.84%.

The observed differences are small in magnitude and partially driven by recent hiring 

and onboarding of PWD and PWTD. [Redacted to protect privacy]

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) Answer:N/A

b. Other Types of Recognition (PWTD) Answer:N/A

D. PROMOTIONS

The Agency instituted a Gift Card Recognition Program in late FY 2016. At the time 

this report was prepared, data for this program were not available to compare the 

demographic information of the recipients of this awards program. The Agency plans 

to conduct analysis of gift cards distributed under this program during FY 2018.
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Securities and Exchange Commission FY 2017

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

i. Qualified Internal Applicants (PWD) Answer:No

ii. Internal Selections (PWD) Answer:Yes

b. Grade GS-15

i.Qualified Internal Applicants (PWD) Answer:Yes

ii. Internal Selections (PWD) Answer:No

c. Grade GS-14

i.Qualified Internal Applicants (PWD) Answer:Yes

ii. Internal Selections (PWD) Answer:No

d. Grade GS-13

i.Qualified Internal Applicants (PWD) Answer:Yes

ii. Internal Selections (PWD) Answer:No

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. Table B11 presents the relevant FY 2017 data to assess whether 

triggers exist with regard to promotions to senior grade levels.

At the SO level, the Agency noted a difference involving PWD among internal 

selections for promotions. The Relevant Applicant Pool (RAP), comprised of all 

employees at grade levels SK-14 and higher, was 5.81% and among qualified internal 

applicants, 5.88% were PWD. [Redacted to protect privacy] 

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 5.80%, while the participation of PWD 

among qualified internal applicants was 1.56%. The Agency did not have a trigger 

involving internal selections for senior grade levels at the SK-15 and SK-17 levels; 

4.76% of selections were PWD compared to their participation among qualified 

internal applicants at 1.56%.

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 6.36%, and the participation of PWD among 

qualified internal applicants was 2.88%. On the other hand, 6.25% of selections were 

PWD compared to 2.88% of qualified internal applicants.

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

PWD among qualified internal applicants. The RAP was 12.37%, and the participation 

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

trigger involving internal selections. [Redacted to protect privacy]
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Securities and Exchange Commission FY 2017

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

i. Qualified Internal Applicants (PWTD) Answer:Yes

ii. Internal Selections (PWTD) Answer:No

b. Grade GS-15

i.Qualified Internal Applicants (PWTD) Answer:Yes

ii. Internal Selections (PWTD) Answer:No

c. Grade GS-14

i.Qualified Internal Applicants (PWTD) Answer:Yes

ii. Internal Selections (PWTD) Answer:No

d. Grade GS-13

i.Qualified Internal Applicants (PWTD) Answer:Yes

ii. Internal Selections (PWTD) Answer:No

Applying the same comparisons to PWTD as described in section VI.4.a, the 

Agency presents information on trigger identification for PWTD in promotions to 

senior grade levels.

At the SO level, the Agency notes that the RAP was 1.37%, and the participation 

among qualified internal applicants of PWTD was 0.00%. No anomaly was found for 

the selections to SO positions; [Redacted to protect privacy]

At the SK-15 and SK-17 level (GS-15 equivalent), the Agency had an anomaly 

involving PWTD among qualified internal applicants. The RAP was 1.37%, and among 

the qualified internal applicants, none were PWTD. No trigger was found for the 

internal selections to grades SK-15 and SK-17; 0.00% of the qualified internal 

applicant pool was PWTD. [Redacted to protect privacy] At the SK-14 and SK-16 level 

(GS-14 equivalent), the Agency the RAP was 1.35% while 0.00% of the qualified 

internal applicants were PWTD [Redacted to protect privacy] no trigger was found in 

these data.

At the SK-13 level (GS-13 equivalent), the Agency had an anomaly involving PWTD 

among qualified internal applicants. The RAP was 4.47%, and the participation of 

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

trigger involving internal selections. [Redacted to protect privacy]
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Securities and Exchange Commission FY 2017

3. Using the qualified applicant pool as the benchmark, does your agency have a 

trigger involving PWD among the new hires to the senior grade levels? For 

non-GS pay plans, please use the approximate senior grade levels. If "yes", 

describe the trigger(s) in the text box.

a. New Hires to SES (PWD) Answer:No

b. New Hires to GS-15 (PWD) Answer:Yes

c. New Hires to GS-14 (PWD) Answer:No

d. New Hires to GS-13 (PWD) Answer:No

Applying the same grade equivalencies that were described in section VI.4.a, the 

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

grade levels based on reviewing data underlying Tables B7 and B8.

As described above (see Part E, Section II.C.2 and Part J.III.3.a, supra), the qualified 

applicant pool from Table B7 summarizes data where the applicant self-identified with 

a disability and was deemed qualified for the position. Data in this pool describe 

vacancies for permanent and temporary positions with the SEC that were posted in 

USAJOBS with a closing date during the fiscal year. In contrast, Table B8 presents 

data on new hires onboarded during the course of the fiscal year; some of whom 

applied for a vacancy posted prior to the start of the fiscal year. Differences may be 

observed in the demographic statistics of those selected versus those onboarded as 

new hires. Triggers comparing the composition of PWD and PWTD in applicant flow 

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

At the SO level, the Agency did not have a trigger involving PWD among new hires. 

The qualified applicant pool was 0.00% PWD, and none of the [Redacted to protect 

privacy] newly hired SOs, four permanent and eight temporary new hires, were

PWD.

At the SK-15 and SK-17 levels, the qualified applicant pool was 2.65% PWD, however 

none of the [Redacted to protect privacy] new hires for SK-15 and SK-17 positions 

were PWD.There were no temporary hires in these grade levels.

At the SK-14 and SK-16 levels, the qualified applicant pool was 4.34% while 7.14% 

[Redacted to protect privacy] of the [Redacted to protect privacy] permanent new 

hires to SK-14 and SK-16 positions were PWD. [Redacted to protect privacy] 

At the SK-13 level, the qualified applicant pool was 4.20% while 6.67% [Redacted to 

protect privacy] of the [Redacted to protect privacy] new hires to SK-13 positions 

were PWD. [Redacted to 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 box.

a. New Hires to SES (PWTD) Answer:No

b. New Hires to GS-15 (PWTD) Answer:Yes

c. New Hires to GS-14 (PWTD) Answer:Yes

d. New Hires to GS-13 (PWTD) Answer:Yes

Applying the same grade equivalencies that were described in section VI.D.1 and

Tables reviewed in section VI.D.3, the Agency presents information on trigger 

identification for PWTD new hires to senior grade levels.
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Securities and Exchange Commission FY 2017

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

i. Qualified Internal Applicants (PWD) Answer:Yes

ii. Internal Selections (PWD) Answer:Yes

b. Managers

i.Qualified Internal Applicants (PWD) Answer:Yes

ii. Internal Selections (PWD) Answer:No

c. Supervisors

i.Qualified Internal Applicants (PWD) Answer:Yes

ii. Internal Selections (PWD) Answer:No

At the SO level, the Agency did not have a trigger involving PWTD among new hires. 

The qualified applicant pool was 0.00%, and none of the [Redacted to protect privacy]

new hires to SO positions were PWTD. [Redacted to protect privacy] At the SK-15 

and SK-17 levels, the qualified applicant pool was 1.23%, however none of the 

[Redacted to protect privacy] permanent new hires to SK-15 and SK-17 positions 

were PWTD. There were no temporary hires in these grade levels.

At the SK-14 and SK-16 levels, the qualified applicant pool was 2.90%, though none

of the [Redacted to protect privacy] permanent new hires to SK-14 and SK-16 

positions were PWTD. [Redacted to protect privacy]

At the SK-13 level, the qualified applicant pool was 2.33% and 2.22% [Redacted to 

protect privacy] of the [Redacted to protect privacy] permanent new hires to SK-13 

positions was PWTD. [Redacted to protect privacy] The Agency notes the small 

magnitude of the observed difference between the qualified applicant pool and new 

hires for the SK-13 level (0.11%).

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 SKlevels below SK-17 who hold supervisory status. FY 2017 data underlying Table B11 

presents the data relevant for assessing whether triggers exist with regard to 

promotions to supervisory positions.

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

comprised of permanent managers at the SK-17 level, was 5.85%, and the qualified 

internal applicants were 5.88% PWD. None of the internal selections for SO positions 

were PWD.

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

through SK-15 levels, was 5.65%, but the qualified internal applicant pool was 

1.92%. PWD were 10.00% of [Redacted to protect privacy] manager selections. 

Therefore, no trigger existed for manager selections.
20

Securities and Exchange Commission FY 2017

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

i. Qualified Internal Applicants (PWTD) Answer:Yes

ii. Internal Selections (PWTD) Answer:No

b. Managers

i.Qualified Internal Applicants (PWTD) Answer:Yes

ii. Internal Selections (PWTD) Answer:No

c. Supervisors

i.Qualified Internal Applicants (PWTD) Answer:Yes

ii. Internal Selections (PWTD) Answer:No

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) Answer:No

b. New Hires for Managers (PWD) Answer:Yes

c. New Hires for Supervisors (PWD) Answer:Yes

For supervisors, the Agency had 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 7.08% PWD, and the qualified internal applicants included 

no (0.00%) PWD. There was no anomaly identified for internal selections; none of the 

qualified internal applicants were PWD, and none were selected.

Applying the same grade equivalencies that were described in section VI.4.e, the 

Agency presents information on trigger identification for PWTD internal promotions to 

supervisory positions from data underlying Table B11.

For executives, the RAP was 1.27% PWTD though 0.00% of the qualified internal 

applicants were PWTD. The Agency did not identify an anomaly involving internal 

selections; no PWTD were among the qualified internal applicants for SO positions, 

and none were selected.

For managers, the RAP was 1.41% PWTD though 0.00% of the qualified internal 

applicants were PWTD. The Agency did not identify an anomaly involving internal 

selections; no PWTD were among the qualified internal applicants for manager 

positions, and none were selected.

For supervisors, the RAP was 1.63%, though 0.00% of the qualified internal applicants 

were PWTD. The Agency did not identify an anomaly involving internal selections; no 

PWTD were among the qualified internal applicants for supervisor positions, and none 

were selected.
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Securities and Exchange Commission FY 2017

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) Answer:No

b. New Hires for Managers (PWTD) Answer:Yes

c. New Hires for Supervisors (PWTD) Answer:No

Section VI: 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 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.

A. VOLUNTARY AND INVOLUNTARY SEPARATIONS

Applying the same grade equivalencies that were described in section VI.4.e, the 

Agency presents information on trigger identification for PWD new hires into 

supervisory positions. Data underlying Tables B7 and B8 are relevant for assessing 

whether differences exist with regard to applicants and new hires in supervisory 

positions for PWD (this question) and PWTD (see the following question). Anomalies 

were found in FY 2017 new hire data for PWD at the manager and supervisor levels. 

As described above (see Part E, Section II.C.2 and Part J.III.3.a, supra), the qualified 

applicant pool from Table B7 summarizes data where the applicant self-identified with 

a disability and was deemed qualified for the position. Data in this pool describe 

vacancies for permanent and temporary positions with the SEC that were posted in 

USAJOBS with a closing date during the fiscal year. In contrast, Table B8 presents 

data on new hires onboarded during the course of the fiscal year; some of whom 

applied for a vacancy posted prior to the start of the fiscal year. Differences may be 

observed in the demographic statistics of those selected versus those onboarded as 

new hires. Triggers comparing the composition of PWD and PWTD in applicant flow 

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

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

permanent executives were PWD. No trigger was found.

For managers, the qualified applicant pool was 0.75%, and none of the newly-hired 

permanent managers were PWD, providing evidence of a variance.

For supervisors, the qualified applicant pool was 1.94%, and none of the newly-hired 

permanent supervisors were PWD. These data suggest the presence of a trigger.

Differences were found in FY 2017 new hire data for PWTD at the manager level. No 

PWTD were selected as new hires for executive or supervisory positions in FY 2017. 

For executives, no anomaly was found as the qualified applicant pool was 0.00%, and 

none of the newly-hired permanent executives were PWTD.

For managers, the qualified applicant pool was 0.37% PWTD, though none of 

the newly-hired permanent managers were PWTD.

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

newly-hired permanent supervisors were PWTD. Supervisor data do not suggest 

the presence of a trigger.
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Securities and Exchange Commission FY 2017

1. In this reporting period, did the agency convert all eligible Schedule A 

employees with a disability into the competitive service after two years of 

satisfactory service (5 C.F.R. § 213.3102(u)(6)(i))? If "no", please explain why 

the agency did not convert all eligible Schedule A employees.

Answer: Yes

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) Answer:Yes

b. Involuntary Separations (PWD) Answer:Yes

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) Answer:Yes

b. Involuntary Separations (PWTD) Answer:Yes

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.

[Redacted to protect privacy] employees were converted to the competitive service 

under the Schedule A legal authority during FY 2017. [Redacted to protect privacy] 

of those employees were converted within two years of entering on duty with the 

SEC [Redacted to protect privacy] successfully converted to the competitive service 

during FY 2017 after serving multiple Schedule A appointments[Redacted to protect 

privacy] converted within two years of being placed into the most recent Schedule A 

appointment.

Table B14 provides FY 2017 data on voluntary and involuntary separation by 

disability. These data 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).

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

disabilities. The inclusion rate for PWD was 5.59%, and for people without disabilities, 

including those who did not self-identify, the inclusion rate was 4.47%.

For involuntary separations, the percentage of PWD exceeded that of persons 

without disabilities. The inclusion rate for PWD was 0.93%, and for people without 

disabilities, including those who did not self-identify, the inclusion rate was 0.07%.

Using data from Table B14 to calculate the inclusion rates for PWTD, the following 

was found in FY 2017 data. Inclusion rates were calculated as the number of PWTD 

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

among persons with no disability (this group also includes those who did not selfidentify as having a disability and those with a disability that is not targeted).

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

targeted disabilities. The inclusion rate for PWTD was 9.88%, and for people without 

targeted disabilities, it was 4.45%.

For involuntary separations, the percentage of PWTD exceeded that of persons 

without targeted disabilities. The inclusion rate for PWTD was 1.23%, and for people
23

Securities and Exchange Commission FY 2017

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.

B. ACCESSIBILITY OF TECHNOLOGY AND FACILITIES

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

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

794(b)), concerning the accessibility of agency technology, and the Architectural Barriers Act of 

1968 (42 U.S.C. § 4151 – 4157), concerning the accessibility of agency facilities. In addition, 

agencies are required to inform individuals where to file complaints if other agencies are 

responsible for a violation.

1. Please provide the internet address on the agency's public website for its 

notice explaining employees' and applicants' rights under Section 508 of the 

Rehabilitation Act, including a description of how to file a complaint.

without targeted disabilities, the inclusion rate was 0.11%.

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 [Redacted to protect privacy] employees who completed the Exit Survey in 

FY 2016, [Redacted to protect privacy] self-identified as having a disability (5.49%). 

Among exiting employees who reported a disability in FY 2016, [Redacted to 

protect privacy] reported that they were provided reasonable accommodation.

The Exit Survey continued in FY 2017. Through July 31 (Q3), [Redacted to protect 

privacy] departing employees completed the Exit Survey, and [Redacted to protect 

privacy] (5.71%) self-identified as having a disability. A smaller percentage of 

employees with disabilities completed the Exit Survey (5.71%) as compared to their 

participation among those who separated from the Agency (9.95%) and as compared 

to their total workforce participation at the end of the year (7.15%). Among exiting 

employees who reported a disability through Q3 of FY 2017, [Redacted to protect 

privacy] reported that they were provided reasonable accommodation.

The small number and percentage 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.

In FY 2018, the Agency will compile information from the Exit Survey across years to 

support more general conclusions about why employees with disabilities left the SEC.

Information specific to the accessibility of Agency technology under Section 508 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 is posted on SEC.gov 

(http://www.sec.gov/disability/sec_access.htm and 

www.sec.gov/accessibility/sec- accommodation-procedures.pdf).

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 at http://www.opm.gov/policy-dataoversight/disability-employment/selective-placement-program-coordinator-directory/. 

OHR has also built a separate page providing more in-depth information about hiring 

PWD (https://www.sec.gov/ohr/sec-disability-program-page.html). This page 

includes a link to an online form (https://www.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.
24

Securities and Exchange Commission FY 2017

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.

3. Describe any programs, policies, or practices that the agency has undertaken, 

or plans on undertaking over the next fiscal year, designed to improve 

accessibility of agency facilities and/or technology.

The SEC posts information on how to file an EEO complaint at 

https://www.sec.gov/eeoinfo/eeocomplaints.htm.

In line with the Agency’s plans for implementing the required and recommended 

elements of Section 501 of the Rehabilitation Act, the Agency will update the SEC 

website with applicable procedures under Section 508 related to technology 

accessibility.

These 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.

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 (http://www.sec.gov/disability/sec_access.htm and

www.sec.gov/accessibility/sec-accommodation-procedures.pdf). These resources 

provide information on accessibility in workspace 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 

https://www.sec.gov/eeoinfo/eeocomplaints.htm.

In line with the Agency’s plans for implementing the required and recommended 

elements of Section 501 of the Rehabilitation Act, 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.

Regarding the accessibility of technology, the Agency developed a Technology 

Strategic Plan to cover the years 2018 – 2020. That plan was posted to the sec.gov 

website (http://technologyplan.sec.gov/). 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.
25

Securities and Exchange Commission FY 2017

C. REASONABLE ACCOMMODATION PROGRAM

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

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

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

reasonable accommodations during the reporting period. (Please do not 

include previously approved requests with repetitive accommodations, such as 

interpreting services.)

2. Describe the effectiveness of the policies, procedures, or practices to 

implement the agency’s reasonable accommodation program. Some examples 

of an effective program include timely processing requests, timely providing 

approved accommodations, conducting training for managers and supervisors, 

and monitoring accommodation requests for trends.

The Agency will also conduct a review assessing current policy and procedure related 

to accessibility of facilities as required by the Architectural Barriers Act during FY 

2018.

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 

2017, 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 reasonable accommodation requests as 

described in Part H of this report (supra).

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

used in FY 2017 for capturing data related to processing reasonable accommodation 

requests. From those data, the time frame for processing initial requests for 

reasonable accommodation during FY 2017 was 22.3 days. Requests for AHT were 

processed in 21.6 days. RA requests, excluding requests for AHT, were processed in 

23 days.

The interactive portal, AskHR, on the Agency’s intranet described above 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 2016, the Disability Program Office developed and issued a new policy 

and standard operating procedures to clarify the process and guidelines for the 

Temporary Medical Telework (TMT) program. In FY 2017, the SEC processed 117 

TMT requests, processed 244 RA requests, of which 106 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
26

Securities and Exchange Commission FY 2017

presentation on the following programs and processes: Disability Accommodations, 

Reasonable Accommodation, Temporary Medical Telework, Telework, and Leave 

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

the New Employee Handbook and made available on the new AskHR portal.

In FY 2017, the SEC designed business requirements to implement an electronic case 

management system that would allow employees to request reasonable 

accommodations personally and privately. During the requirements gathering phase 

for the new system, opportunities were identified that could 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 reasonable accommodation cases.

Going forward, the Agency will continue its efforts to implement the business 

requirements for the electronic case management system as further described in Part 

H of this report, supra.

Further, the Agency’s policy on reasonable accommodation is currently undergoing 

final review for approval following OHR’s standard policy development procedures. 

During FY 2018, the Agency will review the electronic case management system’s 

business requirements, the new policy, and related procedural changes that support 

reasonable accommodation for employees and applicants for employment. This 

review will address coverage of required and recommended elements defined under 

Section 501 of the Rehabilitation Act, as amended in 2017. Changes to reasonable 

accommodation procedures will likely necessitate updates to training, job aids, 

notices, and other information sources in FY 2019 and beyond.

D. PERSONAL ASSISTANCE SERVICES ALLOWING EMPLOYEES TO 

PARTICIPATE IN THE WORKPLACE

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

are required to provide personal assistance services (PAS) to employees who need them 

because of a targeted disability, unless doing so would impose an undue hardship on the 

agency.

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

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

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

monitoring PAS requests for trends.

Section VII: EEO Complaint and Findings Data

A. EEO COMPLAINT DATA INVOLVING HARASSMENT

The Disability Program Office recently updated the reasonable accommodation policy 

to include requests for PAS. The policy is in OHR's internal review process and will be 

sent to EEOC for final review thereafter. In the interim, the Agency entered into a 

contract to support employees needing PAS. The Agency currently has one employee 

using PAS. OHR proactively reached out to this employee and shared the recent 

EEOC regulations on PAS earlier in FY 2017. OHR is developing communications to 

share with employees and managers regarding the availability of PAS for those in 

need.
27

Securities and Exchange Commission FY 2017

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?

Answer: No

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?

Answer: Yes

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.

B. EEO COMPLAINT DATA INVOLVING REASONABLE 

ACCOMMODATION

1. During the last fiscal year, did a higher percentage of PWD file a formalEEO 

complaint alleging failure to provide a reasonable accommodation, as 

compared to the government-wide average?

Answer: No

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?

Answer: Yes

3. If the agency had one or more findings of discrimination involving the failureto 

provide a reasonable accommodation during the last fiscal year, please 

describe the corrective measures taken by the agency.

Section VIII: 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?

Answer: No

2. Has the agency established a plan to correct the barrier(s) involving PWD 

and/or PWTD?

Answer: Yes

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.

The Agency did not have any findings of discrimination alleging harassment based on 

disability status.

The Agency did not have any findings of discrimination involving the failure to provide 

a reasonable accommodation.
28

Securities and Exchange Commission FY 2017

Trigger 1

There is a lower-than-expected participation rate of Persons with Targeted 

Disabilities in the total workforce and in promotions to higher level positions. The 

participation rate of PWTD in the SEC’s workforce was less than 1% in FY 2014 

based on the then-current Standard Form 256 (SF-256) Self Identification of 

Disability. Participation has increased based on the revised categories reflected in 

the new October 2016 version of the SF-256 to 1.84% in FY 2017.

Barrier(s)

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:

• 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;

• Consistency and structure in the posting, screening, and interview processes 

for selection;

• Awareness on the part of hiring managers and subject matter experts or others 

involved in recruitment and selection about the requirements for and flexibilities 

available under government-wide programs supporting PWD and the affirmative 

action plan for PWTD; and

• Employment programs, especially reasonable accommodation and disability 

programs, supportive of PWD and PWTD.

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 this barrier analysis focused 

on persons with targeted disabilities. Going forward, as the Agency prepares for 

implementation of the revised regulation in FY 2018, OEEO will leverage or expand 

this prior work to include the population of persons with disabilities in the workforce. 

The objective of these efforts will be to continue to implement action plans 

developed to address PWTD and expand those plans in line with revised regulation. 

Additional action will focus on:

• Analysis of quantitative data and 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 tablespresenting 

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?

(Yes or No)

Lacey Dingman, Chief Human Capital Officer, OHR Yes

Peter Henry, Acting Director, OEEO Yes

Barrier Analysis Process Completed? 

(Yes or No)

Barrier(s) Identified? 

(Yes or No)
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Securities and Exchange Commission FY 2017

Barrier Analysis Process Completed? 

(Yes or No)

Barrier(s) Identified? 

(Yes or No)

Yes No

Sources of Data

Sources 

Reviewed?

(Yes or No)

Identify Information Collected

Workforce Data Tables Yes

Analyzed applicable workforce demographic

data from FY 2011 - FY 2015.

Complaint Data (Trends) Yes

Reviewed complaints filed by PWTD during

FY2013-FY2016 for any trends

Grievance Data (Trends) No

Findings from Decisions (e.g., 

EEO, Grievance, MSPB, AntiHarassment Processes) No

Not applicable.

Climate Assessment Survey (e.g., 

FEVS) Yes

Reviewed Federal Employee Viewpoint 

Survey results from FY 2013 through FY 

2015 to compare responses from persons 

with disabilities to those with no disability.

Exit Interview Data Yes

Reviewed Exit Survey data from FY 2016

and FY 2017 provided by persons with 

disabilities.

Focus Groups No

Interviews Yes

Interviewed 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

Reviewed 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

Researched and reviewed the law and

federally mandated hiring and promotions 

policies, practices, and procedures 

applicable to recruitment and retention of 

PWTD; reviewed the Agency's hiring and 

promotions policies, practices, and 

procedures applicable to people with 

disabilities, including PWTD; reviewed the 

efficiency and effectiveness of the SEC's 

reasonable accommodation program; and 

reviewed selection case files (hiring and 

promotions) for the second half of FY 2014 

and the first half of FY 2015.

Target Date 

(mm/dd/yyyy)

Planned Activities Sufficient 

Staffing & 

Funding 

(Yes or No)

Modified 

Date 

(mm/dd/yyyy)

Completion 

Date 

(mm/dd/yyyy)
30

Securities and Exchange Commission FY 2017

02/28/2019 OEEO will implement feasible 

changes to the workforce data tables 

providing information on PWD and 

PWTD in collaboration with a shared 

service provider.

Yes

11/30/2017 OEEO will conduct a Workplace 

Experience Survey of the Agency 

workforce to explore employee 

perceptions among the population of 

PWD and PWTD as well as those 

without disabilities on, among other 

topics, the recruitment, hiring, 

promotion, recognition, and retention 

of talent.

Yes 11/30/2017

01/31/2018 The Agency will establish a crossfunctional working group with 

representatives from OEEO and 

OHR to develop action plans and 

implement required and 

recommended activity under Section 

501 of the Rehabilitation Act of 1973.

Yes 01/31/2018

Fiscal Year Accomplishments

2017 Representatives from OEEO and OHR implemented a number of actions

2016 OHR engaged in the following recruitment/outreach initiatives:

4. Please explain the factor(s) that prevented the agency from timelycompleting 

any of the planned activities.

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

impact of those activities toward eliminating the barrier(s).

OEEO considered launching a Workplace Experience survey in the summer of 2017. 

To avoid interfering with an OHR survey focused on career development of 

employees currently holding SK-15, SK-16, and SK-17 levels into higher level 

leadership ranks, the OEEO Workplace Experience survey was rescheduled for 

October and early November of 2017.

Representatives of OEEO and OHR agreed to take action toward enhancing equal 

employment opportunity for PWTD and proposed 15 actions to address 

recommendations from the study of PWTD.

As of September 30, 2017, 12 of those actions have been closed or completed, one 

was transitioned to an ongoing monitoring status, and two are under review 

pending some action or decision.

The actions toward improvement related to:

• Embracing best practices suggested by OPM and EEOC on recruiting, 

hiring, retaining, and promoting PWD and PWTD;

• Adding structure to programs for the hiring, development, advancement, and 

retention of PWD and PWTD, including programs focused on training persons with 

no disability toward greater inclusion of PWTD;

• Issuing, communicating, and training those directly involved in the hiring or 

promotions process on the policy memorandum entitled: Requirements for 

Screening and Interviewing Job Candidates (PM-2016-001) to include the 

requirement of documenting decisions made at all phases of the selection process;

• Expanding and leveraging relations with external affinity groups and with DIAC to
31

Securities and Exchange Commission FY 2017

support strategic relationships with professional organizations focused on individuals 

with disabilities;

• Proactively developing and implementing strategies with and through DIAC to 

retain employees who are PWTD;

• Developing communications and hosting events focused on PWTD to highlight 

successes from that population;

• Improving tracking and analysis of complaints and other relevant data forPWTD; 

and

• Formalizing the responsibilities of a Selective Placement Program Managerwithin 

OHR to focus on employment programs and initiatives for PWTD.

Because of the relatively small size of the PWTD population, 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 over the five years ending in FY 2017:

• Over the five year period from FY 2013 through FY 2017, the permanent 

workforce of PWTD experienced net growth of 9 persons or 12.50%, which 

approximates the 13.08% net growth in the total permanent workforce over that same 

time period. The participation rate of permanent PWTD employees in the SEC’s 

workforce remained virtually unchanged over this period (a decline of .01% points), 

and the participation rate of PWTD SK-11 and higher declined .15% points to 1.56%.

• Over the five year period from FY 2013 through FY 2017, the permanent 

workforce of PWD experienced net growth of 118 persons or 57.84%. The 

participation rate of permanent PWD employees in the SEC’s workforce grew at a rate 

of 22.65% to 7.15%, and the participation rate of PWD SK-11 and higher increased 

1.69% points (a growth rate of 19.96% or nearly 20%) to 6.63% over this five year 

period.

The SEC 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. Please note, data from SF-256 collected prior to October 2016 were 

recharacterized against the definitions found in the revised form in order to estimate 

the five year trends. As such, the numbers of employees who are reported in this 

trend analysis as PWTD and/or PWD in prior years may underestimate the workforce 

due the addition of disability and targeted disability categories.

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, as reflected above, continue to require 

focused attention toward improvement. Starting in FY 2016 and through FY 2017, 

representatives of OEEO and OHR initiated and completed actions intended to 

address the recommendations to improve equal employment opportunity. These 

actions will continue into FY 2018.

In the interim, the EEOC issued revised guidance and regulation focused on PWD and 

PWTD in the federal workforce. Changes to regulation require and recommend 

additional affirmative action on the part of agencies regarding the recruitment, hiring, 

development, advancement, recognition, and retention of PWD and PWTD.

The Agency will be implementing additional required and recommended actions 

during FY 2018 and beyond.