National Council on Disability

US Foreign Policy and Disability 2017: Progress and Promise

National Council on Disability

March 8, 2018

1 
2 

National Council on Disability

An independent federal agency making recommendations to the President and Congress to 

enhance the quality of life for all Americans with disabilities and their families.

Letter of Transmittal 

Dear Mr. President: 

On behalf of the National Council on Disability (NCD), I am pleased to submit this report 

titled US Foreign Policy and Disability: Progress and Promise 2017. 

One billion people, or 15 percent of the world’s population, experience some form of 

disability, and an estimated 80% of people with disabilities live in developing countries, 

post-conflict societies, among refugee populations, and in countries with histories of 

political violence. People with disabilities and their families are subject to economic and 

social marginalization, segregation, discrimination, and a broad range of other civil and 

human rights violations around the world. The lack of protection against discrimination 

and exclusion leads to economic hardship and a loss of productive capacity. The World 

Bank has reported the enormous cost of excluding people with disabilities—estimating 

the global Gross Domestic Product loss due to disability to be between $1.71 trillion to 

$2.23 trillion annually. 

The US government maintains thousands of international programs administered by 

agencies at a cost of billions annually. Because people with disabilities are a significant 

portion of the developing world’s population, any sizable US government program 

overseas has the potential to attract participants and employees with disabilities and 

impact the quality of life of people with disabilities in those countries through its policies 

and activities. 

In previous studies on US foreign policy, NCD sought to advance understanding and to 

promote accessibility and inclusion of people with disabilities in foreign assistance 

programs funded by the United States by examining the extent to which US disability 

rights laws were extended in international settings through the activities of the 

Department of State (DOS), the United States Agency for International Development 

(USAID), the Department of Defense (DOD), and the Peace Corps. The studies 

examined the employment, accessibility, and outreach policies and programs of these 

agencies. US Foreign Policy and Disability: Progress and Promise 2017 follows-up on 

NCD’s previous foreign policy studies by providing a current assessment of the 

application of federal disability laws in US foreign aid programs administered by DOS, 

USAID, and the Peace Corps, detailing the extent to which these agencies have 

developed new planning or programs to ensure the inclusion of people with disabilities 

and removed the barriers to access to people with disabilities identified in NCD’s prior 

reports. It also provides NCD’s first examination of the policies and practices of the 

Millennium Challenge Corporation regarding disability inclusion. 

March 8, 2018 

The President 

The White House 

Washington, DC 20500 
3 

National Council on Disability 

An independent federal agency making recommendations to the President and Congress to 

enhance the quality of life for all Americans with disabilities and their families.

Unfortunately, while mainstreamed inclusion of disability in development has the 

potential to improve social and economic inclusion; findings from this study suggest that 

improvements still need to be made to ensure that people with disabilities are not left 

behind in US foreign aid programs. This report finds across all agencies examined: 

nonexistent or outdated formal disability policies; significant underrepresentation of 

employees with disabilities; unclear recruitment and retention policies and supports for 

employees with disabilities; inadequate human and fiscal resources dedicated to the 

institutionalization of system-wide inclusion; absence of accountability due to 

inadequate monitoring of the number of people with disabilities included in foreign aid 

programs from design to implementation and evaluation; unclear public information 

related to disability access and inclusion on agency webpages; inconsistent physical 

accessibility to structures and programs overseas, and disparate implementation of 

international standards. There is still work to be done. 

This report makes recommendations aimed at strengthening the inclusion and 

accessibility of US foreign aid programs that are grounded in a basic premise: that 

overseas economic development will not be successful unless people with disabilities 

are included in US programs overseas. 

NCD looks forward to working with you in ensuring that the goals of US foreign aid 

programs are inclusive of and accessible to people with disabilities, and that the 

recommendations in this report are implemented. 

Clyde E. Terry 

Chairperson 
4

US Foreign Policy and Disability ................................................................................. 6

Executive Summary ...................................................................................................... 8

1. Disability and Development: Background and Literature .................................... 17

1.1. Disability Prevalence and Demographics ........................................................... 17

1.2. Social and Economic Exclusion and Discrimination ............................................ 18

1.3. US Foreign Assistance and Accessibility ............................................................ 19

1.4. Global Development and Disability Frameworks ................................................ 19

2. Right to Inclusion and Participation in Foreign Policy and Assistance: 

Legal Overview ............................................................................................................ 22

2.1. Federal Disability Rights Laws ............................................................................ 23

2.2. Executive Orders and Implementing Regulations ............................................... 25

2.3. Foreign Assistance and Respect for Human Rights ........................................... 26

3. Disability Policy and Practice: Agency Implementation ...................................... 28

3.1. Department of State: Disability Policy and Practice .......................................... 28

3.1.1. Policies and Guidance ................................................................................. 29

3.1.2. Responsibility and Resources ...................................................................... 29

3.2. USAID: Disability Policy and Practice ................................................................. 31

3.2.1. Oversight and Staffing .................................................................................. 32

3.3. Peace Corps: Disability Policy and Practice ...................................................... 35

3.3.1. Agency Reporting and Disability .................................................................. 35

3.4. Millennium Challenge Corporation: Disability Policy and Practice .................. 38

3.4.1. Gender and Social Inclusion ........................................................................ 38

4. Employment and Participation: Agency Implementation .................................... 42

4.1. Department of State: Employment and Participation ........................................ 46

4.2. USAID: Employment and Participation ............................................................... 48

4.2.1. Office of Civil Rights and Diversity ............................................................... 49

4.2.2. Careers ........................................................................................................ 49

4.2.3. Advancing Disability Inclusive Development ................................................ 50

4.3. Peace Corps: Employment and Participation .................................................... 51

4.3.1. Compliance .................................................................................................. 52

4.3.2. Diversity and Inclusion ................................................................................. 53

4.4. Millennium Challenge Corporation: Employment and Participation ................ 56

5. Accessibility and Inclusion: Agency Implementation .......................................... 61

5.1. Department of State: Physical Accessibility ...................................................... 61

5.1.1. The Bureau of Overseas Building Operations .............................................. 61

5.1.2. Accessibility Guidelines ................................................................................ 63

5.2. USAID: Physical Accessibility............................................................................. 65

5.2.1. USAID Construction Assessment ................................................................. 65

5.2.2. Wheelchair Program .................................................................................... 67

5.3. Peace Corps: Accessibility and Accommodations for Peace Corps 

 Volunteers ................................................................................................................ 68

5.3.1. Health and Physical Accessibility ................................................................. 68

5.3.2. Accessible Projects ...................................................................................... 69

5.4. Millennium Challenge Corporation: Physical Accessibility.............................. 70
5

6. Foreign Assistance Programs: Agency Implementation ..................................... 75

6.1. Department of State: Foreign Assistance Programs ......................................... 75

6.2. USAID: Foreign Assistance Programs ............................................................... 80

6.2.1. USAID: Disability Inclusive Development ..................................................... 80

6.2.2. USAID: Funding Policies and Guidance ....................................................... 81

6.3. Peace Corps: Foreign Assistance Programs ..................................................... 84

6.3.1. Underrepresented Groups: Peace Corps Volunteer Recruitment ................ 84

6.4. Millennium Challenge Corporation: Foreign Assistance Programs ................ 87

7. Recommendations and Action Steps .................................................................... 89

7.1. Vision and Practice ............................................................................................. 90

7.1.1. Systems Change and Collaboration ............................................................. 90

7.2. Recommendations: Law & Cross-Agency Policies ............................................. 91

7.3. Recommendations: Department of State.......................................................... 94

7.4. Recommendations: USAID................................................................................. 95

7.5. Recommendations: Peace Corps ...................................................................... 96

7.6. Recommendations: Millennium Challenge Corporation.................................. 98

7.7. Conclusions and Limitations ............................................................................... 99

7.7.1. Methodology and Sources of Information ................................................... 100

Appendix A. Summary of Previous NCD Foreign Policy and Disability 

Recommendations .................................................................................................. 101

Appendix B. Disabled People's Organization Survey Summary ......................... 105

Appendix C. Detailed Review of Human Rights Reporting .................................. 105

Endnotes .................................................................................................................. 112
6

US Foreign Policy and Disability 

“There is no escaping our obligations: our moral obligations as a wise leader 

and good neighbor in the interdependent community of free nations—our 

economic obligations as the wealthiest people in a world of largely poor 

people, as a nation no longer dependent upon the loans from abroad that once 

helped us develop our own economy—and our political obligations as the 

single largest counter to the adversaries of freedom.”

—John F. Kennedy 

In the five decades since President Kennedy categorized US foreign assistance as a 

moral, political and economic obligation, we have seen progress; thanks to the support 

of the United States, individuals across the globe are living longer, healthier, and fuller 

lives. For 50 years, US-foreign-aid-funded projects and programs have helped to 

increase access to education, promote justice and improve social and economic 

outcomes, for most. 

Unfortunately, despite emerging inclusive development efforts, people with disabilities, 

the world’s largest minority group, remain marginalized. Rendered vulnerable by the 

physical, social and cultural barriers encountered by having a disability, this sector of 

the population relies on the support of foreign aid and assistance to access basic 

human rights. Yet, as you will see in the chapter that follows, disproportionate exclusion 

of people with disabilities and resulting inequities exist and, in fact, are an ongoing, 

global crisis. 

Approximately 800 million people with disabilities living in developing countries1 look to 

the United States through a cautiously optimistic lens, hopeful that the world’s largest 

contributor to foreign aid2

 will remain steadfast in its long-standing commitment to 

inclusion. The release of this report at the start of a new Administration is intended to 

offer a resource for implementing fresh perspectives and achieving the limitless promise 

of sustainable development for all. 
7

As the next installment in a series of National Council on Disability Foreign Policy 

Reports3,4,5

, US Foreign Policy and Disability: Progress and Promise 2017 includes: 

 an executive summary, outlining core concepts and key findings; 

 a brief history of US foreign policy and introduction to four of the United States’ 

primary agencies responsible for providing foreign assistance; 

 background and supporting literature on disability and disability inclusive 

development; 

 an updated overview of US laws and policy related to disability inclusion; 

 findings related to agency implementation of disability policy, disability inclusive 

employment and volunteer participation, physical and web accessibility and 

disability inclusive foreign assistance programs and projects including agency 

specific examples of promising practices and/or missed opportunities; 

 progress reporting on previous NCD recommendations for the US Department of 

State (DOS) and the US Agency for International Development (USAID); and

 targeted recommendations and action steps for improved disability inclusion. 

The report is organized into chapters by topic, each with an agency-specific sub-section 

focused on policy and program implementation. The appendices that follow summarize 

findings by agency, and, in some instances, provide further detail, examples, and 

context. 

Findings from previous reports have helped policymakers, including the White House 

and Congress, to make policy decisions that have improved the inclusion of people with 

disabilities in US foreign aid programs and operations overseas. The goal of this report 

is to highlight that progress, while at the same time calling attention to the ways in which 

agencies responsible for managing and executing US foreign assistance can promote 

inclusive development as part of a shared commitment to achieving greatness for all 

people. 
8

Executive Summary 

This report provides an up-to-date review of the inclusion of people with disabilities in 

US foreign policy efforts. This includes a current analysis of federal disability rights law, 

executive orders and implementing regulations, and foreign assistance and human 

rights related to disability inclusion. In addition, the policies and practices of four federal 

agencies responsible for either funding or executing US foreign assistance activities, 

were reviewed for inclusion of disability. The agencies of interest were the Department 

of State (DOS), the United States Agency for International Development (USAID), the 

Peace Corps and the Millennium Challenge Corporation (MCC). 

Evaluation methods included an extensive desk review of each agency and applicable 

legal and policy documents, key informant interviews with agency staff members and 

program participants, and a survey assessing the accessibility of agency programs and 

facilities, including informational, attitudinal, and physical access. Core areas of 

investigation were: 

1. employment of people with disabilities within federal agencies; 

2. access to information and physical accessibility of federal agencies; and 

3. the inclusion of people with disabilities in foreign assistance programs. 

Results of the data analysis show that some progress has been made in regard to the 

inclusion of people with disabilities (e.g., establishing and appointing a Special Advisor 

for International Disability Rights at the DOS), yet efforts often suffer from the “silo 

effect” and lack sustained and coordinated engagement. In addition, a persistent lack of 

accountability—through data collection, monitoring, and evaluation—diffuses 

responsibility for ensuring the inclusion of people with disabilities in programs and 

policies agency-wide. 
9

Key findings relevant to all agencies (the DOS, USAID, the Peace Corps, and MCC) 

include: 

 nonexistent or outdated formal disability policies; 

 significant underrepresentation of employees with disabilities; 

 unclear recruitment and retention policies and supports for employees with 

disabilities; 

 inadequate human and fiscal resources dedicated to the institutionalization of 

system-wide inclusion (i.e., the progress made within some programs is not 

universally applied); 

 absence of accountability through disability-disaggregated data and monitoring 

and evaluation practices (e.g., adequately monitoring the number of persons with 

disabilities (PWDs) included in foreign aid programs from design to 

implementation and evaluation); 

 public information related to disability access and inclusion lacking in clarity (i.e., 

agency webpages are difficult to navigate, and information relating to disability is 

difficult to find); and 

 physical accessibility is inconsistently achieved overseas, and the 

implementation of international standards is disparate. 

Moving forward, agencies should focus their attention on developing inclusive policies 

and programs that are: 

Collaborative Participatory, engaging, and inclusive of diverse stakeholders,

especially those with disabilities

Operationalized Systematized across all programs, projects, and sectors, and 

which include supporting policies and guidance

Resourced Equipped with fiscal and human resources to meet the needs 

of the population

Equitable Accessible, measurable, and transparent
10

General recommendations for action can be applied across the agencies (for a full list of 

agency-specific recommendations see Chapter 7) and outlined below using the CORE 

framework: 

Collaborative 

 Ratify the Convention on the Rights of Persons with Disabilities 

 Model and promote disability inclusion among government and program partners 

 Develop consultative global advisory boards/committees 

 Explore public/private partnerships 

 Implement iterative beneficiary feedback 

 Build capacity in employees and partners 

Operationalized 

 Develop, implement, or update formal disability policies and guidance 

 Mainstream disability inclusion across programs and sectors 

 Standardize program monitoring and evaluation, data collection, and reporting 

Resourced 

 Prioritize disability inclusive development funding 

 Establish, appoint, and fill disability coordinator positions 

 Provide funding for awareness building 

Equitable 

 Clarify current legislation 

 Improve accessibility and representation 

 Consistently report progress and results 

 Continue efforts and programs that promote a disability inclusive workforce 

To effectively translate these recommendations into action, agency leadership and 

stakeholders must proactively map strategies that go beyond avoiding discrimination 

and instead create new pathways to economic, physical, and social inclusion. As the 

world’s largest foreign aid contributor, the United States has a responsibility to lead by 

example. Prioritizing people with disabilities is a move in the right direction 
11
12

Department of State: Mission and Values 

The mission of the Department of State (DOS) “is to shape and sustain a peaceful, 

prosperous, just, and democratic world and foster conditions for stability and progress 

for the benefit of the American people and people everywhere”.6 The DOS is the 

diplomatic face of the nation and the main agent of American foreign policy. From its 

beginnings as the first federal agency created under the Constitution, the DOS has 

grown into an agency that now maintains a diplomatic presence in over 180 countries, 

employs over 75,000 individuals, and oversees an annual budget of over 27 billion US 

dollars) 

The State Department’s diplomatic role is highly visible and carries with it the need to 

set an example of democratic freedoms, respect for human rights at home and abroad, 

and advocacy for the same freedoms and respect in other countries. The DOS does this 

through: (a) foreign assistance; (b) direct consular services to Americans and foreign 

nationals at home and abroad; and (c) cultural and educational exchange programs 

between the United States and other countries.
13

The US Agency for International Development (USAID): Mission and Values 

For more than 70 years, the United States has provided development assistance to 

countries in need, with priorities ranging from basic human needs, financial stabilization, 

and economic growth, to sustainability, democracy, and post-war rebuilding. In 2013, 

USAID adopted a new mission statement, committing to “partner to end extreme 

poverty and promote resilient, democratic societies while advancing our security and 

prosperity.”

7

 To support societies in reaching their full potential, the organization 

prioritizes promotion of “free, peaceful, and self-reliant societies with effective, legitimate 

governments; building human capital and creating social safety nets that reach the 

poorest and most vulnerable.”

8 USAID’s core values include individual and collective 

passion for its mission and commitment to achieving excellence. The organization 

believes that demonstrating integrity and respect is critical to empowering others, and 

works to build an inclusive culture that promotes continued learning and improvement at 

the individual and organizational level. 

USAID’s organizational structure is comprised of individualized bureaus and offices that 

have independent areas of focus but shared responsibilities. Led by a team of 

administrators and senior executives and funded by Congress, the organization awards 

the majority of their funds through competitive contracts, grants, and cooperative 

agreements. With missions (offices and staff) in more than 80 countries, and programs 

in more than 100, staff and program teams spend less than one percent of the federal 

budget to carry out work in areas including: agriculture, economic growth, education, 

democracy, and human rights and governance. 
14

Peace Corps: Mission and Values 

Volunteers serving on behalf of the Peace Corps have worked for more than 50 years to 

address critical issues in 140 countries. As an independent agency within the executive 

branch of the United States Government, the Peace Corps is overseen by the Senate 

Committee on Foreign Relations and the House Committee on Foreign Affairs. With a 

general annual budget of approximately one percent of the US foreign operations 

budget, the agency provides service opportunities “for motivated change-makers to 

immerse themselves in a community abroad, working side by side with local leaders to 

tackle the most pressing challenges of our generation”.

9

The Peace Corps mission of promoting world peace and friendship is achieved by 

providing trained men and women to interested countries and improving understanding 

of Americans by those in the countries they serve, and vice versa. Their mission of 

promoting inclusion and diversity of people in some of the most excluded and 

economically challenged areas of the world is driven by change makers who seek 

reform through a variety of global initiatives. The agency strives to provide marginalized 

populations and disadvantaged groups—such as women and girls, people with 

disabilities, ethnic and religious minorities, and others—with programming and 

assistance in order to foster improvements in access to health care, education, 

infrastructure, agriculture, and community economic development.

Currently, the Peace Corps works in 65 countries and engages in community-led

projects that support sustainable growth through programming in agriculture, business, 

community growth, education, environment, health, female empowerment, gender 

equality, technology, water and sanitation, and youth. 
15

Millennium Challenge Corporation (MCC): Mission and Values 

The Mission and Congressional mandate of the Millennium Challenge Corporation is 

poverty reduction through economic growth. With a strong belief that gender and social 

inequality are significant constraints to economic growth and poverty reduction, MCC’s 

mission is executed with a focus on inclusion, striving to reach the poorest, most 

disadvantaged and potentially excluded groups. This includes but is not limited to 

women, youth, ethnic and religious minorities, people with disabilities, and more 

generally, the poorest of the poor. MCC’s projects are designed to provide these groups 

with improved access to infrastructure, land, health care, education, and productive 

roles within the economy. 

MCC’s emphasis on catalyzing inclusive economic growth, evidence-based decision

making, and transparency is helping to drive international efforts to achieve the 17 

interconnected Sustainable Development Goals that make up the United Nations 2030 

Agenda for Sustainable Development. MCC’s approach is unique in that it carefully 

selects the “best governed” developing countries to enable them to lift themselves out of 

poverty. With a core belief that aid is more effective in a country with a strong 

commitment to accountable and democratic governance, MCC contributes to 

strengthening democratic institutions and processes.10
16
17

1. Disability and Development: Background and Literature 

This chapter presents disability as a complex, global issue and includes prevalence and 

demographic information, an overview of the history and evolution of disability inclusive 

development, and evidence to support claims of economic and social disparities. This 

section also highlights relevant global agendas, including the United Nations’ 

Transforming our World: The 2030 Agenda for Sustainable Development and The 

Convention on the Rights of People with Disabilities (CRPD). 

“Marginalization is the most dangerous form of oppression”

- Iris Young, 2004 

1.1. Disability Prevalence and Demographics 

According to the World Health Organization Report on Disability,11 approximately fifteen 

percent of the world’s population, more than one billion people, live with some form of a 

disability. To understand disability in context, it is important to note that disability is part 

of the human condition, and that much of the human population will experience disability 

at some point throughout life, whether temporarily or permanently. There have been 

many different models developed to define disability; however, for the purpose of this 

report, disability is understood based on the International Classification of Functioning, 

Disability, and Health (ICF), developed by the World Health Organization (WHO) in 

2011 and the UN Convention on the Rights of People with Disabilities (CRPD). WHO 

defines disability as a complex umbrella term that includes impairments (problems in 

body function or structure), activity limitations (difficulty encountered by an individual in 

executing a task or action), and participation restrictions (problems experienced by an 

individual in involvement in life situations). The term “disability” involves not only the 

individuals themselves, but also the interaction between their bodies and the features of 

society in which they live. This interaction dovetails with the CRPD, which adopts a 

social model of disability and defines disability as including “those who have long-term 

physical, mental, intellectual or sensory impairments which in interaction with various 

barriers may hinder their full and effective participation in society on an equal basis with 

others.”

12
18

As many as eighty percent of people with disabilities in developing countries live in 

isolated rural areas, where necessary medical resources and other related services are 

rare.13 A previous NCD foreign policy report indicates that of that eighty percent, only 

about two percent have access to rehabilitation and appropriate basic services. In both 

developed and developing countries, research suggests that people with disabilities are 

at a disadvantage in many aspects of life, including educational attainment, labor 

market outcomes, financial stability, housing and standard of living conditions, and 

more. 

1.2. Social and Economic Exclusion and Discrimination 

Due its bidirectional link to poverty, disability is identified as a developmental issue, 

since disability may increase the risk of poverty and vice versa. This dynamic and 

intricately linked phenomenon is documented in empirical literature that indicates a 

higher level of economic and social exclusion for people with disabilities and their 

families in developed and developing countries.14 Both poverty and social exclusion 

have been linked to other disadvantages and discrimination including employment, 

housing, and participation in community life.

While many people with disabilities have broken barriers to inclusion, shattered 

stereotypes about limitations, and contributed to the economic, cultural, and political 

welfare of their communities, there are still many issues that stand in the way of full 

inclusion and access for these individuals. In most areas of the developing world, 

people with disabilities and their families are not only socially stigmatized, but also 

politically marginalized and economically disadvantaged. Exclusion and marginalization 

increase the risk of poverty and limit their access to necessary medical, educational, 

and financial support services. In addition, the majority of people with disabilities in the 

developing world do not have access to the statutes, regulations, and legal protections 

that US citizens have (see Chapter 3). Lack of access to justice increases vulnerability 

and limits their ability to advocate for social, economic and physical inclusion. There is 

also a lack of infrastructure in developing areas, which makes it difficult for people with 

disabilities who live, work, or visit those countries to access basic human rights. 
19

1.3. US Foreign Assistance and Accessibility 

According to the 2013 report issued by the National Council on Disability, “the situation 

of people with disabilities in developing countries underscores the critical need to 

ensure that foreign assistance programming is directed toward advancing disability 

rights and eliminating barriers to inclusion for people with disabilities.”

15 The United 

States is well positioned to model strategies for increasing and building on the human 

potential of people with disabilities; assistance efforts abroad would improve greatly if 

the principles established in US civil rights law, under the Rehabilitation Act and the 

Americans with Disabilities Act, were applied to all foreign operations abroad. 

Application of the aforementioned laws and other disability rights laws would not only 

provide essential guidance for US government agencies when implementing foreign 

assistance programs, but would also ensure that US citizens and contractors with 

disabilities, who are living outside of the US, would be protected against discrimination 

in the implementation of US program abroad. Specific examples focused on 

employment and volunteer programs are included in the chapters that follow. 

US citizens seeking to provide assistance abroad, through volunteering or cultural and 

educational exchanges, often face a number of barriers including inaccessible buildings, 

transportation, information and communication technology, and others. To echo the 

findings of the NCD 2013 report, the US is the world’s largest bilateral development 

donor, and therefore should ensure that the taxpayer dollars not only support foreign 

assistance programs, but are inclusive of and accessible to all, including people with 

disabilities. 

1.4. Global Development and Disability Frameworks 

The United States is widely recognized as a leader in disability rights and, as such, has 

a moral obligation to lead and participate in international movements and global 

frameworks impacting people with disabilities. Two such frameworks are the UN 

Convention on the Rights of People with Disabilities (CRPD), which incorporates many 

aspects of US legislation and policy, and the 2030 Agenda for Sustainable 

Development. 
20

Article 32 of the Convention on the Rights of Persons with Disabilities16 (CRPD), of 

which the United States is a signatory, clearly highlights the role of international 

cooperation in ensuring that people with disabilities are not excluded from development 

initiatives. This includes the role of international cooperation in supporting national 

efforts for realizing the objectives of the Convention, while promoting the inclusion and 

accessibility of people with disabilities in international development programs. Others 

aspect of international cooperation include capacity building, training programs and best 

practices, sharing of technical knowledge, and partnership with regional organizations 

and civil society.

The 2030 Agenda for Sustainable Development and its commitment to leaving no one 

behind has gone ahead of the Millennium Development Goals17 (MDGs) to explicitly 

include people with disabilities, thereby opening doors for their participation and 

recognition as active contributing members of society who should not be discriminated 

against in any way or left behind (IDDC 2016). US foreign aid aims to fight poverty and 

enhance lives in developing regions through implementing initiatives to advance global 

health, improve education, contribute to food security, and more.18 These frameworks 

are integral to advancing rights and opportunities for people with disabilities and apply 

to both developing and developed nations. Alignment between these global frameworks 

and the mandate of our agencies of interest (the DOS, USAID, Peace Corps, and MCC) 

is outlined in the agency sections that follow.
21
22

2. Right to Inclusion and Participation in Foreign Policy and 

Assistance: Legal Overview 

This chapter identifies key pieces of legislation related to disability inclusion as it applies 

to US citizens living abroad as well as those participating in programs and projects that 

are funded or executed by one or more of the four agencies that are the focus of this 

report. Agency implementation of the laws and legislation referenced in this section is 

discussed in detail in the chapters that follow. 

“Many people depend on the United States’ strong voice as an advocate for equality 

under the law and individual rights. They look to this country to continue to prioritize 

populations which face discrimination in their daily lives.”

InterAction, 201619

US law has recognized the rights of people with disabilities to live free from 

discrimination and enjoy full inclusion in social and economic life for decades. Beginning 

with the Architectural Barriers Act (ABA), 42 U.S.C. §§ 4151 et seq., signed in 1968, 

followed shortly after by the Rehabilitation Act, 29 U.S.C. §§ 791 et seq. in 1973, and 

continuing with the landmark Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12111 

et seq., signed in 1990, the United States has developed a legislative framework that 

mandates respect for the rights of people with disabilities by public and private entities 

alike.20 This includes recognition of the rights of people with disabilities outside the 

United States through their inclusion in foreign policy. 

The following is a brief survey of US anti-discrimination laws and their applicability to 

federal agencies in their domestic and international operations, particularly in the areas 

of employment, program design, and facility construction. 
23

2.1. Federal Disability Rights Laws 

The primary source of protections for people with disabilities with respect to the 

conduct of the Federal Government is the Rehabilitation Act, 29 U.S.C. §§ 791 et seq. 

(Pub. L. No. 93-112 (1973)). The Rehabilitation Act prohibits discrimination against 

people with disabilities in the employment practices of federal agencies,21 (Section 

501), including with respect to the treatment of independent contractors22; in access to 

facilities (Section 502) 23; in federal contracting (Section 503)24; in any federal program 

or activity (Section 504)25; and in access to information (Section 508).26 Section 501 

requires federal agencies to take affirmative steps to promote the hiring, placement, 

and advancement of persons with disabilities within each agency and submit annual 

reports on their progress. Section 503 prohibits discrimination against people with 

disabilities by federal contractors and similarly requires such contractors to take 

affirmative actions to employ and promote people with disabilities.27

Section 504 of the Rehabilitation Act prohibits discrimination against people with 

disabilities in any program or activity receiving federal financial assistance or under 

any program or activity conducted by any federal agency.28 “Program or activity” is 

defined broadly, applying to operations of state and local governments that receive 

federal assistance, including their sub-agencies; colleges, universities, and other 

postsecondary institutions, whether public or private; and private organizations like 

corporations and partnerships that receive assistance or are “principally engaged in 

the business of providing education, health care, housing, social services, or parks 

and recreation.”29

Section 508 of the Rehabilitation Act (29 U.S.C. § 794 (d)) requires federal agencies 

to make their electronic and information technologies accessible to people with 

disabilities, including employees of the Federal Government and members of the 

public. It applies to all federal agencies and covers the development, procurement, 

maintenance, and use of electronic, information, and communication technology 

(ICT).30 It requires the full range of every federal agency’s “public-facing” content, as 

well as specified non-public-facing content, to be accessible. 
24

While the Rehabilitation Act applies to the Federal Government, the Americans with 

Disabilities Act (ADA)31 extends ADA protections to the public at large and regulates 

private conduct. The ADA prohibits discrimination across several different spheres, 

including employment (Title I), public services offered by state and local 

governments (Title II), public accommodations (Title III), and telecommunications 

(Title IV), as well as other miscellaneous areas (Title V). Title I is especially 

important because protects employees working both domestically and abroad. In its 

foreign operation, Title I it is limited to the protection of US citizens working for US 

employers.32 This means that US citizens who work for international companies or 

corporations that were established outside of the US, protections are limited to those 

laws and policies mandated by the organization’s home base of record. 

In addition to the Rehabilitation Act and the ADA, the Architectural Barriers Act 

(ABA) supports accessibility for people with disabilities by requiring that, with two 

exceptions,33 all buildings and facilities designed, constructed, amended, or leased 

with federal funds be accessible to people with physical disabilities.34 It also requires 

certain federal agencies to set standards to ensure compliance of those facilities 

covered by the law, including those operated by the Department of Housing and 

Urban Development, the Department of Defense35, the US Postal Service, and the 

General Services Administration, which prescribes standards for all facilities outside 

the purview of the other listed agencies, including those with overseas operations.36

In addition to these landmark laws, people with disabilities in federal employment are 

also entitled to the protections against discrimination contained in the Civil Service 

Reform Act of 1978 (Pub. L. No. 95-454) and protection from retaliation under the 

Notification and Federal Employee Antidiscrimination and Retaliation Act of 2003 

(NO FEAR; Pub. L. No. 107-174). The former prohibits any “personnel action” that 

discriminates against a federal employee or applicant on the basis of disability 

(Section 2302(b)(1)(D)), while the latter prohibits retaliation against federal 

employees for claims of discrimination and requires all federal agencies to submit 

annual reports documenting claims of discrimination made against them, as well as 
25

any disciplinary actions taken as a result (Section 203(a)). As will be evident below, 

the reporting requirements of the NO FEAR Act have been effective in promoting 

greater attention to the rights of people with disabilities within the agencies of 

interest. 

2.2. Executive Orders and Implementing Regulations 

The statutory framework outlined above is supplemented by a series of Executive 

Orders that establish guidelines for federal agencies to eliminate discrimination 

against people with disabilities and encourage their inclusion in federal employment. 

Executive Order 13163, Increasing the Opportunity for Individuals with Disabilities to 

be Employed in the Federal Government37 and its companion, Executive Order 

1316438, Establishing Procedures to Facilitate the Provision of Reasonable 

Accommodation, call on federal agencies to expand their outreach efforts to recruit 

more people with disabilities and increase efforts to promote their accommodation in 

federal employment. 

Executive Order 13548, Increasing Federal Employment of Individuals with 

Disabilities,

39 reaffirms that it is US government policy to reduce discrimination 

against people with disabilities and encourage these people to seek employment in 

the Federal Government. The Order recognizes that it is essential for the Federal 

Government “to become a model for the employment of people with disabilities” and 

to improve efforts to recruit, retain, and promote people with disabilities.

In January 2017, the EEOC adopted a final rule to codify these guidelines and 

specify the steps agencies must take to increase the number of federal employees 

with disabilities.40 Among other things, the rule requires agencies to provide personal 

assistance services for employees with certain disabilities so that they can fully 

participate in work and work-related travel. Chapter 4 provides supplemental 

information and highlights progress and challenges related to implementation. 
26

2.3. Foreign Assistance and Respect for Human Rights 

The legal frameworks surveyed above reflect a commitment to advance the rights of 

people with disabilities living within the United States and those US citizens living 

and working abroad for US employers. With the passage of the Foreign Assistance 

Act in 1961 (Pub. L. No. 87-195), Congress extended these efforts, establishing that 

respect for individual rights and an equitable distribution of the benefits of 

development should be among the primary goals of US foreign policy (Section 

101.3). Sections 116 and 502(b) of the Act condition the provision of assistance to 

any government on respect for internationally recognized human rights, and call for 

assessments of the human rights records of all potential recipients of assistance.41

The Act is unequivocal that “[n]o assistance may be provided” to any government 

that commits gross violations of human rights. This is a critical piece of legislation for 

people with disabilities who are more vulnerable to social and economic exclusion, 

violence and unsafe conditions. 

The combined force of this broad legal framework—which covers the inclusion of 

people with disabilities in federal and federally-financed programs and employment, 

accessibility of public facilities and electronic and information technologies, and 

conditions under which foreign assistance may be provided offers a powerful base 

from which federal agencies must act to meaningfully include people with disabilities 

in their activities, including their activities abroad. How the agencies of interest are 

implementing this framework in their respective policies and practices will be the 

subject of the following sections. 
27

“Free Me”: An Indonesian Childhood in Chains

In 2017, Human Rights Watch published a story about 15-year-old Subetki, who spent 

six years immobile, chained to the floor by his ankles in his home in Serang, Indonesia. 

Prompted by a neighbor’s attempt to use the media to bring attention to the young 

man’s living conditions, members from the National Commission for Child Protection 

(Komnas Anak) intervened and were told by the family that he was chained to protect 

the community. Sadly, Subetki is not alone and his story is not uncommon. 

As a result of absence of knowledge of mental health issues, and dangerous 

misconceptions and false beliefs attributing mental illness to possession by evil spirits, 

sinning or partaking in immoral behavior, more than 57,000 people in Indonesia have 

been subjected to pasung—shackled or locked up in confined space—at least once in 

their lives. In 1977, the Government banned such practices, but according to families 

interviewed by Human Rights Watch, lack of government support and services for 

individuals with mental health issues leave many families feeling like chains and 

shackling are their only options. 

Unfortunately, despite his pleas to “free me”, eight days later Subetki remained chained 

in his home- just one kilometer from the local government office.42
28

3. Disability Policy and Practice: Agency Implementation 

As federal agencies responsible for either funding or executing US foreign assistance 

activities, the Department of State (DOS), the United States Agency for International 

Development (USAID), the Peace Corps, and the Millennium Challenge Corporation 

(MCC) are governed by the laws and regulations explained in Chapter 2 however, 

internal policies guide each agency’s approach to disability inclusion.

I believe that the defining challenge of our era is to shift to a new model of 

development—one that is more inclusive and more attuned to the world we live in, one 

that is more visionary, depicting the world we want; one in which we are all valued, 

respected and afforded opportunities to reach our highest potential. 

- Charlotte McClain-Nhlapo, 

Global Disability Advisor, World Bank and 

former USAID Global Advisor on Disability and Inclusive Development 

(USAID 2014)43

This chapter identifies core disability inclusion policies within each agency and provides 

examples that illustrate their approach to implementation. The chapters that follow focus 

specifically on programs and policies related to: employment (Chapter 4), access to 

information and physical accessibility (Chapter 5), and foreign assistance programs 

(Chapter 6). In addition to the programs and policies themselves, these chapters 

contain case examples that address missed opportunities. Then, Chapter 7 presents 

recommendations and proposed action steps to address these missed opportunities. 

3.1. Department of State: Disability Policy and Practice

According to the US Department of State’s International Disability Rights webpage, the 

Department is dedicated to facilitating the inclusion of people with disabilities as part of 

its foreign policy approach. Noting that “discrimination against people with disabilities is 

not simply unjust”, but “hinders economic development, limits democracy, and erodes 

societies,” the agency presents a brief but clear overview of their opposition to 

discrimination and commitment to partnering with governments and civil society to 

promote inclusion across sectors. 
29

3.1.1. Policies and Guidance 

Interestingly, although the Department has clear, publically available messaging that 

outlines its stance on “pursuing diplomacy that is inclusive and empowering of persons 

with disabilities,”44 the content has not been expanded upon and translated into a formal 

disability policy. This lack of publically available agency guidance was noted in previous 

NCD reports, and recommendations were made that the Department adopt a formal 

disability policy as well as issue policy statements on its compliance with the 

Rehabilitation Act, with specific emphasis on Sections 501, 503, and 504, clarifying its 

application in the United States and abroad. Communications with DOS staff reveal that 

in 2013 the State Department issued a policy on disability inclusion through an ALDAC 

Cable 13-STATE-7082 entitled, Advancing Disability-Inclusive Diplomacy as a Global 

Policy Priority. Unfortunately, this cable is not a publically available document; which 

limits visibility of the agency’s concerted efforts to increase inclusion of people with 

disabilities in as a “Global Policy Priority”. 

3.1.2. Responsibility and Resources 

Following the U.S. signing of the Convention on the Rights of Persons with Disabilities, 

the Special Advisor for International Disability Rights (SADR) was appointed. The 

position, housed in the Bureau of Democracy, Human Rights and Labor, is the most 

senior-level disability human rights position at the State Department. The person filling it 

“coordinates the interagency process for the ratification of the Disabilities Treaty; 

ensures that foreign assistance incorporates persons with disabilities; leads on disability 

Policy and Perception

The Department of State’s prominent global presence among agencies that provide 

U.S. foreign assistance presents a unique opportunity to position itself as a leader in 

disability inclusion. In this instance, the lack of a formal disability policy and failure to 

follow the lead of more visibly inclusive bureaus within the Department itself, whose 

mission and policy statements include disability-specific language, exemplifies the 

power of perception. Despite its website’s inclusive sentiment, the agency’s failure to 

act in response to NCD’s recommendations may be viewed as silence on the issue—

a silence that is deafening for the 800,000,000 people with disabilities living in 

developing countries that look to the United States to help their voices be heard.
30

human rights issues; ensures that the needs of persons with disabilities are addressed 

in international emergency situations; and conducts public diplomacy, including with civil 

society, on disability issues”.

Based on interviews with employees of several bureaus, the visibility of people with 

disabilities in DOS policies and programs has been raised within the department 

through the public presence of the SADR, increased interagency cooperation, affinity 

groups, and a greater number of bureaus with someone designated to address disability 

rights45. Unfortunately, while staff reporting suggests significant improvement, the 

dearth of disability disaggregated data on program investments and outcomes (fiscal 

and human resources) makes it difficult to effectively analyze or report out on the return 

on investment. 

Visibility, Data and Decision Making

The ability to measure effective progress is directly correlated to the presence and 

accessibility of data and information. By no means is the absence of disabilitydisaggregated data relegated exclusively to the Department of State; rather it is a 

persistent issue impacting the majority of bi-lateral and multi-lateral development 

agencies. Despite the presence of US laws that address the inclusion of people with 

disabilities abroad (Sections 501, 504 and 508 of the Rehabilitation Act), the 

Department falls short in its noted absence of a publically available, formal, agencydirected policy for the inclusion of people with disabilities in US foreign assistance. 

While the agency reports that internal cables exist, it remains unclear why such 

efforts to improve inclusion of people with disabilities are not visible to the public. This 

type of gap in accessible information makes it challenging to obtain disability 

disaggregated data and reporting. This is a major issue because of the widespread 

disparities in the inclusion of people with disabilities in mainstream development 

programming and the number of programs and projects that are funded or overseen 

by the DOS. Additionally, public-facing disability inclusive policies help to measure 

performance of programs and ensure accountability of partners abroad; making it 

easier to track investment and advocate for critical funding that supports the physical, 

economic and social wellbeing of people with disabilities across the globe. 
31

3.2. USAID: Disability Policy and Practice

Nearly a decade before the adoption of The Convention on the Rights of Persons with 

Disabilities, USAID was leading the way for disability inclusive development. Following a 

recommendation from NCD in 1996, the agency published its first disability policy paper. 

Published in September 1997, by the Bureau for Policy and Program Coordination, the 

policy served as evidence of the agency’s investment in people with physical and 

cognitive disabilities and those who advocate on their behalf. Citing a commitment to 

avoiding discrimination and a desire to stimulate engagement with in-country 

counterparts and governments, the policy extends from program and project design to 

implementation, with the simple goal of promoting “the inclusion of people with 

disabilities both within USAID programs and in host countries where USAID has 

programs”.

46

Twenty years later, the agency has established a number of programs and invested in 

projects that respond to the unique needs of people with disabilities, but the policy has 

remained unchanged. NCD has addressed the value of the policy and the need for 

revisions that respond to the changing needs of people with disabilities in each of its 

previous Foreign Policy and Disability reports, and similar recommendations have been 

made by other stakeholder agencies.47,48 Unfortunately, while key informant interviews 

acknowledge that the existing policy is outdated, USAID’s Bureau of Policy, Planning 

and Learning (PLL), USAID reports via key informant interview, that there is “not a 

current effort in place to update the policy”. It is unclear why policy updates have not 

been made over the past two decades; the agency cites changing Administration as the 

current, primary barrier to policy revision, and expressed plans to revisit the topic with 

new leadership.49
32

3.2.1. Oversight and Staffing 

In addition to the Disability Policy recommendations, previous NCD reports have 

identified the need for adequate staffing and resources to support implementation of 

disability inclusive programming. According to communications with USAID staff, the 

agency “has made a deliberate and concerted effort to move coordinator positions into 

the related technical bureaus,” resulting in the Disability Coordinator position moving to 

the Center of Excellence on Democracy, Human Rights and Governance (DRG), which 

is housed within the larger Democracy, Conflict and Humanitarian Affairs (DCHA) 

Bureau. Unfortunately, the position of Disability Coordinator is currently vacant, and 

disability-related work is managed by the DRG/DCHA staff. 

The role appears to have been vacant since the departure of the former Disability 

Coordinator in 2014. Communications with USAID staff and leadership reveal that the 

Agency did attempt to fill this position under the Obama Administration but were 

unsuccessful. It is unclear whether the Disability Coordinator position was ever posted 

as a job vacancy using the USAID careers portal, but at this time, the position is not 

posted. 

In the absence of a Disability Coordinator, USAID has made reported efforts to 

decentralize disability work, with the goal of increasing disability inclusion across 

sectors. This includes appointing a full-time staff member in their Education Office in the 

Bureau for Economic Growth, Environment and Education (E3) who is dedicated to 

Monitoring and Evaluation

Typically, in the development sector, monitoring and evaluation refers to the ways in 

which funding agencies track the progress of their partners and grantees. However, 

in this instance, USAID is lacking an internal process for measuring its own progress. 

This has not always been the case. From 1997 to 2008, USAID published five reports 

on the implementation of its disability policy. The publications, produced bi-annually, 

highlighted inclusive practices and presented recommendations. It is unclear why the 

agency discontinued this practice, because doing so not only leaves a gap in its 

disability-specific program monitoring and evaluation, but also sets a negative 

precedent for holding partner agencies accountable for tracking similar results.
33

disability inclusion. Yet despite the addition of this new role, it remains to be seen how 

USAID will measure the impact of their cross-sector efforts given the absence of an 

agency-wide coordinator. The recommendations presented in Chapter 7 expand on the 

need for a more systematized, agency-wide approach to disability inclusion. 

In addition to the need for human capital devoted to disability, previous NCD 

recommendations from 2013 also note the need for “ample resources...and finances” 

for this work. At this time, USAID reports that funding for targeted disability 

programming (through the agency’s Empowerment and Inclusion Division) has been 

fairly consistent over the past 10 fiscal years, with a budget of approximately 25 million 

US dollars per year.50

 

The majority of disability programming is housed within the Programs for Vulnerable 

Populations (within The Center of Excellence on Democracy, Human Rights and 

Governance). Unfortunately, a lack of disability-disaggregated data makes tracking 

disability specific budgets and investments extremely challenging. Therefore, the 

following findings are based on financial information specific to the strategic objective, 

Investing in People (which includes social and economic services and protection for 

vulnerable populations).51

 

 Investment in Disability Programs: The 2016 total net cost of operations for 

USAID was approximately $12.5 billion (usd). Of that, 3.2 billion was allocated to 

Investing in People and $281.5 million went to Social and Economic Services 

and Protection for Vulnerable Populations. Using the $25 million figure provided 

by USAID, this means that only eight percent of the total budget for vulnerable 

populations is allocated to disability. This is extremely concerning given the 

magnitude of marginalization and exclusion experienced by people with 

disabilities. 

 Stagnant Budget: The net cost/budget for Investing in People has increased by 

more than $430 million since 2013. However, according to USAID key informant 

interviews, the budget for disability programs has remained consistent. 
34

The Invisible Billion 

According to USAID’s own Advancing Disability Inclusive Development52 webpage, in 

spite of disabilities link to poverty, and evidence of disproportionate marginalization and 

exclusion, people with disabilities remain “invisible” in the global development agenda. 

Unfortunately, despite the agency’s reported commitment to improving disability 

inclusive development, its financial investments tell a different, contradictory story. If

USAID’s 2016 investment in disability was 25 million dollars (as reported in key 

informant interviews), that equates to just .002% of it’s nearly 12.5 billion total net cost 

of operations. 

In addition to disability specific programs, USAID’s twin tracked approach to inclusive 

development seeks to integrate disability into all of its programs. Noting a commitment 

to ensuring that all USAID programming should be accessible to all individuals, 

including people with disabilities, the agency reports concerted efforts to shift away from 

appropriated funding and to promote disability inclusion in other sectors of their work. 

Unfortunately, while mainstreamed inclusion of disability in development has the 

potential to improve social and economic inclusion; findings from this study suggest that 

USAID currently lacks the infrastructure and tools for monitoring and evaluation 

necessary to ensure that people with disabilities are not left behind. 

Tracking Investment 

USAID considers itself a “business focused development agency focused on results” 

and has a number of tools in place to help track and monitor its investments and 

progress. From the illustrative Dollars to Results53 platform to the Development 

Experience Clearinghouse,54 the agency has worked tirelessly to make their data 

publically available and transparent. Disappointingly, despite the plethora of digital 

resources and consistent agency self-evaluations and reporting, tracking resources and 

investment in disability is incredibly arduous. Unlike other population-based areas of 

work, none of the available resources include disability as a targeted topic or keyword. 

This not only makes it difficult to evaluate dissemination of resources earmarked for 

disability-specific work, but it also brings to the surface a larger question: why, with 

everything USAID knows about the marginalization and exclusion of people with 

disabilities, are they yet again not included? 
35

Additional information related to USAID’s disability policies is included throughout this 

report. Please see the following chapters and appendices for further detail and targeted 

topical content: Employment–Chapter 4, Access to Information, Physical 

Accessibility–Chapter 5, Foreign Assistance Programs (including resource 

allocation and monitoring and evaluation)–Chapter 6. A summary of detailed 

recommendations can be found in Chapter 7. 

3.3. Peace Corps: Disability Policy and Practice 

For five decades, the Peace Corps has brought the United States’ spirit of volunteerism 

to 141 countries across the globe. During this time, more than 225,000 individuals have 

contributed to the agency’s mission of promoting peace and friendship by bringing their 

unique experience and knowledge to partner countries to help tackle projects across 

multiple sectors including agriculture, environment, community economic development, 

health, education, and youth in development. 

Until now, the Peace Corps has not been included in National Council on Disability and 

Foreign Assistance evaluations. Therefore, unlike the Department of State and USAID, 

which had previous recommendations to build upon, researchers analyzing agency 

policy on disability inclusion relied heavily on publically available information on the 

Peace Corps website,55 including strategic plans and annual reports. Unfortunately, 

while there is evidence of disability inclusion in Peace Corps-funded projects abroad 

(see Chapter 6–Foreign Assistance), the lack of public-facing disability-specific policies 

(with the exception of non-discrimination in employment- see Chapter 4), combined with 

limited disability-related information on the agency’s website make it more challenging 

to evaluate the agency’s investment in disability inclusion. 

3.3.1. Agency Reporting and Disability 

In an effort to better understand the Peace Corps’ approach to disability inclusion, the 

team responsible for collecting data for this report reviewed the agency’s Performance 

and Accountability Report56 Congressional Budget Justification57 and Strategic Plan 

(2014–2018)58

. Despite the comprehensive nature of each of the documents, a key 
36

word search (“disability”, “disabilities”, “disabled”) found only eight total mentions among 

all three publications. Of those, five briefly mentioned disability as part of compensation 

and insurance documentation, one referenced a project in Mongolia focused on Special 

Olympics, and one alluded to the agency’s diversity and inclusion program (additional

detail in Chapter 4–Employment). 

Clearly, the documents referenced above are not an exhaustive sample; however, as 

the primary reporting of the Peace Corps’ initiatives and priorities, the visible absence of 

disability throughout is concerning and should be remedied. 

Note: In response to initial reporting, the Peace Corps provided researchers with the 

agency’s FY 2016 Annual Performance Report & FY 2018 Annual Performance Plan59. 

Using the same search terms listed above, “disability”, “disabilities”, “disabled”, 

produced only one result. 

The agency’s performance goal 6.2: Build an Open and Inclusive Organizational 

Culture is intended to, “Increase the percentage of Peace Corps Volunteers, U.S. direct 

hire staff, and host country staff who agree that the agency has an inclusive 

organizational culture to 90 percent and maintain that level of performance through FY 

2018” 60

. Among the target populations, are individuals with disabilities. 

Overview: This performance goal measures the openness and inclusion 

of the Peace Corps as perceived by post staff, headquarters staff, and 

Volunteers with respect to race, ethnicity, age, sex, disability, religion, 

sexual orientation, veteran status, family status, and gender identity or 

expression. This direct outcome measure can be used to evaluate how all 

groups perceive the agency’s culture of inclusion and to what extent 

employees and Volunteers feel valued. 

While it is encouraging to see that the agency is explicitly focusing on creating a 

culture of inclusion, they continue to report that the goal was met among host 
37

country staff, but not among U.S. direct hire staff or volunteers. See chapter 4 for 

additional information about efforts to increase staff training on intercultural 

competence, diversity, and inclusion (ICD&I). 

In conclusion, even with the updated information provided by the Peace Corps, 

the agency is still lacking a public-facing policy that explicitly responds to the 

need to increase the number of staff and volunteers with disabilities. It is strongly 

recommended that leadership consider mirroring efforts like those focused on 

same-sex couples as a way to increase disability awareness and inclusion. 

Additional evidence of where disability is and is not included amongst Peace Corps 

activities is included throughout the report: specific examples focused on employees 

and volunteers with disabilities are given in Chapter 4, access to information and 

physical accessibility are covered in Chapter 5, and case studies that highlight inclusive 

projects abroad can be found in Chapter 6. Chapter 7 then summarizes missed 

opportunities and provides recommendations. 

Access to Information: FOIA

The Peace Corps is subject to the Freedom of Information Act (FOIA), including 

provisions of the act providing individuals with the right to request records created by 

the Peace Corps and other federal agencies. Given the absence of publically 

available, disability-specific information accessible via the Peace Corps website, the 

research team attempted to use the FOIA process to collect additional data for 

analysis. While the FOIA is designed to support transparency and accessibility, in this 

instance the process was time consuming and yielded a very limited amount of 

usable information. Researchers attempted to contact multiple staff members but 

were consistently redirected to the FOIA process, thus negatively impacting access 

to information.

Note: Follow up communications with the Peace Corps (November 2017) reveal that 

delays in accessing information via FOIA were delayed as “FOIA requests for 

information were under review outside of the FOIA office”. This points to a need for 

increased, public-facing, accessible information related to disability inclusion in the 

Peace Corps. 
38

Disability Inclusion: Stories and News 

Initial review of the Peace Corps public-facing content revealed a disproportionate lack 

of disability specific stories and news (as compared to other marginalized groups 

(LGBTQ & Over 50). However, with the support of Peace Corps staff, several of 

stories and examples were brought to researchers’ attention, including a 2014 profile 

of a volunteer with hearing loss, a 2010 video highlighting the placement process 

for a volunteer with a visual impairment, a 2011 video highlighting experiences of 

Deaf volunteers at the 2011 Smithsonian Folk Festival, and a 2011 video sharing the 

experience of a volunteer with a physical disability supporting Special Olympics in 

Paraguay.61–64

While these examples certainly highlight disability inclusion, they are dated and far and 

few between. The majority are more than five years old and considering that there are 

hundreds of videos on the agency’s YouTube channel,65 and close to 1,000 stories on 

the Peace Corps website, there is certainly room for improvement with regards to 

sharing information and experiences related to disability. 

The Peace Corps would benefit from targeted outreach to volunteers with disabilities 

and should establish a centralized web page that reflects the agency’s commitment to 

disability inclusion. 

3.4. Millennium Challenge Corporation: Disability Policy and Practice 

This is the first examination made by the National Council on Disability of the Millennium 

Challenge Corporation (MCC); therefore, no previous recommendations for the 

inclusion of people with disabilities have been made. Information specific to MCC’s 

breadth of disability specific work is extremely limited; therefore, this chapter highlights 

other agency programs targeted at including vulnerable groups. The goal is to highlight 

the need for disability policies and programs and to identify areas where disability can 

be added to existing programs. 

3.4.1. Gender and Social Inclusion 

In an effort to reduce gender disparities in their programs, MCC has developed a policy 

that applies to all of its programs. According to MCC’s webpage on gender and social 

inclusion, “gender and social inequality are known constraints to economic growth, and 

research shows that the benefits from poverty reduction initiatives are unequally shared 
39

with women and marginalized populations;” therefore, inclusion of these people is a 

core component of their work. MCC regards disability as a cross-cutting issue that is 

included in the definition of marginalized populations.

66

It is important to note that while marginalized populations are referred to on the Gender 

and Social Inclusion webpage, MCC’s only official policy related to inclusion, entitled 

“Gender Policy”—which appears Chapter 4 of the organization’s Compact Development 

Guidance document and was referenced throughout interviews with MCC staff 

members—is explicit to gender equality. The Gender Integration Guidelines, however, do 

make broader statements regarding gender and social inclusion, stressing that “gender 

integration is the incorporation of social and gender analyses throughout development 

processes and institutions in order to have more sustainable and equitable outcomes”. 

With some revision (i.e.—specifying people with disabilities) this analyses provides an 

opportunity for disability to be included under the umbrella of social inclusion.

The integration process outlined by MCC proactively requires, through the support of 

the Social and Gender Assessment (SGA) staff, partner countries to participate in 

designing and integrating gender throughout the compact agreement process (i.e., from 

project inception and implementation to monitoring and evaluation). Partner countries 

are also required to have a person with social and gender analytical, design, and 

management skills on their core team to ensure social and gender equality are 

incorporated from inception to implementation of projects. In addition, once the compact 

officially begins, MCC and the partner country hold an implementation workshop that 

explicitly includes the topic of gender integration to ensure that all team members have 

a similar understanding of gender integration throughout the project. Communications 

with staff at MCC reveal that while there is not a formal disability policy, implementation 

workshops also include a focus on social inclusion topics; including the exclusion of 

groups based on income level, age, geographic location, ethnicity and disability. 

To ensure equal and consistent representation of people with disabilities, MCC would 

benefit from formalizing its curriculum and making the contents of the implementation 

workshops publically available. 
40

Interviews with MCC staff and a review of the eligibility criteria for MCC country partners 

show that disability is also considered as one of the social and political factors that 

could affect compact or threshold program development and implementation, as well as 

one of the factors that is of specific concern to the US Government. Specifically, the 

review board considers the “state of democratic and human rights (especially of 

vulnerable groups)”, which includes mention of people with disabilities when assessing 

MCC compact proposals. As such, disability is considered as supplemental information 

to be considered when selecting countries for threshold or compact programs. Although 

it is unclear what weight is given to these social and political factors, the treatment of 

people with disabilities is assessed through the State Department Human Rights Report 

and Freedom House’s Countries at the Crossroads Report67. 

In addition to considering people with disabilities when establishing threshold or 

compact programs, MCC has several informal processes for including people with 

disabilities, related to accessibility guidelines in overseas construction and the 

beneficiary consultation process; these processes will be expanded upon in Chapters 5 

and 6. 

Closing the Gap

It is no surprise that MCC has detailed policies and guidance related to gender 

inclusion. The marginalization of women and girls is a prominent issue not only in 

development, but also in organizations, classrooms, and communities across the 

globe. As one of the primary agencies responsible for managing and facilitating US 

foreign assistance, MCC is well placed to emerge as a leader in disability inclusion by 

extending their comprehensive social and gender policy to include people with 

disabilities. Similar findings for the other agencies profiled in this report show that 

making small semantic changes to explicitly include disability has the potential to 

create big results in areas of data collection and investment tracking, workplace 

diversity and inclusion, and access to programs and projects. 
41

At a Glance: Law, Policy and the Global Agenda 

Disability Inclusive Employment 

US Legislation and Guidance: 

(1961) Foreign Assistance Act 

(1973) Rehabilitation Act 

(1978) Civil Service Reform Act 

(1990) Americans with Disabilities Act 

(2003) Notification and Federal Employee Antidiscrimination and Retaliation Act (NO 

FEAR) 

(2000) Executive Orders 13163 and 13164 

(2010) Executive Order 13548 

The Convention on the Rights of Persons with Disabilities (2007) 

Article 5: Countries are to recognize that all persons are equal before the law, to prohibit 

discrimination on the basis of disability and guarantee equal legal protection. 

Article 26: Countries are to provide comprehensive habilitation services in the areas of 

health, employment and education to enable persons with disabilities to attain maximum 

independence and ability. 

Article 27: Countries are to prohibit discrimination in job-related matters, promote selfemployment and entrepreneurship, employee people with disabilities in the public sector 

and promote employment in the private sector and ensure that they receive reasonable 

accommodations in the workplace. 

The 2030 Agenda for Sustainable Development 

Goal 8: Promotes inclusive economic growth, full and productive employment allowing 

persons with disabilities to fully access the job market 
42

4. Employment and Participation: Agency Implementation 

As the nation’s largest employer and party to more than $400 billion annually in federal 

contracts with private employers, the US government has both a responsibility and 

opportunity to model best practices in inclusive hiring, retention, and training for people 

with disabilities. This is especially critical to ensure that our US presence overseas is 

demonstrative of a diverse and inclusive workforce. The United States has long been a 

global leader in promoting inclusive employment opportunities for people with 

disabilities. These practices and initiatives are overseen by the US Department of 

Labor’s Offices of Disability Employment Policy (ODEP) and Federal Contract 

Compliance Programs (OFCCP), the Equal Employment Opportunity Commission 

(EEOC), and the Office of Personnel Management (OPM). 

In the conduct of diplomacy and development, people are critical. Indeed, the success 

of the Department of State and USAID is directly tied to the knowledge, skills, integrity, 

and creativity of our dedicated employees. Their principles, talents, and diversity—

reflecting the America they represent—strengthen their ability to move the world in the 

direction of greater democracy, security, and prosperity. 

-Bureau of Resource Management, 200768

On, July 26, 2010, with the goal of hiring 100,000 people with disabilities in 5 years, the 

previous Administration issued EO13548 on Increasing Federal Employment of 

Individuals with Disabilities. As part of this effort, specific guidelines were introduced to 

support agency implementation, including recruitment, retention, and reporting. See 

Disability and Employment Policies and Directives below for an overview of Standard 

Form (SF) 256-Self-Identification of Disability, Schedule A Hiring Authority for People 

with Intellectual Disabilities, Severe Physical Disabilities, or Psychiatric Disabilities (5 

CFR 213.3102(u)), and the statutory hiring authority for Veterans who are thirty percent 

or more disabled (5 U.S.C. 3112; 5 C.F.R. §§ 316.302, 316.402, and 315.707) and 

Management Directive 715. 
43

In September 2016, OPM published their Report on the Employment of People with 

Disabilities in the Federal Executive Branch69, which highlights the tremendous progress 

resulting from EO13548 on Increasing Federal Employment of Individuals with 

Disabilities. The tables below present an overview of OPM findings and highlights key 

data points from USAID, the DOS, and the Peace Corps. The table focuses on two 

areas of measurement, On Board Employees and New Hires, with comparisons 

between 2010 and 2015 to show progress over time. Note: Due to the agency sizes of 

the Peace Corps and Millennium Challenge Corporation, specific agency reporting 

could not be included within the larger OPM publication; however, employment-related 

information for these agencies is included in the agency subsections below. 

Disability and Employment Policies and Directives

SF 256 is the primary tool for employee self-identification of disability, developed for 

use by the Federal workforce.

Schedule A: A special authority, noncompetitive hiring process that allows for people 

with disabilities to be hired for specific positions within the Federal Government.

Schedule A, 5 CFR 213.3102(u), for hiring people with severe physical 

disabilities, psychiatric disabilities, and intellectual disabilities: This excepted 

authority is used to appoint people with severe physical disabilities, psychiatric 

disabilities, and intellectual disabilities.

Management Directive 715: Published by the EEOC, gives guidance to federal 

agencies on reporting under Section 501 of the Rehabilitation Act and further outlines 

agency leadership responsibility to demonstrate a commitment to disability inclusive 

employment, thus embedding the premise into agency culture.
44

Table 4a: All Career Employees 

On Board: All Career Employees

Nonseasonal, Full-time Career Employees

All Employees Targeted 

Disability70

All Disability

Federal Executive Branch 

2010 1,831,719 17,445/0.95% 129,546/7.07%

2015 1,838, 352 20,274/1.10% 173,997/9.46%

USAID

2010 2,130 14/0.66% 88/4.13%

2015 2,930 23/0.78% 140/4.78%

DOS

2010 8,959 48/0.54% 476/5.31%

2015 10,068 49/0.49% 573/5.69%

Peace Corps

2010 943 1/.11% 21/2.23%

2015 1002 4/.4% 43/4.29%

*NOTE: The information reported by the EEOC in the above mentioned sources was 

suspected as being inaccurate. The Peace Corps provided updated numbers to 

researchers that are reflected in the table71. However, it should be noted that the FY 

2010 and FY2015 MD715 reports cited as the source of information is not publicly 

available for verification. 
45

Table 4b. New Hires 

New Hires

Nonseasonal Full-time Career (Including Transfers)

All 

Employees

Targeted 

Disability

All Disability All Disability 

Including 30% 

or more 

Veterans

Schedule A

Federal Executive Branch

2010 151,999 1,178/0.78% 9,712/6.39% 18,926/12.45% 902/0.59%

2015 139,159 1,768/1.27% 14,519/10.43% 26,466/19.02% 2,403/1.73%

USAID

2010 217 1/0.46% 17/7.83% 22/10.14% 0/0.00%

2015 151 1/0.66% 11/7.28% 19/12.58% 10/6.62%

DOS

2010 557 3/0.54% 17/3.05% 44/7.90% 3/0.54%

2015 491 1/0.20% 31/6.31% 82/16.70% 6/1.22%

Peace Corps

2010 NO DATA

2015 448 1/.22% 23/5.13% n/a n/a

The data shows that currently, the Executive Branch of the Federal Government 

employs more people with disabilities, both by percentage and real number, than at any 

time in the past 35 years. Unfortunately, comparing data from USAID and DOS, which 

have the most comparable available data points, with that from the executive branch as 

a whole demonstrates that the foreign service agencies fall below government averages 

in almost every category72

. 

“The reality is, unless you go in and you look at hiring practices, employment practices, 

promotions, separation - unless you actively recruit candidates for your position, and not 

only give them equal access but provide them mentoring support before they get into 

your organization so they can compete for the position - then you’re failing.”

Don Steinberg, CEO, World Learning 

(2016)73
46

4.1. Department of State: Employment and Participation 

The Department of State (DOS) employs approximately 14,000 Foreign Service 

employees, 11,000 civil service employees, and another 50,000 local employees at 

overseas posts. It considers its workforce its most valuable asset in its effort to 

communicate and further U.S. foreign policy objectives and American values abroad.74

Employees provide expertise and knowledge that serve a broad variety of purposes, 

ranging from document storage and passport processing to research for treaty 

negotiations. Charged with “represent[ing] the United States to the world,” the DOS

promotes its commitment to diversity and inclusion as a way to visibly represent 

American values and policy goals around the globe. The DOS views its role as an 

employer as a form of leadership by example, and seeks to model diversity and 

inclusiveness in its human resource practices. 

Looking only at the hiring data presented above, the Department of State’s employment 

of people with disabilities is consistently below the Federal average. The DOS reports 

via key informant interviews that efforts to increase the employment of people with 

disabilities were hampered first by budgetary constraints caused by the economic 

downturn of 2008, and then by budget sequestration in 2011. In its’ 2016 Workforce 

Succession plan75, the DOS considers its overall hiring climate as “uncertain”.

Additionally the DOS has several active measures in place to promote the inclusion of 

people with disabilities in their workforce, including: 

 the Disability/Reasonable Accommodation Division (DRAD); 

 presence of a Special Personnel Placement Coordinator; and 

 ongoing recruitment, hiring, and retention efforts, including non-competitive 

Schedule A hiring, disability inclusive internships and ongoing partnerships with 

wounded warrior organizations and disabled veterans. 

As of FY 2016, the DRAD has been placed within the newly created Office of 

Accessibility and Accommodation (HR/OAA) in an effort to centralize accessibility and 

accommodation issues. Expanded recruitment, continued use of Schedule A hiring 
47

authority, and staff training in the utilization of that authority are among the efforts 

planned to increase the hiring of people with disabilities. In addition to hiring and 

recruitment initiatives, efforts to retain and promote employees with disabilities include 

better tracking of employees, encouraging employees to self-identify disabilities, 

increased availability of assistive technologies, and the establishment of a Disability 

Affinity Group within the Department. Communications with DOS staff also reveal that 

the in addition to creating a new office to centralize (internal) disability programs, they 

also created and SES position to oversee these efforts.76

Each of these developments have raised the overall profile of people with disabilities 

within the DOS and increased the visibility of disability rights in its work globally. 

According to key informant interviews, in recent years, there are more employees than 

ever before who have experience and expertise in disability rights, and additional 

numbers of staff are focused on disability in sections of the Department such as grantmaking, cultural exchanges, and disability rights and labor. Increasing staff awareness 

of disability issues has also been improved by way of staff training, which now includes 

a week-long human rights course that is held twice per year. Additionally, there are 

internal working groups in sections whose purpose is to help recruitment efforts and 

support current staff with disabilities. 

Additional information about ways disability inclusive hiring practices are improving 

inclusion in other program areas, including through DOS-managed volunteer programs, 

can be found in Chapter 6–Foreign Assistance Programs. 
48

The Representative Workforce 

Despite encouraging “U.S. businesses operating overseas as well as domestic host 

country businesses to take into consideration persons with disabilities in relation to 

employment practices and local stakeholder engagement, including in their labor and 

human rights corporate social responsibility policies, programs, and practices.”

77 Both 

OPM data and communications with stakeholders suggest that the DOS is struggling to 

follow its own lead. Having a workforce that is representative of the principles of 

diversity that the United States promotes to their partners abroad not only demonstrates 

a public commitment to inclusion, but also brings the lived experiences of the disability 

community to the table. A lack of consistent, participatory engagement of people with 

disabilities in developing policies and programs that impact their lives is a historical and 

persistent problem that extends far beyond the scope of work of the DOS; however, a 

strengthened focus and renewed commitment to developing a disability inclusive 

workplace would send a strong global message.

4.2. USAID: Employment and Participation 

In addition to complying with the legal mandates outlined in Chapter 3, USAID seeks to 

“promote and foster a diverse and inclusive workplace, free of discrimination, where all 

employees are valued and can contribute to their fullest potential”. Unfortunately, despite 

agency efforts, the OPM data above shows that with just fewer than five percent of their 

employees identified as having a disability, USAID consistently falls below federal averages. 

Key informant interviews did not uncover a clear reasoning behind the below average 

employment rates of people with disabilities at USAID. However, findings from this 

study suggest that navigating USAID’s approach to disability inclusive employment is 

made somewhat difficult by the way information is organized on their website. For 

example, careers information and logistics (vacancies, application instructions etc.), 

including information about the Disabilities Employment Program (guided by EO13548 

on Increasing Federal Employment of Individuals with Disabilities), is nested under the 

“Work with Us” link on the homepage; however, information about the agency’s diversity 

and inclusion practices, including reasonable accommodations, demographic reporting, 

and dispute resolution, is not linked and is found several clicks away under the 

“Independent Offices” link. Moreover, neither is represented on the agency’s core 

disability webpage, “Advancing Disability Inclusive Development.”
49

Information on disability inclusive employment is disbursed among multiple web pages; 

the following subsections highlight the information available. 

4.2.1. Office of Civil Rights and Diversity78

Disability is part of USAID’s larger workforce diversity and inclusion agenda. Tasked 

with overseeing these efforts, The Office of Civil Rights and Diversity (OCRD), an 

independent office reporting to USAID’s administrator, has two main areas of focus: 

Dispute, Intake, and Resolution (DIR) and Diversity Management and Outreach (DMO). 

For current and prospective employees with disabilities at USAID, the works of both 

sections of the office are equally important. 

4.2.2. Careers79

The careers page, which serves as the home of logistical information for those 

interested in direct-hire or contract positions located in the United States or abroad in 

USAID missions around the world, includes a link to the types of jobs available within 

the agency. This link including the Disabilities Employment Program and access to the 

Federal Employee Viewpoint Survey, which also touches upon issues related to 

employees with disabilities. 

Disabilities Employment Program 

In response to Executive Order 13458, USAID adopted its Disabilities Employment 

Program in 2010 in an effort to “improve their efforts to employ Federal workers with 

disabilities and targeted disabilities through increased recruitment, hiring, and retention 

of these individuals”.

80 The Disabilities Employment Program webpage provides very 

basic information about the program, including instructions for applying and a contact 

person; however, all details are linked to other agency websites.81–83

Roles and Responsibilities 

DIR manages the EEO complaint process, the Alternative Dispute Resolution 

Program, the Reasonable Accommodation process, and the Anti-harassment 

Program, while DMO provides diversity and inclusion training, manages special 

emphasis programs and reviews and analyzes race, sex, national origin, and 

disability workforce demographics.
50

Employee Viewpoint Survey 

As part of its commitment to transparency, USAID also published findings from the 2015 

Federal Employee Viewpoint Survey, conducted by the Office of Personnel 

Management. The survey, which evaluates several job satisfaction-related metrics, 

includes one question specifically targeted at assessing employees’ opinions of diversity 

efforts. The question reads: “Policies and programs promote diversity in the workplace 

(for example, recruiting minorities and women, training in awareness of diversity issues, 

mentoring)”84. Employee responses were primarily positive, with 62.26 percent of 

respondents (n = 1,819) reporting that they “strongly agree” (n = 294) or “agree” (n = 

849). However, 267 employees had a negative response, reporting that they either 

“disagree” (n = 164) or “strongly disagree” (n = 103). There is no additional information 

on how this information was used, if at all, at the agency level. 

4.2.3. Advancing Disability Inclusive Development85

While there is no mention of employment on the agency’s Disability Inclusive 

Development webpage, this page is the home of the agency’s related training for 

employees and partners. The 2013 NCD report included a recommendation that federal 

agencies, including USAID, introduce mandatory training in disability rights and 

disability inclusion in development. This recommendation was based on findings from 

previous reports indicating that personnel around the world are unfamiliar with 

strategies for disability inclusion in facilities, programs, and employment opportunities. 

USAID is making progress in this area and reports that hiring managers and HR 

professionals now must undergo mandatory disability training. These trainings occur every 

two years and are part of both new hire orientation and existing employee professional 

development. While the agency has yet to implement position-specific trainings for other 

staff, such as technical and budget officers, as was recommended in the NCD report, 

efforts are underway to develop a “Disability 102” training specifically targeted towards 

USAID personnel and focused on inclusion mandates within the agency’s automated 

directive system. The training serves as a follow-up to their current Disability 101 course, 

which is required for any USAID office or Mission that wants to receive disability funding. 
51

Trainings like Disability 101 are updated annually to reflect the evolving needs of the 

disability community and are developed in collaboration with relevant technical offices 

(i.e., Office of Education, Office of Gender Equality etc.), with the relevant disability 

technical specialist from the agency, and, at times, with relevant outside experts such 

as disabled peoples’ organizations.

4.3. Peace Corps: Employment and Participation 

In addition to the more than 7,000 volunteers serving in 65 countries, the Peace Corps 

also employs 1,093 direct hire staff and 3,007 locally-hired personnel (including shortterm language and cross-cultural training staff). In an effort to ensure that their 

workforce mirrors the diversity of the communities they serve, the Peace Corps follows 

standard operating procedures to comply with legal mandates and has a 

comprehensive diversity and inclusion policy aimed at promoting a “culture of inclusion.”

User Experience

Unfortunately, for current and/or prospective employees (with or without a disability), 

or even just for those interested in understanding the agency’s approach to disability 

inclusive employment, navigating multiple landing pages may prove difficult. While 

there is a plethora of information available for those willing and able to conduct a 

thorough web search, diversity and inclusion information (including reporting and 

policies and procedures) is not represented on the agency’s careers page, nor is 

there a link to the OCRD page, which contains additional links to demographic data 

and EEO reporting. Additionally, the Disability Inclusive Development webpage 

makes no mention of the agency’s having a diverse (disability inclusive) workforce as 

part of its overall agency strategy.
52

Volunteers or Employees? 

The research team responsible for compiling the data for this report raised the question 

of whether under US law, given Peace Corps volunteers’ direct oversight by the agency 

and receipt of a stipend and benefits, those volunteers should be categorized as 

employees. However, the Peace Corps Act (22 U.S.C. Sec. 2504(a)),86 expressly 

defines volunteers as nonemployees: “[E]xcept as otherwise provided in this chapter, 

volunteers shall not be deemed officers or employees or otherwise in the service or 

employment of, or holding office under, the United States for any purpose.” Cases 

raising discrimination claims by volunteers (or potential volunteers) have been brought 

under Section 504 of the Rehabilitation Act (on programs) and not 501 (on employees). 

The agency regulations cite to anti-discrimination provisions elsewhere, including 42 

U.S.C. Sec. 5057(a)(1), that prohibit discrimination on grounds of disability by “an 

individual with responsibility for the operation of a program that receives [federal 

financial] assistance,” including under Section 504, for its mandate against disability 

discrimination against volunteers. 

4.3.1. Compliance 

The Peace Corps provides an overall policy of equal opportunity employment for all 

people, and they provide affirmative employment action for people with disabilities 

through their Office of Civil Rights and Diversity (OCRD). Their policy statement related 

to equal opportunity is consistent with US laws and legal requirements for all federal 

agencies to establish Equal Employment Opportunity Programs (29 CFR Part 1614),87

with specific affirmative requirements in the areas of disabled veterans, members of 

underrepresented groups, people with disabilities, and additional authorities. 

Additionally, the Peace Corps follows a standard operating procedure for providing 

reasonable accommodations to people with disabilities, which is administered by the 

OCRD. From the time reasonable accommodations are requested, OCRD is available 

to offer guidance and assistance throughout the process. Information on 

accommodations can be accessed through the intranet, and trainings are offered in 

every New Employee Orientation (NEO). These trainings make new and existing 

employees aware of their rights and responsibilities, and can also be accessed from 

office staff on an as-needed basis. 
53

The OCRD is responsible for facilitating the reasonable accommodation request 

process throughout the agency, and all requests are monitored and evaluated for 

analysis and trending. In FY 2016, the OCRD offered at least six additional training 

opportunities in addition to the NEO trainings, and also disseminated educational 

resources and materials at National Disability Employment Awareness Month event. 

According to key informant interviews, in FY 2017, OCRD will finalize training materials, 

which will consist of an online training platform aimed at conveying the importance of 

providing reasonable accommodations for employees and volunteers88

. 

4.3.2. Diversity and Inclusion 

Beyond compliance with legal mandates, the “Peace Corps believes that having a 

diverse and inclusive agency is necessary to achieve its mission.”

89 As detailed in the 

agency’s FY 2015 Performance and Accountability Report, the Peace Corps actively 

seeks to build a culture of inclusion by:

1. building an organizational culture that connects each staff member to the Peace 

Corps mission; 

2. encouraging collaboration, flexibility, and fairness; and 

3. leveraging the diversity of skill sets throughout the agency so that all individuals are 

able to participate and contribute to their full potential. 
54

Data Collection and Reporting 

Of the agencies targeted in this report, the Peace Corps’ commitment to “building a 

culture of inclusion” is the most clearly stated, and their efforts to measure progress in 

this area should be highlighted. However, while the Peace Corps has clearly invested 

institutional resources in improving diversity and inclusion efforts, there is room for 

improvement in the way they report data to the public. 

For example, the agency set a goal for achieving a ninety percent rating on having an 

“open and inclusive organizational culture” by FY 2016 (Performance goal 6.2), which 

would be assessed by asking the Peace Corps volunteers to rate of the organization’s 

“level of inclusivity and openness with respect to race, ethnicity, age, sex, disability, 

religion, sexual orientation, veteran status, family status, and gender identity or 

expression.” In its 2015 Peace Corps Performance and Accountability Report, the 

agency states that this goal was met among host country staff, but not United States 

direct hires or volunteers. Further probing into the data shows that while the question 

posed to the staff allows for reporting specifically on the demographic sub-categories 

noted above, the public-facing content does not distinguish between demographic 

groups. This makes it more challenging to evaluate agency progress with regards to 

specific, underrepresented populations. 

Note: As mentioned in Chapter 3, the Peace Corps provided researchers with additional 

documentation following the agency’s technical review of the report contents. Among 

new sources of information was the FY 2016 Annual Performance Report & FY 2018 

Annual Performance Plan.

90 The updated report is consistent with the above information 

related to the agency’s failure to meet Goal 6.2, but does offer additional insight into the 

ways the agency is responding to this issue. One notable area is the mention of newly 

developed staff trainings. The Peace Corps reports that “by August of 2016, staff at 19 

posts had been trained on the same-sex couples initiative, and 13 posts had received 

the revised training on intercultural competence, diversity, and inclusion (ICD&I). Five 

posts received both of these trainings, and an additional five posts were scheduled to 

receive one or both trainings by the end of the year”. The contents of the updated ICD&I 

training are not publically available, making it impossible to measure the explicit 

inclusion disability inclusion. However, the agency’s explicit focus on same-sex couples 

as a training area is an example of a promising practice that can be adapted for 

disability inclusion.

Interestingly, despite its institutional investment in building a diverse workforce, the 

Peace Corps rarely mentions disability inclusion in its reporting and publications. As 

previously noted in Chapter 2, a review of the agency’s Performance and Accountability 

Report91

, Congressional Budget Justification92 and Strategic Plans93 revealed a 

combined total of eight mentions of disability, none of which reference hiring, 

recruitment, or retention practices. Note: The addition of the FY 2016 Annual 
55

Performance Report & FY 2018 Annual Performance Plan90 as a source of information 

(October 2017) discovered just one key word (“disability”; “disabilities”; “disabled”) 

mention of disability. 

The lack of public facing documentation presenting a commitment to disability is not 

necessarily reflective of institutional practices. A review of the OPM progress reports 

containing measurable evidence (on board members, employees, new hires, etc.) was 

inconclusive94; however, key informant interviews and data provided by Peace Corps 

staff (October 2017) revealed behind-the-scenes efforts to comply with Executive Order 

13548, including support for Schedule A hiring and a commitment to offering 

noncompetitive hiring options for people with disabilities and those who support them 

such as readers, interpreters, and personal assistants. 

In an effort to increase recruitment and retention of employees with disabilities, the 

agency reports that there is employee oversight by the Office of Human Resources 

Management (HRM), the Office of Diversity and National Outreach (ODNO), and the 

Office of Civil Rights and Diversity (OCRD). Additionally, Peace Corps reports that they 

have developed a marketing and recruitment plan that focuses on training and 

accountability for hiring managers; unfortunately, due to lack of publically available 

information, at this time it is unclear how this plan has translated into practice within the 

agency. 
56

4.4. Millennium Challenge Corporation: Employment and Participation 

Hiring and promotion of people with disabilities within MCC is overseen by the Human 

Resources Management Division within the Department of Administration and Finance 

(AF), however, recruitment of employees with disabilities is also the responsibility of 

each MCC department and is overseen by the Departmental Vice President, Deputy 

Vice President, Managing Directors, and Senior Directors. 

MCC has a policy statement pertaining to equal employment opportunity that is 

consistent with US laws and a policy promoting diversity in the workplace. The policy is 

designed to prevent discrimination against people with disabilities in areas of 

employment, hiring and promotion both inside, and outside of the United States. The 

policy also helps to ensure compliance with the No FEAR act. As part of efforts to 

increase the hiring of people with disabilities at MCC, the agency reports having used 

the Schedule A hiring authority to non-competitively hire people with disabilities and 

reports that approximately eight percent of MCC’s workforce are people with disabilities. 

These individuals reportedly work in a variety of positions and departments, including 

positions in the HR department that are involved in recruiting, hiring, and promoting 

people with disabilities. 

Transparency and Inclusion

As noted in other areas of the report, disability disaggregated data is often absent 

from the majority of publically available documentation and reporting across the 

agencies of focus; unfortunately, this is especially true for the Peace Corps. Despite 

being subject to the Freedom of Information Act (FOIA) and having detailed 

instructions on their website for making requests for information, attempts to find 

Peace Corps-specific OPM data, EEOC Reporting, Employee Viewpoint Surveys, or 

other sources of demographic information were unsuccessful. Additionally, if the 

experience of the researchers compiling data for this report is at all representative of 

that of the general public, accessing information from, or about, the Peace Corps is 

no easy feat. Of all of the agencies of focus, the Peace Corps has the most limited 

pool of public data, and the FOIA request process, in addition to being time 

consuming, rarely produced answers to pointed questions without multiple attempts 

and follow-up outreach.
57

Communications with staff at MCC reveal that efforts to recruit, retain and promote 

people with disabilities are guided by the agency’s newly created Diversity and Inclusion 

Strategic Plan and progress towards the plans goals are tracked through annual 

reporting to the Equal Opportunity Employment Commission through the Equal 

Employment Opportunity Management Directive 715 (EEO MD 715) report95

. 

Unfortunately, reporting specific to MCC is not included in the OPM agency reporting 

cited above (likely because of agency size and number of employees) and information 

is not reported via the agency’s website. This makes measuring the effectiveness of 

disability inclusive employment efforts difficult to track for those outside of the agency. 

Agency Reporting: Transparency and Visibility

Unlike the DOS and USAID, MCC is not represented in the individual OPM agency 

reporting cited above, and while the agency complied with requests for information, 

accessing recent, measurable data proved more challenging. At the time of this 

research, communications with staff at MCC reveal that they are in compliance with 

reporting standards and do submit agency information as required; however unlike 

other agency’s MCC does not make this information publically available on their 

website. The same lack of visibility is true for the agency’s above referenced Diversity 

and Inclusion Strategic Plan. MCC can easily increase its transparency, and 

demonstrate reported progress in disability inclusive employment practices, by 

uploading EEOC and hiring information in an accessible format to the web. 

Additionally, while MCC staff was responsive when asked for supplementary 

information or clarifications; communications with multiple staff in the agency suggest 

a lack of consistent, institutional knowledge of programs and practices related to 

disability inclusion and employment. This suggests room for improvement related not 

only to external sharing of information, but internal communications as well. 
58

Table 4c. No Fear 

NO FEAR 

On May 15, 2002, then-President Bush signed into law the Notification and Federal 

Employee Anti-Discrimination and Retaliation (No FEAR) Act to increase federal agency 

accountability for acts of discrimination or reprisal against employees. The No FEAR Act 

became effective on October 1, 2003 (Public Law 107-174). 

Table 4c illustrates the total number of NO FEAR complaints by agency between 2013–

2015 and highlights those related to “reasonable accommodations” for employees with 

disabilities. 

The Department of State

Year 2013 2014 2015 2016

Total 153 130 164 181

Disability 41 32 47 46

Discrimination Findings: 1 (2015)

USAID

Year 2012 2013 2014 2015*

Total 14 18 21 31

Disability 3 2 7 9

Discrimination Findings: 0

*2015 Through 9/30 

Peace Corps

Year 2013 2014 2015 2016

Total 2 4 4 4

Disability 0 1 0 0

Discrimination Findings: 0

MCC

No Public Reporting Available

Key Findings: 

 Despite EEOC requirements that every Federal agency “must post quarterly on 

its public website summary statistical data pertaining to EEO complaints filed with 

the agency” (EEOC 2017), USAID’s available data was last updated in 2015 and 

MCC has no reporting available on their site. 
59

 Of the four agencies of interest, the DOS is the only agency to report an actual 

finding of discrimination related to disability. Although on the surface this may 

suggest that these agencies have been successful at reducing or eliminating 

discriminatory conduct, the numbers alone are not conclusive. Complaints are 

often resolved before a formal finding is reached with no admission of 

responsibility. This makes tracking outcomes difficult. Claimants may choose to 

accept a settlement or accommodation, or they may drop a complaint out of fear 

of retaliation or because they have found a different job, among other reasons. 

Many others may choose not to raise a complaint at all. 

Discriminatory harassment, retaliation, and other abuses are often underreported 

and are thus left out of the agency statistics altogether. Employees experiencing 

discrimination often worry that they will lose their jobs or suffer professional 

consequences like being denied promotions if they make a complaint, and many 

others simply lack the time and resources to raise a complaint and gather 

necessary evidence. As a result, while increasing transparency is an important 

step in holding agencies accountable, agencies must still take preemptory steps 

to reduce discriminatory conduct by their employees. 
60

At a Glance: Law, Policy, and the Global Agenda 

Physical Accessibility and Access to Information 

US Legislation and Guidance: 

(1961) Foreign Assistance Act 

(1968) Architectural Barriers Act 

(1973) Rehabilitation Act—Sections 502 and 508 

(1990) Americans with Disabilities Act—Title III 

The Convention on the Rights of Persons with Disabilities (2007) 

Article 5: Countries are to recognize that all persons are equal before the law, to prohibit 

discrimination on the basis of disability and guarantee equal legal protection. 

Article 9: On the fundamental issue of accessibility, the Convention requires countries to 

identify and eliminate obstacles and barriers and ensure that persons with disabilities 

can access their environment, transportation, public facilities and services and 

information and communications technologies. 

Article 19: Persons with disabilities must be able to live independently, to be included in 

the community, to choose where and with whom to live and to have access to in-home, 

residential and community support services. 

Article 20: Personal mobility and independence are to be fostered by facilitating 

affordable personal mobility, training in mobility skills and access to mobility aids, 

devices, assistive technologies and live assistance. 

Article 21: Countries are to promote access to information by providing information 

intended for the general public in accessible formats and technologies, by facilitating the 

use of Braille, sign language and other forms of communication and by encouraging the 

media and Internet providers to make on-line information available in accessible 

formats. 

The 2030 Agenda for Sustainable Development 

Goal 11: Creates accessible cities and water resources, affordable, accessible and 

sustainable transport systems, providing universal access to safe, inclusive, accessible 

and green public spaces 
61

5. Accessibility and Inclusion: Agency Implementation 

In order for people with disabilities to actively participate in the programs funded and 

facilitated by the agencies of focus, they must have physical access to the environments 

where the agencies conduct their work, and access to related information. 

With today’s signing of the landmark Americans for Disabilities Act, every man, 

woman, and child with a disability can now pass through once-closed doors into a 

bright new era of equality, independence, and freedom. 

-Former President George Bush, 199096

The Architectural Barriers Act and Sections 502 and 508 of the Rehabilitation Act 

collectively require that federal facilities, and electronic and information technology 

be made accessible to people with disabilities, including both people within federal 

employment and members of the public. Each of the agencies of focus has legal 

responsibilities to ensure that their programs and projects are accessible to people 

with disabilities. The following sections provide explanations of the implementation of 

federal law and include agency-specific policies and programs aimed at improving 

accessibility. 

5.1. Department of State: Physical Accessibility

The DOS, as part of its presence in other countries and in fulfillment of its role as the 

representative of the United States government, has a property portfolio97 that includes 

“over 89,000,000 square feet of functioning property, and over $7 billion in projects”. 

These properties include not only embassies and consulates, but also office, living, and 

recreational spaces for employees of the U.S. government and, in many cases, their 

families. 

5.1.1. The Bureau of Overseas Building Operations 

The Bureau of Overseas Building Operations (OBO) is charged with the overall 

management of the DOS property portfolio, and pursuant to that charge must not 

only ensure the safety and functionality of DOS properties, but must also represent 
62

the United States government and the American people in a highly visible manner. 

The Bureau of Overseas Buildings Operations (OBO’s) mission is:

To provide safe, secure and functional facilities that represent the U.S. 

government to the host nation and support our staff in the achievement of U.S. 

foreign policy objectives. These facilities should represent American values and 

the best in American architecture, design, engineering, technology, sustainability, 

art, culture and construction execution.98

OBO is charged with the overall management of the DOS overseas real property 

portfolio, and pursuant to that charge must not only ensure the safety and functionality 

of properties managed under Chief of Mission Authority, but must also represent the 

United States government and the American people in a highly visible manner. Part of 

OBO’s charge includes ensuring that DOS properties are accessible. The Architectural 

Barriers Act (ABA) of 1968 sets the legal framework for building, renovation, and 

operation, and requires that buildings built, altered or leased by the U.S. government 

meet guidelines for accessibility established by the United States Access Board (ABA). 

This mandate includes compliance with the ABA Accessibility Standards, and 

Reasonable Accommodation under the Rehabilitation Act of 1973. OBO manages that 

compliance via design principles whose purpose is to balance the needs for 

accessibility, functionality, and security. OBO’s policy is formalized in Design PD 04: 

Barrier-Free Accessibility, (current revision 5/22/2017). 

OBO balances the need for the built environment of the DOS from site selection to longterm facility management. This encompasses a variety of structures used for a number 

of purposes extending from embassy offices to staff housing to Marine Security Guard 

Residences. All construction goes through a rigorous process that involves approvals at 

each stage, from site selection to occupancy, all of which are guided by a barrier-free 

accessibility policy designed to ensure that construction and renovation projects comply 

with the ABA. As projects are nominated, they undergo a review process that considers 

the viability of the project in light of critical needs of the post, severity of barriers, and 

cost. 
63

5.1.2. Accessibility Guidelines 

Accessibility guidelines apply to all public areas of DOS properties, to all portions of 

buildings used as office space, and to many (though not all) residential spaces. OBO 

manages diplomatic dwelling units in 3 sub-categories, each with differing requirements. 

There is a waiver process that can be invoked to generate exceptions to these 

guidelines, but it “exists for exceptional circumstances only” 99 and is narrowly 

construed. Such requests go through the OBO Director, and then to the General 

Services Administration (GSA) for approval. Examples of exceptions would be historic 

buildings or properties leased for 12 months or less. In general, however, the barrierfree policy is meant to ensure compliance with the ABA to the fullest extent possible. All 

new construction must be accessible, and renovation proposals must include 

accessibility improvements to existing structures in project-affected areas. Even historic 

buildings must be reviewed to determine whether or not accessibility improvements 

would threaten their historic or cultural value. Historic buildings are not exempt from 

accessibility, but OBO has greater leeway in applying accessibility to avoid damaging 

historic integrity. 

Another way DOS properties may come to be altered is if overseas mission personnel 

with disabilities ask for reasonable accommodations under the Rehabilitation Act of 

1973 when they involve building accessibility. In such cases, “OBO will fund and 

execute those alterations”. However, the alteration project is not necessarily 

undertaken immediately. With 276 overseas missions to manage, projects are initiated 

on an ongoing, rolling basis. The number and turnover of properties present obstacles 

to ensuring accessibility of all properties, as does the time it takes to see a project 

through from start to finish in a host country. OBO keeps track of project progress 

through periodic worldwide surveys of DOS properties. One such survey, conducted in 

2002, estimated that about forty percent of all properties (including residences) were 

substantially accessible; by 2013 that percentage had risen to about sixty percent100

. 

A new survey is currently underway and will afford an up-to-date look at accessibility. 

OBO will be revising the survey at the end of this calendar year. 
64

In the case of the procedures to access consulates and embassies, security does trump 

access in the sense that any person who attempts to enter a secure building goes 

through a process of gaining access, rather than being able to simply enter at will. 

However, this is different from a physical barrier. In terms of physical inaccessibility, 

OBO believes that lack of accessibility is not commonplace, but is rather a design issue 

that may sometimes require creativity—particularly in the case of older buildings or 

those in closed, urban settings—but can almost always be overcome. In the case of the 

closed doors cited in 2013, the solution was procedural and involved actuators 

administered by guards. OBO maintains that, while the process of access may be rigid, 

it should not be assumed that physical access to an embassy poses an insurmountable 

security versus accessibility tradeoff. Accessible security doors are required at the 

location of all primary accessible routes for both ingress and egress. The 

implementation and maintenance of these systems is an ongoing concern due to the 

complexity of the system. 

OBO’s charge of maximizing accessibility requires being responsive to the needs of a 

variety of settings. In the case of an embassy, protocol requires entering by way of a 

secure room that can endure a blast before proceeding further into the facility. 

Accessibility and Security

The 2013 NCD report observed that where security and accessibility concerns come 

into conflict, the prevailing DOS opinion was that “security concerns trump 

accessibility”. This conclusion was based on information gathered at US Embassies 

in 14 developing countries by local advocates, citing inaccessible spaces and 

inoperable doors reported to have been closed because of security concerns. OBO 

staff maintains that there is no conflict between accessibility and security, that the 

information gathered was misinterpreted, and that what were procedural security and 

access issues were viewed instead as physical barriers.

With safety and security among the primary focuses for the new Administration, the 

DOS is presented with an opportunity to publically clarify its approach and highlight 

its commitment to accessibility for all. 
65

In a historic building, maintaining the cultural value of the structure—and by extension, 

the goodwill of the host country—is an additional concern. OBO’s policies guide the way 

in which it balances these sorts of concerns, and physical accessibility remains a 

fundamental part of its charge. 

5.2. USAID: Physical Accessibility 

Evaluating the accessibility of environments and information is not only critical to 

ensuring the inclusion of the agency’s employees with disabilities in the United States 

and abroad, but it also plays a large role in ensuring that USAID’s disability inclusive 

development efforts on the ground are accessible to all. Two of USAID’s programs that 

focus primarily on physical accessibility are profiled below. Additional information about 

accessibility and accommodations can be found in Chapter 4–Employment and 

Participation, while a detailed overview of how USAID approaches nondiscrimination 

and access in their foreign aid policies is the presented in Chapter 6–Foreign 

Assistance. 

5.2.1. USAID Construction Assessment 

The 2014 USAID Construction Assessment101 details findings from a worldwide survey 

of USAID’s construction portfolio that took place between July 1, 2011, and June 30, 

2013. Designed to provide details of the character, scope, value, and management of 

construction activities supported by USAID, the report includes limited mention of 

accessibility for people with disabilities. In the 346-page report, which includes 

Staff Training and User Experience

Previous NCD reports noted the need for increased staff training and awareness on 

topics and issues related to disability. The DOS can mitigate potential accessibility 

issues by ensuring that the breadth of their workforce is aware of the unique needs of 

people with disabilities and has strategies and tools for creating and maintaining 

inclusive environments. This is especially important for those working overseas, 

where Human Resources personnel, or related staff with existing knowledge, may not 

be present to provide guidance. 
66

information on 758 projects or prime awards (including 3,304 sub-awards) totaling 5.6 

billion US dollars, a keyword search (for “disability,” “disabilities,” and “disabled”) 

produced just six results. The agency’s description of the infrastructure design process 

briefly mentions accommodation of disabilities, with a follow-up paragraph stating, 

“disability accessibility standards are required for construction contracts”. However, of 

the 572 sub-awards (sub- awards are projects that are contracted to primary agency 

that then hires secondary agency to facilitate the project) that responded to the survey’s 

accessibility question, just fifty-five percent reported including such standards. 

Furthermore, the report indicates that of 995 buildings serviced by the respondents 

(schools, hospitals/clinics, other buildings), the more than half (423) were unaware of 

the requirement for accessibility standards, while only 316 respondents indicated that 

they were aware of them. 

Despite the fact that survey results indicate that the requirements of the agency’s policy 

on accessibility have not been adhered to, the recommendations from the Construction 

Assessment fail to include accessibility as an issue to be addressed. It should be noted 

that the assessment lists the Agency Coordinator for Disability as a partner in improving 

“appropriate design standards and technology for construction”102, however, at the time 

of this study, USAID did not employ anyone in that role, and there were no current 

efforts in place to fill the position. 

In an effort to supplement information in the Construction Assessment, key informant 

interviews revealed that leased and owned office spaces overseas are initially 

renovated before occupancy to the fullest extent possible to follow guidelines and 

standards detailed in the International Building Code (IBC), Americans with Disabilities 

Act (ADA), Architectural Barriers Act (ABA), and any other country-specific laws or 

statutes dealing with accessibility and life safety. When USAID offices are located on 

embassy compounds, the OBO uses the same standards and is responsible for 

incorporating them in the building and compound designs. Regardless of whether 

USAID is located on or off the embassy compound, the country designated Post 

Occupational Safety and Health Officer (typically the Embassy Facility Management 
67

Officer), is responsible for monitoring and enforcing accessibility standards for all 

agencies. 

5.2.2. Wheelchair Program 

USAID’s most prominent disability accessibility program takes a collaborative, 

systematic approach to improving the inclusion of people with disabilities. As part of the 

agency’s Programs for Vulnerable Populations sector that also includes the Displaced 

Children and Orphans Fund, the Leahy War Victims Fund, the Victims of Torture 

Program, and the Disability Program, the Wheelchair Program103 was developed in 

response to a finding by the World Health Organization in its 2011 World Report on 

Disabilities that an estimated 20 million individuals require a wheelchair to be mobile. In 

collaboration with WHO, USAID applies the following fundamental principles to the 

production, provision and distribution of wheelchairs: 

1. Environmental and Individual Appropriateness: In opposition to a “one size 

fits all” approach, the program focuses on ensuring that wheelchairs are fit 

to the individual and are able to respond to often rough, rural physical 

environments. 

2. Sustainable Local Services: This principle highlights the need for longterm production and repair solutions that take into consideration local 

resources and capacity. 

3. Training for Service Providers and Wheelchair Riders: Recognizing that 

the usefulness of a wheelchair is directly related to its ability to meet 

users’ complex, individualized needs, USAID collaborated with WHO to 

develop basic and intermediate training materials that support knowledge 

and skill development in this area. These trainings are a core component 

of the programs ongoing efforts. 

4. Quality of Life for Wheelchair Riders: The focus of this principle is to 

simultaneously invest in local Disabled Peoples Organizations (DPOs) and 

self-help groups that can support translating mobility into opportunity for 

improved community inclusion, economic self-sufficiency, and advocacy. 
68

Access to Information and Progress Reporting 

There is no shortage of descriptive information related to USAID’s physical accessibilityfocused programming and projects. However, when access to information is included in 

overall accessibility efforts, the web content specific to physical accessibility is 

segmented and disbursed among multiple webpages; making navigating the site 

difficult. 

Additionally, while the agency invests considerable time and effort in its initial 

development and dissemination of information about its accessibility programming, 

there appears to be a lack of progress reporting on results from the program.104–107

5.3. Peace Corps: Accessibility and Accommodations for Peace Corps 

Volunteers

This section evaluates accessibility in the Peace Corps via two tracks: (1) accessible 

volunteer opportunities and (2) accessible Peace Corps-funded projects. Additional 

project examples can also be found in Chapter 6–Foreign Assistance. 

5.3.1. Health and Physical Accessibility 

Due to the nature of the circumstances in which all potential volunteers serve, all 

applications are examined on a case-by-case basis to ensure that each volunteer is 

placed in an environment conducive to their ability level. Volunteers can only serve in 

programs and countries that support their medical needs, which is determined by the 

Health History Form, which they complete with their application.

As part of the application process, prospective volunteers receive an individual 

assessment based on the medical records they provide and the resources available in 

host countries. The Peace Corps application explicitly states, that “an applicant must 

have the physical and mental capacity, with or without medical accommodation, to 

perform the essential functions of a volunteer for a full tour of duty without unreasonable 

disruption due to health concerns.” The Peace Corps also offers a list of health 

conditions108 typically not supported in Peace Corps service. 
69

Note: The Peace Corps reported the existence of additional policies surrounding the 

providing of reasonable accommodations in e-mail communications with researchers in 

October, 2017. However, the link to the file was corrupted and thus inaccessible. 

5.3.2. Accessible Projects 

The Peace Corps website has a specific section on its’ website that contains information 

on what volunteers do and in what types of projects they may be engaged. Projects are 

developed across six sectors, including agriculture, environment, health, community 

economic development, education, and youth in development, and the agency reports 

that many have translated to positive change for communities in need. While the Peace 

Corps sponsors many projects in areas such as infrastructure, education, and 

sanitation, it does not appear to have specific policies or procedures that mandate 

inclusion of people with disabilities, and therefore, no accommodations seem to exist 

that would make the projects more accessible to this population. 

For example, the Peace Corps website describes initiatives, such as those in Moldova 

and Senegal, to construct functioning latrines and improve hygiene education of 

students and educators. However, there is no mention of any accommodations that 

would help make these projects more accessible to people with disabilities. 

Individualized Approaches to Inclusion

While the Peace Corps’ approach to evaluating volunteers’ ability to safely serve in a 

variety of countries has the right intention, its’ lack of targeted disability recruitment 

and/or supplementary information preceding the health assessments is problematic. 

For volunteers with a disability, completing the application process is an arduous task 

as it is, and not knowing whether your disability will exclude you from service until 

after you’ve completed all of the steps could be incredibly frustrating. Therefore, 

Peace Corps would benefit from altering their current setup, which requires 

applicants to search each country’s profile for accessibility information, and instead 

developing a list of countries and/or projects where people with disabilities would be 

most likely to have success.
70

Perception and Inclusion 

Communications with Peace Corps staff as part of this report’s technical review 

(October 2017) highlighted the following projects as examples of disability inclusion in 

action: 

 Leadership Camp for the Deaf - Our Talking Hands - Peace Corps Ghana109

 Peace Corps & HIV/AIDS (Spotlight on Kenya and Deaf and Hearing Impaired)110

 Peace Corps and Special Olympics111

Unfortunately, despite the small sampling of projects noted above and the Peace Corps’ 

investment in “building a culture of inclusion,” its publicly available information would 

seem to indicate that people with disabilities are rarely—if ever—considered in the 

development and implementation of internal and external policies and programs. For 

example, Food Security, one of four global programs highlighted on the Peace Corps 

website, lists accessibility as one of four pillars of the work they do, but its examples 

focus on improving access for women. Similarly, work done in Mozambique is described 

as striving to meet the needs of the most vulnerable communities, but while it highlights 

children and individuals with HIV/AIDS, the site again fails to include disability. These 

are just two examples of areas where the Peace Corps has missed opportunities to 

share how their work is inclusive of the world’s largest minority population.

The Peace Corps would benefit from a formal review of its’ policies and practices 

related to including individuals with disabilities as target beneficiaries in its work abroad. 

In doing so, the agency has the opportunity to address other issues surrounding the 

need to reduce disparities in the amount of public-facing disability inclusive media and 

content. 

5.4. Millennium Challenge Corporation: Physical Accessibility 

Since their adoption in 2012, MCC has applied the International Finance Corporation’s 

Environmental and Social Performance Standards112 (IFC PSs) as well as the IFC 

Environment, Health and Safety Guidelines113 to its’ program investments. Prior to that, 

MCC had required under due diligence to screen and integrate handicap access into its 

project design. As part of its due diligence analysis under the IFC Performance 

Standards since 2012, MCC must go further by demonstrating how each construction 

project it undertakes has integrated relevant handicap access design features and must 

document how those features were determined. 
71

IFC PSs’ Performance Standard 1, Assessment and Management of Environment and 

Social Risks and Impacts, lays out a systematic approach to “identify individuals and 

groups that may be directly and differentially or disproportionately affected by the 

project.” The same standard explicitly includes a focus on vulnerable groups, 

considering such factors as “mental and physical disability” and stating that “where 

individuals or groups are identified as disadvantaged or vulnerable, the client will 

propose and implement differentiated measures so that adverse impacts do not fall 

disproportionately on them and they are not disadvantaged in sharing development 

benefits and opportunities”.

The EHS Guidelines state that “facilities also should be designed and built taking into 

account the needs of disabled people” and explicitly require facilities to provide an 

accessible means of egress for PWDs. The EHS recommends that the International 

Code Council (ICC) guidelines be followed, as appropriate, with respect to accessibility 

and means of egress114

. 

In spite of all of these official policies, data collected through key informants suggests a 

more nuanced approach to ensuring physical accessibility. While new construction and 

renovation projects are reported to include accessibility for PWDs, “the procedures for 

the design and implementation vary by country, project, and overall site conditions.” At a 

minimum, MCC applies national regulation requirements and standards to ensure 

accessibility. The IFC Performance Standards state that national regulations and 

standards must be met, but if deficiencies exist in those standards (as many countries 

do not have rigorous accessibility standards), international guidelines are to be used to 

ensure accessibility is integrated. Again, this is subject to “appropriateness” and “overall 

site conditions.” Accessibility provisions are enforced through contractual mechanisms 

entered into by the local government-implementing entities (Millennium Challenge 

Accounts or MCAs) that are in place to implement and administer the compact between 

their country and MCC. How consistently these are applied and/or reviewed is unclear. 
72

MCC and MCA maintain a robust focus on stakeholder engagement in their 

assessment, design, and implementation processes. Stakeholders include entities from 

the public and private sector, as well as nongovernmental and civil society members. 

This includes stakeholder engagement during Compact design as well as during 

implementation, especially through environment and social impact assessment and 

resettlement action plans. MCC also reports that it conducts public outreach to the 

disability community during design and construction. To take one example, in Cabo 

Verde, this consultation resulted in the addition of ramps being placed over trenches 

that had been dug near the homes of PWDs for a water and sanitation project. In 

addition, ramps were provided in key community areas, such as near schools, post 

offices, and markets, to assure that PWDs were able to access key services. In the 

Philippines, participatory monitoring groups were created and remained actively 

involved as advocates for vulnerable groups to ensure that accessibility was designed 

into the Philippine Compact Agreement. In another project in the Philippines, this one 

related to road rehabilitation, MCC and country-level staff addressed accessibility during 

the analysis and design components of the project and provided additional 

compensation to vulnerable groups, including those with disabilities, during the 

resettlement process115

. 
73

Accessibility in Action

Throughout the interview process, MCC staff members referenced a number of 

disability inclusive accessibility projects. Some of these projects include wheelchair 

ramp access into facilities, sanitary conveniences, space requirements, reach 

ranges, and other design features. Specific examples include the following:

● In MCC’s current program in Georgia, school rehabilitation efforts are 

re-equipping schools with handicap access including ramps, accessible 

restrooms, and widened walkways.

● MCC funded the design and construction of a water utility headquarters 

building in Jordan which includes access ramps at the entrance and 

elevators to reach the second floor.

● In MCC’s first compact in Benin, the MCC-sponsored renovation of 

courthouses there included installation of access ramps in addition to 

stairs.

● In MCC’s first compact in Lesotho, all 152 health facilities were designed 

to be physically accessible, including healthcare equipment, even in 

remote rural areas.

● As part of an MCC effort to increase access to land titling in Mongolia, 

land offices were built with wheelchair accessible ramps and entrances.

These projects provide solid examples of how agencies can ensure that mainstream 

development projects are inclusive of people with disabilities. With more formal 

strategies for systematizing and scaling-up these practices, it can be assumed that 

MCC would expand their inclusion of people with disabilities and set the bar for other 

agencies.
74

Web Accessibility

The Internet has become a primary source of information for people around the 

world, including those with disabilities. In 1998, Congress amended the Rehabilitation 

Act of 1973 to require Federal agencies to make their electronic and information 

technology (EIT) accessible to people with disabilities. The law (29 U.S.C. § 794 (d)) 

applies to all Federal agencies when they develop, procure, maintain, or use 

electronic and information technology. Under Section 508, agencies must give 

employees and members of the public with disabilities access to information that is 

comparable to that accessible by individuals without a disability.

To evaluate website accessibility, a Mac with VoiceOver was used to navigate 

through the web pages, review content, jump to links, review headings on pages, and 

find images. Findings show that while each of the agency’s sites meets minimum 

accessibility requirements, there are a number of small changes that, if made, help to 

ensure that people with disabilities can consistently access information and 

resources provided by each agency. These include:

 ensuring that links are consistently organized in the same manner across 

landing pages,

 limiting the number of clicks and redirects to access information (especially 

content specific to disability),

 verifying accessibility of PDFs and/or including accessible Word documents, 

and

 captioning all images, graphics, and visual representations of information 

using specific captioning features that differentiate between captions and 

general text.
75

6. Foreign Assistance Programs: Agency Implementation 

As the world’s largest foreign aid donor (by volume), the United States provides nearly a 

quarter of official development assistance116

. With this role comes responsibility. 

“If development is to be truly sustainable and inclusive it must benefit all citizens - in 

particular the poorest, most marginalized and vulnerable.”

-OECD, 2016 

This chapter builds on each agency’s disability policy, focusing specifically on the inclusion 

of people with disabilities in its programs and projects abroad. The Department of State, 

USAID, the Peace Corps, and the Millennium Challenge Corporation each have diverse 

mandates and missions, but share a common commitment to promoting peace, security, 

and economic and physical wellbeing of all people, including those with disabilities. 

In addition to information on agency policy and program implementation, this chapter 

also provides the majority of in-country case examples and beneficiary and project 

partner feedback. Data was collected via desk review and key informant interviews. 

6.1. Department of State: Foreign Assistance Programs 

As the National Council on Disability has previously noted, the promotion of human 

rights has long played a formative role in US foreign policy. Since its passage in 1961, 

the Foreign Assistance Act has helped to ensure that the human rights of all recipients 

of aid are respected. Agencies like the DOS have played an essential role in 

investigating of human rights abuses and implementing human rights protections in 

foreign assistance decision-making. The following sections describe the steps the DOS 

takes to ensure that the objectives of the Act are met. 

The DOS compiles country reports on human rights annually, using information 

gathered from embassy and consular staff. Since 2003, that report has incorporated 

information on the treatment of people with disabilities. When this information was first 

included, it varied tremendously, with some reports constituting little more than a line or 

two about PWDs. However, over time, and with help from the office of the Special 
76

Advisor for Disability Rights, the reports now have a designated section in which the 

treatment of people with disabilities is specifically reported, and many country reports 

contain coverage in other sections, as well. 

The Office for Democracy, Human Rights, and Labor (DLR) has compiled reports on the 

human rights practices of other countries for over 60 years, and since 2003 has included a 

section specifically focused on countries’ human rights records with respect to people with 

disabilities. The 2013 NCD Report used this information to assess countries’ reportage as 

of 2009 by examining information in the section specific to people with disabilities 

(Section 6: Discrimination, Societal Abuses, and Trafficking in People). The analysis took 

the form of: 1) a country-by-country survey of the reports that tracked responses in nine 

areas, and 2) a more qualitative analysis of reports filed by a select group of nine countries. 

It is important to note that the survey information was not designed to evaluate countries’ 

human rights records per se, but rather it was designed to determine the inclusion or 

omission of information specific to people with disabilities in the reports themselves. 

In an effort to follow up on the 2013 NCD report’s survey of 2009 data117, researchers 

examined the Country Reports on Human Rights Practices for 2015118. In general, 

reportage would seem to have significantly improved between 2009 and 2015. 

However, there are several caveats to take into consideration: 

 The data only indicates whether or not the described information appears 

somewhere in a given country. No qualitative analysis of that information was 

available for the 2009 data, and so if a report met the threshold for the descriptor 

of a given category, then it was noted as such. 

Human Rights Reporting

Despite progress in human rights reporting, there is still wide variation in the overall 

length and depth of reportage about people with disabilities. Instituting standardized 

formatting would help to streamline information, measure progress, and fill gaps in 

disability-disaggregated data collection.

Appendix c presents a detailed review of 2015 Disability Coverage in Human Rights 

Reporting. 
77

 This comparison avoided making assumptions about various aspects of the data, 

which affected the overall percentages. For instance, when examining “additional 

information on women or children with disabilities,” the existence of educational 

opportunities was often a factor in determining whether or not the report in 

question met the threshold for that descriptor. However, numerous reports 

contained information about the existence of educational programs but did not 

specify the level of schooling or the age of the students. Unless some other 

reference made it clear that the program was for children, the existence of an 

educational program was not assumed to serve children. Conversely, anything in 

a report that specified children would have qualified as a “specific mention.”

 In comparing the 2009 and 2015 reports, only information outside the People 

with Disabilities section of the reports was analyzed. 

The data indicates a significant improvement in countries’ reports between 2009 and 

2015. All nine categories show an increase, and several are dramatic. Perhaps most 

telling, however, is the improvement in final category, “additional information” located 

outside the “People with Disabilities” category. In 2009, twenty-four percent of the reports 

incorporated information about people with disabilities somewhere outside of the specified 

subsection. As of 2015, that figure has risen to over ninety-seven percent. Many reports 

mention disabilities in the Executive Summary, but that alone did not qualify a country 

report as having met the threshold for this category. Thus, while the qualitative treatment 

of human rights and disability contained in the country reports varies significantly, 

disability is far more incorporated into all aspects of human rights reportage today than 

was the case in 2009. DOS attributes this to an effort to provide instruction and review the 

individual country reports to expand reportage and work with the language used in the 

human rights reports. This does not go as far as to meet NCD’s 2013 recommendation to 

standardize the reporting, but represents a significant improvement. 

Specific methodology and detailed findings, including in-depth reviews of the nine 

countries’ reports (Ghana, Uganda, Russia, Armenia, India, Namibia, Zambia, Nepal, 

and Colombia) are presented included in Appendix c. 
78

The Bureau of Educational and Cultural Affairs Volunteer Programs 

The Bureau of Educational and Cultural Affairs (ECA)

119 works as a public affairs arm of 

the Department of State. Its legislative mandate originates in the Mutual Educational 

and Cultural Exchange Act of 1961, more commonly known as the Fulbright Hays Act, 

and its mission is “to increase mutual understanding between the people of the United 

States and the people of other countries by means of educational and cultural exchange 

that assist in the development of peaceful relations.”

The ECA sponsors a wide variety of academic, professional, sports, and cultural 

exchanges to further the diplomatic goal of friendly and peaceful relations with other 

countries. This includes activities such as academic research, professional exchanges, 

foreign language study, lecture sponsorship and other public programs, and educational 

institution assistance overseas. Among the more prominent programs are the Fulbright 

Programs, the Humphrey Fellowship Program, the Muskie Internship Program, and the 

Kennedy-Lugar Youth Exchange and Study (YES) Program. Inclusion of people with 

disabilities is integral to ECA’s overall purpose and has been a key component of its 

overall diplomatic mission. In 1995, ECA created the National Clearinghouse on 

Disability and Exchange, and since then has widened its scope to include people with 

disabilities in the full range of academic, professional, sports, and artistic exchanges it 

sponsors in an effort to “prove diversity is our strength, and that everyone provides 

important contributions.” The ECA Diversity Statement,120 which covers ECA’s internal 

operations as well as its educational and cultural programs, commits firmly to “fairness, 

equity, and inclusion” and seeks the involvement of underrepresented populations, 

including people with disabilities. 

DOS Sponsored Educational and Cultural Programs 

The Fulbright Program121 is ECA’s flagship program. It covers an array of academic 

activities and exchanges for US citizens who wish to study abroad. Sponsored 

research, overseas study, and professional exchanges that encourage scholarly 

interactions are among the multiple types of fellowships and scholarships this program 

offers. The Humphrey Fellowship Program122 brings professionals from developing 

countries to the United States for non-degree study. It is a type of Fulbright program, but 

has acquired an identity of its own since its institution in 1978.

The Edmund Muskie Internship Program123 is a summer internship program that brings 

graduate students to the United States from eastern Europe, the Caucasus, and Central 

Asia. It is intended to give emerging leaders meaningful work experience while exposing 

them to American culture and values, while the Kennedy-Lugar Youth Exchange (YES) 

Program124 is a cultural exchange program for high school students intended to promote 

lasting relationships between exchange students and their host families, and is focused 

on countries with significant Muslim populations.
79

The Bureau of Educational and Cultural Affairs Volunteer Programs (cont.) 

Among the programs supported through the ECA, there are also youth, sports, and art 

programs that are characterized by the inclusion of people with disabilities. ECA works 

with Special Olympics, Paralympics, the Kennedy Center’s Very Special Arts (VSA) 

program for arts and disabilities, and other such organizations to foster inclusion (Ruth 

2016). ECA funds tens of thousands of programs each year125 that reach a variety of 

participants, and its cultural programs reach millions more. Most programs exist as 

partnerships under ECA oversight and are generally aligned with American foreign 

policy goals. 

Visible, Tangible Commitment to Inclusion 

ECA’s commitment to inclusion is highly visible. Its website features content pages that 

are specific to disabilities, such as the “Disabilities in Exchange Programs” webpage, 

which links to the Mobility International (MIUSA) “National Clearinghouse on Disability in 

Exchange” website. The site offers detailed information, advising, and training to 

individuals and organizations seeking to explore how people with disabilities may take 

advantage of foreign exchange programs, including numerous stories of inclusion under 

the heading of “Disability is Diversity,”

126 and links to an additional page for its “Lives 

Without Limits” campaign.

In addition to its outreach activities, ECA policies seek to live up to the inclusiveness of 

its diversity statement. Applications to exchange programs do not require applicants 

with disabilities to identify themselves as such, allowing them to be considered for 

programs on an equal basis with all other applicants. Additionally, program budgets 

allocate funding to fulfill requests for reasonable accommodations made by exchange 

participants with disabilities. Finally, the Bureau conducts programs on disability issues, 

for disability rights advocates to ensure that all of its programs are open to individuals 

with disabilities. The Bureau’s commitment to programmatic inclusion is both tangible 

and visible, and is the result of direct efforts to highlight American leadership in disability 

rights. 

Internal Operations

In addition to being a mainstay of its programs, inclusion is an integral part of ECA’s 

internal operations, as well. The Bureau works specifically with the DOS’s central 

Human Resources Bureau on hiring individuals with disabilities and maintaining 

reasonable accommodations in the workplace. Furthermore, the ECA has an internal 

working group that meets on a regular basis to examine what needs to be done to 

recruit people with disabilities into its programs and find support. This group increases 

the focus on disability in a substantial way, and enables ECA to identify and address 

any problems that may arise. 

Conclusion 

Budgets, outreach, and problem solving are ongoing challenges, but ECA staff suggest 

that the commitment to inclusivity is deeply ingrained in the culture of the Bureau and 

transcends challenges from without. ECA’s commitment to disability rights is visible in 

its policies, programs, and internal operation. 
80

6.2. USAID: Foreign Assistance Programs 

As the lead US agency responsible for providing development assistance, USAID’s 

foreign assistance programs play a critical part in shaping how other US agencies and 

development stakeholders, both at home and abroad, approach disability inclusion. 

Unfortunately, despite its pioneering role in calling attention to disability as a crosscutting development issue, and its efforts to systemize inclusion via policy and 

directives, the agency has consistently come under scrutiny for failing to adequately 

monitor, evaluate and document the inclusivity of its assistance programs. 

This section begins with an introduction to disability inclusive development at USAID, 

including current agency guidance for employees and partners, initiatives, and focus 

areas. A review of previous NCD and stakeholder recommendations will follow, with a 

focus on evaluating the agency’s efforts to better serve people with disabilities. 

Throughout this section references will be made to the agency’s disability policy (the 

focus of Chapter 3), and case examples will be used to provide context and identify best 

practices and missed opportunities. Recommendations and action steps are presented 

in Chapter 7. 

6.2.1. USAID: Disability Inclusive Development

On its website, USAID highlights a twin-track approach to disability inclusive 

development that includes support for disability-specific programs to address targeted 

needs and a quest to integrate disability into all of its programs. The agency asserts that 

there are legal, social, and economic reasons to support people with disabilities in 

development and that this work necessarily extends into education, political inclusion, 

economic empowerment, vocational training, and health and emergency response. 

Specific disability inclusive USAID projects and programs include: accessible education 

and increasing access to assistive technology; national awareness campaigns and 

accessible polling initiatives that promote compliance with CRPD; organizational 

capacity-building in disabled peoples’ organizations (DPOs) and advocacy program for 

people with disabilities; microcredit grant programs focused on women with disabilities 
81

to promote economic independence; workforce development initiatives for youth and 

adults; and health programs constructed using principles of universal design. 

As an area of focus that intersects multiple sectors of work, USAID reports that currently 

the majority of work on disability is overseen by the Center of Excellence on 

Democracy, Human Rights and Governance, and the larger Democracy, Conflict and 

Humanitarian Affairs Bureau (DCHA). Additionally, the agency categorizes the Disability 

Program as one of five Congressionally directed Programs for Vulnerable Populations 

managed by the agency. This portfolio also includes the Displaced Children and 

Orphans Fund, the Leahy War Victims Fund, the Victims of Torture Program and the 

Wheel Chair Program. 

6.2.2. USAID: Funding Policies and Guidance 

A number of previous NCD report recommendations focused on improving inclusion of 

people with disabilities via USAID’s funding process. The following shortcomings—and 

therefore areas of opportunity—were identified: (1) lack of disability inclusive guidance 

in statements of work; (2) failure to incorporate disability inclusion in technical 

evaluation criteria in USAID solicitations; and (3) absence of disability indicators in 

monitoring and evaluation. 

A recent review of USAID’s policy on nondiscrimination for beneficiaries and associated 

documentation shows a strong institutional commitment to preventing discrimination of 

marginalized groups, including people with disabilities. Updated in December of 2016, 

Intersectionality and Disability

The intersectionality of disability with other agency priority areas has the potential to 

strengthen inclusive programs and policies. However, at this time, the absence of a 

systemic approach to disability inclusive development at USAID makes tracking 

investments and outcomes extremely difficult. The lack of a disability coordinator, 

existence of multiple funding sources and presence of an outdated agency policy 

combined, create a perfect storm that fuels unintended exclusion. For disability to 

effectively be mainstreamed across all sectors of USAID work, there must be a clear 

systemic approach to identifying the actors and streamlining their work. 
82

policy statements focus on nondiscrimination for end-users and beneficiaries and 

provide internal guidance and information on acquisitions and assistance awards. The 

following is a summary of the policy statements; full text and frequently asked questions 

can be viewed on the USAID website. 

 Internal Guidance–ADS Chapter 200: Announced in March 2016, asserts that 

all USAID programs must be accessible to all beneficiaries, and discrimination is 

prohibited on the basis of nonmerit factors (e.g., disability, age, gender). 

 Acquisitions/Contracts–AIDAR 48 CFR 752.7038: Announced in October 

2016, applies to all contracts and “explicitly articulates an inherent principle that 

all beneficiaries should be able to participate in USAID programs without 

discrimination.” This policy requires that contractors not discriminate against any 

end-user/beneficiary and mandates that language of the clause be included in all 

subcontracts.127

 Assistance Awards/Grants/Cooperative Agreements–ADS Chapter 303: 

Announced in November 2016, approves and implements changes to policies of 

nondiscrimination for beneficiaries and requires recipients to include language 

from the provision in all sub-awards and contracts. 

None of the above is intended to limit the contractors’ or recipients’ ability to pursue 

activities that focus on addressing the needs of targeted populations. In the related 

documentation, USAID asserts that the policy changes do not represent a shift in the 

agency’s approach to development; instead, the updated policies on nondiscrimination

provide clarification and critical language, reaffirming a commitment to development that 

is inclusive of all128. It should be noted that the policies apply to the above-mentioned 

acquisition and assistance awards to for-profit and nongovernment organizations, but 

further negotiations would be required to apply these policy statements to instruments 

involving government-to-government assistance, public international organizations 

(PIOs), or interagency agreements. 
83

Unfortunately, despite the adoption of the above-mentioned guidance and policy, efforts 

to better include people with disabilities in programs abroad appear to have been, for 

the most part, unsuccessful. Detailed below, findings from a 2015 study found that the 

absence of clear, explicit language in USAID solicitations for funding is directly 

correlated with whether or not people with disabilities are reported as having been 

included in the project as a whole.129

Despite the findings presented in the InterAction study described above, and previous 

NCD recommendations that noted the need for additional policy directives aimed at 

improving “meaningful disability inclusion”, USAID has not made any modifications to 

their solicitations process, nor has the agency added disability to the evaluation criteria 

for potential collaborations. This is especially concerning because, as previously noted 

in the 2013 NCD report, the agency’s gender requirements (ADS 2005) provide a 

template for designing modifications and provide justification for the value of this metric. 

Disability Inclusive Solicitations

At the request of the USAID Disability Team, InterAction, led by researchers from the 

Perkins School for the Blind, completed a two-phase study that reviewed 85 public 

USAID solicitations (available within a six-month period during 2012–2013) to assess 

(1) how disability inclusive language is used in solicitations, and (2) correlations 

between the presence of said language and reported disability inclusive 

programming in the sectors of education, health, and democracy and human rights 

and governance.

Key findings:

 Of the 85 solicitations reviewed, forty-eight percent do not mention disability 

within the scope of work

 Ten percent had zero mention and failed to meet USAID’s minimal 

requirement for including disability in clausal language

 Of those that did include a mention of disability, only fourteen percent had 

what the study’s expert review panel considered to be “significant” language

 In the second phase of the project, accessing follow-up reporting proved 

especially challenging because only thirteen percent of those contracted to 

implement the projects were in compliance with USAID’s reporting mandates
84

6.3. Peace Corps: Foreign Assistance Programs

As noted in previous chapters, the Peace Corps does not have formal policies in place 

to guide the inclusion of people with disabilities in any of its programs, including Foreign 

Assistance. However, there is evidence to suggest that the agency is committed to 

diversity and inclusion. The following sections explore current policies and practices for 

recruiting underrepresented groups, highlight an example of a volunteer with a disability 

and note ways in which current and former volunteers have interacted with people with 

disabilities in their work. 

6.3.1. Underrepresented Groups: Peace Corps Volunteer Recruitment 

Improving the recruitment of underrepresented applicant groups130 is a priority for the 

Peace Corps; while they do not currently have efforts in place that target prospective 

volunteers with disabilities, its approaches for the LGBTQ and age 50 and over 

communities demonstrate a commitment to diversity. For example, under the previous 

Administration, the percentage of Volunteers who self-identified as members of an 

underrepresented LGBTQ group increased by ten percent—from eighteen percent in 

2009 to twenty-eight percent in 2015. This is in part due to the Peace Corps’ 

collaboration with multiple agencies, organizations, and universities in order to advance 

the 2011 Presidential Memorandum on International Initiative to Advance the Human 

Accessible Data and Inclusion

The section above not only reiterates recommendations from previous reports, but 

also points to additional areas for improvement, in particular open data and disability 

disaggregated data. The research team responsible for the 2015 study referenced in 

above 30 reported multiple challenges associated with obtaining publically available 

documentation (solicitations and progress monitoring and reporting). This mirrors the 

experience of the authors of this report, who note availability and data transparency 

as major barriers to accessing information.

Additionally, while the absence of disability-disaggregated data was not a primary 

focus for this report, it is consistently identified as a critical issue among development 

actors. Small changes to USAID’s solicitation and reporting processes could easily 

translate to improved inclusion of people with disabilities in the breadth of USAID’s 

work. 
85

Rights of Lesbian, Gay, Bisexual, and Transgender People.

131 Together, these 

institutions’ worked to include same-sex volunteer couples in their host communities, 

actively support LGBTQ volunteers and staff, and strengthen training and resources in 

order to provide an inclusive and supportive agency culture and environment for 

trainees, volunteers, and staff members. 

The Peace Corps has also similar recruitment guidance for prospective applicants who 

are over the age of fifty.

132 The agency encourages those who are in the later years of 

their lives to consider volunteering, and provide validation of how their services can 

positively affect their host communities. Prospective volunteers may choose the length 

of their service (three months to two years), and can even choose the country where 

they serve. Because older adults may have different medical and life choices to 

consider, the agency encourages prospective volunteers to speak to a recruiter to learn 

more about which countries may be able to best support the needs they have. 

In addition to recruitment efforts becoming more inclusive, the Peace Corps has also 

implemented intercultural competency, diversity, and inclusion training and support for 

staff and volunteers. In their Building Capacity, Building Peace Report for 2009–2017,133

the Peace Corps reported that they have expanded intercultural competency, diversity, 

and inclusion trainings to educate staff and volunteers on equity and inclusion, and 

launched the same-sex couple initiative to prepare host countries and sites to support 

the LGBTQ community. 
86

Spotlight on Inclusion

Lauren Engle served a 27-month tour in Armenia. During her service, she worked 

with two nongovernmental organizations (NGOs), Good Hope NGO and Armenia 

Caritas, in a first-of-its-kind program that gave families the educational tools and 

resources needed to provide care for children and adults with both mental and 

physical disabilities, while also trying to remove the social stigma associated with 

having disabilities. Engel stated, “Having an intellectual disability remains a stigma in 

Armenia, and there is a misunderstanding among the general community of what 

having a disability means.”

Engel, along with other volunteers, participated in this project, which was supported 

by a USAID–Peace Corps Small Projects Assistance grant, to assist these families in 

learning effective, hands-on ways to decrease isolation and increase support for 

people with disabilities. They learned from local specialists trained in the native 

language (Yerevan), including a speech pathologist, psychologist, cognitive 

specialist, and part-time medical doctor. Both NGOs and volunteers worked toward 

the goals of empowering children with disabilities and their families on health, social, 

and educational issues facing children with disabilities, and also improving the living 

and educational conditions and public health of this population.

Training efforts were supported by the US Ambassador to Armenia, John Heffern, 

who made a personal visit to show his support. Through the initiation of this project, 

parents and families in the community have been able to form a network of social 

support groups that have led to an increase in confidence for all. While there is still a 

large gap in understanding about people with disabilities, there has been some 

positive movement through this project.
87

6.4. Millennium Challenge Corporation: Foreign Assistance Programs 

MCC’s overarching objective is to reduce poverty through economic growth for all. A 

key aspect of this commitment is ensuring that all individuals have an opportunity to 

benefit from MCC programs. As stated in previous sections, MCC undergoes an 

extensive economic and social assessment prior to project implementation. This 

assessment includes identifying the most marginalized and potentially excluded groups, 

including but not limited to women, youth, ethnic and religious minorities, and PWDs. 

MCC does not maintain a discretionary budget for gender and social inclusion, or 

specific funding for PWDs; instead, the intentional commitment to the inclusion of 

vulnerable groups throughout the planning process allows for PWDs to be included 

within larger projects as needed. Tracking requirements for the inclusion of PWDs vary 

across compacts based on identified needs and local/site-specific factors. 

If someone with a disability is interested in gaining more information about an MCC 

project or has encountered barriers to participation, he or she will be directed to the 

MCA (the partner country entity responsible for implementing the compact agreement) 

(the country team responsible for implementing the compact agreement) or to the 

relevant practice group at MCC headquarters. An example of this flexible process, 

provided by MCC, is as follows: 

For instance, someone may be referred to the Infrastructure group to 

discuss accessibility; the Environmental and Social Performance group for 

information on the IFC Performance Standards; the Human and 

Community Development group for programs related to special education; 

or the Gender and Social Inclusion group, which focuses on ensuring that 

marginalized groups are included in program design and benefits. 
88

Inclusive Development in Action

The following examples of projects funded by MCC briefly illustrate best practices in 

disability inclusion focused on accessibility, employment, and education:

 During implementation of the first compact in Mongolia, it was observed that 

people with disabilities were taking advantage of the health screenings at 

much lower rates than the general population. The MCA team formed a 

partnership with national organizations active in disability issues to identify 

problems and solutions. An outreach campaign dedicated to reaching PWDs

was launched to increase awareness in that community, and transportation 

was provided to health facilities. As a result of the campaign, an estimated 

10,362 additional people with disabilities went through preventive health 

check-ups.

 In its current program in Georgia, the MCA asked bidders for the Technical 

Vocational Education and Training (TVET) program to address how they 

would reach out to disadvantaged groups, including those with disabilities.

Education training modules for principals and teachers included components 

on how to proactively identify needs and develop strategies to support 

inclusion efforts. These modules covered topics such as barriers faced by 

socially disadvantaged students and students with special needs in pursuing 

STEM careers; identification of discrimination in schools (teachers’ attitudes, 

preconceived notions of intelligence, etc.); and skills to address the needs of 

students with learning disabilities.

 In the education portion of the current Morocco compact, students with 

disabilities have been identified as a disadvantaged group, and infrastructure 

design and school improvement plans will consider their needs. This project is 

ongoing and there is no publically available information available to monitor 

progress or outcomes. 
89

7. Recommendations and Action Steps 

While mindful of the lessons of history, we must never fear to innovate and 

challenge current thinking to achieve our country’s ambitious goals.

-US Bureau of Resource Management, 2007134

When former President Kennedy signed the Foreign Assistance Act into law, he spoke 

of the United States’ moral, ethical, and political responsibilities to share our nation’s 

wealth of resources with those who need it most. In order to continue to fulfill our 

obligations and promote the same sense of inclusion that has richened this country with 

diversity, the system of agencies entrusted to manage and implement US foreign aid 

must have a shared vision that not only sees the value in including people with 

disabilities, but positions inclusion as a CORE value in our work at home and abroad. 

Valuing Disability Inclusion

In 2007, the DOS and USAID published a joint strategic plan that included a focus on 

core values and diversity. The authoring Bureau of Resource Management asserted 

that while “goals and priorities may change to keep pace with the dynamic 

international environment, our core values [ Loyalty, Character, Service, 

Accountability, Community, and Diversity] will remain constant.”

Mirroring this approach and commitment, the following CORE approaches are 

intended to guide the DOS, USAID, the Peace Corps, and MCC as they work 

towards improving the inclusion of people with disabilities.

Moving forward, these agencies should focus their attention on developing inclusive 

policies, programs, and projects that are: 

Collaborative Participatory, engaging, and inclusive of diverse stakeholders, 

especially those with disabilities

Operationalized Systematized across all programs, projects, and sectors, and 

include supporting policies and guidance

Resourced Equipped with fiscal and human resources to meet the needs 

of the population

Equitable Accessible, measurable, and transparent
90

7.1. Vision and Practice 

Translating this vision to practices begins with ensuring that people with disabilities are 

accounted for in every project, program, and priority. Findings from this report show that 

for the most part, agency discourse around disability inclusive development 

programming is encouraging. Thanks in part to US foreign aid and assistance 

programs, people with disabilities are making progress, digging in, and applying the 

same strength of character and determination that they use daily to break down 

attitudinal and environmental barriers to advocate for positive change. However, as is 

the case for the majority of institutions working to solve the world’s most complex social 

and economic problems, critical issues remain that require attention and a commitment 

to action—a promise. Findings show that in most cases, despite agency rhetoric 

promoting disability inclusion, the reality is often far less favorable. Across agencies, 

lack of coordinated efforts, limited fiscal and human resources, and the absence of tools 

for measuring progress limit the ability to evaluate progress. 

7.1.1. Systems Change and Collaboration 

Effective change takes teamwork and collaboration. Executive leadership, foreign 

assistance agencies, and community stakeholders will need to work together to address 

the following overarching, systemic issues that are highlighted throughout this report: 

 Dearth of opportunities for people with disabilities to actively participate in 

decision making, policy and program development, and projects funded by US

foreign aid 

 Lack of current, explicit agency disability policy and guidance 

 Shortage of fiscal and human resources dedicated to disability inclusion 

 Absence of transparent, publically accessible data and information related to the 

inclusion of people with disabilities 

While the details differ based on the agency’s scope of work and current approaches, 

the findings show that the majority of missed opportunities fall into one of the above 

categories. This suggests that in addition to each agency individually working to 

improve current policies and practices, the US as a whole must recognize that a shift to 

a truly disability inclusive foreign assistance strategy is a shared responsibility. 
91

The sub-sections that follow expand on the examples above, as well as those 

referenced in the previous chapters, and include targeted recommendations and 

measurable action steps for each of the four agencies profiled in this report. 

7.2. Recommendations: Law & Cross-Agency Policies 

NCD recognizes that changing federal laws and policies will require a concerted effort 

that goes beyond the scope and reach of this report. However, the recommendations 

and action steps outlined below are the result of comprehensive data collection and 

analysis. They have merit and will help to promote improved inclusion of people with 

disabilities in the United States and abroad. 

Knowledge Exchange

Given the need for improvement across agencies and sectors, agencies would do 

well to model particular aspects of their programs and policies after one another and 

learn from each other. For example:

 Of all of the agencies covered in this report, the Peace Corps has the most 

work to do to ensure that people with disabilities are included throughout its 

work. Nevertheless, it is the only agency that has made “building a culture of 

inclusion” a core component of its strategic planning.

 While USAID must make updating its disability policy a priority, it is the only 

agency with a formal disability policy guiding the agency’s disability inclusive 

work; thus, its sister agencies can build from this foundation.

 With regard to building an inclusive workforce, the DOS will need to focus 

attention and resources on hiring, recruitment, and retention—a task made 

easier by the presence and oversight of the Special Advisor for International 

Disability Rights (SADR). This type of position is nonexistent or vacant in the 

other agencies, making coordinating efforts more difficult.

 Findings point to MCC’s need to scale up its data collection and reporting 

efforts related to inclusion of people with disabilities; however, requests for 

information were met with willingness to comply and what appears to be 

genuine enthusiasm and willingness to improve. Other agencies would benefit 

from this approach to cooperation.
92

Collaborative

7.2.1 Ratify CRPD As a global leader in disability inclusive 

development, the US Senate should act promptly 

to provide its advice and consent to ratification of 

the Convention on the Rights of Persons with 

Disabilities.

7.2.2 Model and Promote 

Disability Inclusion 

Among Government 

and Program Partners

The DOS, USAID, the Peace Corps, and MCC 

should model best practices and further encourage 

their foreign counterparts to include persons with 

disabilities in shared initiatives.

7.2.3 Develop Global 

Advisory Boards/ 

Committees

The DOS, USAID, the Peace Corps, and MCC 

should consider developing diverse, global 

advisory boards and committees to help support 

their disability inclusive work. Such groups must 

include people with disabilities and contribute to the 

“nothing about us, without us” approach.

7.2.4 Improve Public/Private 

Partnerships 

Improve public/private partnerships between US 

foreign assistance agencies and Disabled Peoples 

Organizations Abroad.

7.2.5 Implement Iterative 

Processes 

To ensure active participation and effective 

program implementation, the DOS, USAID, the 

Peace Corps, and MCC should implement iterative 

beneficiary feedback processes that promote 

formative progress evaluations and program 

revisions.

7.2.6 Build Capacity in 

Partner Organizations

Active participation by people with disabilities and 

Disabled Peoples Organizations is critical to 

developing programs and projects that effectively 

meet the needs of beneficiaries. By supporting

capacity-building initiatives in partner organizations 

and funding recipients, US foreign aid agencies 

can help boost inclusion through knowledge 

sharing and skill building. 

Operationalized

7.2.7 Develop, Implement,

and/or Update Formal 

Disability Policies and 

Guidance

The DOS, the Peace Corps, and MCC should 

adopt formal policies for disability inclusion. 

Policies should include information and guidance 

on the agency’s approach to disability inclusion 

including, but not limited to: employment, 

accessibility, foreign assistance, program 

monitoring and evaluation, and reporting.

7.2.8 Promote Mainstream 

Disability Inclusion 

Across Programs and 

Sectors

The DOS, USAID, the Peace Corps, and MCC 

should take active steps to ensure that persons 

with disabilities are included in all programs 

conducted abroad, without regard to whether such 
93

programs are specifically directed toward those 

with disabilities, and are encouraged to hold 

positions of leadership within such programs.

7.2.9 Standardize Program 

Monitoring and 

Evaluation, Data 

Collection, and 

Reporting

The DOS, USAID, the Peace Corps, and MCC 

must standardize program monitoring and 

evaluation, disability disaggregated data collection,

and reporting to ensure transparency and program 

efficiency. 

Resourced

7.2.10 Prioritize Disability 

Inclusive Development 

Funding

Congress should consider the promotion of 

disability inclusive development a priority for 

foreign assistance funding.

7.2.11 Establish, Appoint,

and Fill Disability 

Coordinator Positions

USAID, the Peace Corps, and MCC would benefit 

from having a full-time staff person and/or team to 

manage issues related to disability inclusion. This 

individual should have decision making power, 

support from leadership (both fiscal and 

programmatic), and a strong understanding of the 

unique needs of individuals with disabilities in the 

United States and abroad. 

7.2.12 Funding for Building

Awareness

Agency leadership must recognize that stigma is a 

major barrier to disability inclusion and ensure that 

agency projects have funding to build awareness.

Equitable

7.2.13 Uphold Current 

Legislation

Agency leadership should ensure that US laws and 

policies designed to protect the rights of citizens at 

home and abroad are consistently applied and 

implemented in settings outside of the US. 

7.2.14 Improve Accessibility 

and Representation

Those federal agencies working internationally 

should ensure that all public-facing content of 

websites and social media platforms are accessible 

and that they include and accurately represent 

persons with disabilities in substantive content, so 

that campaigns to promote democratic institutions 

or women’s empowerment, for example, include 

visual and other representations of persons with 

disabilities as citizens entitled to the benefits of 

such programs or campaigns.

7.2.15 Consistently Report 

Progress and Results

The DOS, USAID, the Peace Corps, and MCC 

must ensure that programs focused on disability 

and those inclusive of persons with disabilities 

have consistent reporting and results monitoring to 

assure equitable inclusion across program sectors.
94

7.2.16 Continue Efforts and 

Programs that 

Promote a Disability 

Inclusive Workforce

Despite changing Administration, the DOS, USAID, 

the Peace Corps, and MCC must remain 

committed to disability inclusive hiring, training, and 

recruitment practices. 

7.3. Recommendations: Department of State

The following targeted recommendations build upon the general agency 

recommendations above and respond to findings described in the text of this report. 

Collaborative

7.3.1 Ensure 

Stakeholder 

Engagement

The DOS should ensure that decision making 

related to disability inclusive programming is 

participatory and includes diverse stakeholders.

7.3.2 Continue to 

Actively

Participate in 

Global Disability 

Inclusion Efforts 

The DOS should maintain its standing as a global 

leader in disability inclusion through ongoing 

sharing of expertise, coordination of actions and 

commitments to raising the profile of disability 

across a broader range of organizations 

contributing to international development efforts. 

Operationalized

7.3.3 Develop Clear 

Policies and 

Guidance

The DOS should establish a public-facing, 

accessible policy that underscores U.S. 

commitment to including people with disabilities in 

U.S. Foreign Assistance Programming that 

highlights the roles and responsibilities of agency 

staff and implementing partners.

7.3.4 Incorporate 

Disability Inclusion 

into Bureau 

Outreach

Bureaus within the DOS should incorporate 

disability inclusion in their mission statements and 

descriptions of initiatives.

7.3.5 Improve and 

Expand Staff 

Training

Foreign service staff training should continue to 

include a focus on disability rights, and trainings 

should be expanded to include country-specific and 

cultural considerations. Additionally, trainings 

should be updated annually to reflect shifts in U.S. 

foreign policy goals and priorities.

7.3.6 Ensure Equitable 

Hiring Practices

Staff with hiring authority should be fully trained 

and knowledgeable on the Schedule A Hiring 

Authority for persons with disabilities and 

reasonable accommodations.

7.3.7 Create an Action 

Plan for Inclusion

The Department should create actionable steps for 

including persons with disabilities in all aspects of 

its U.S. foreign assistance and workforce 

development programs.
95

7.3.8 Standardize 

Reporting

The Department should develop a universal 

template for annual human rights reports and train 

embassy staff in its use for data collection and 

reportage.

Resourced

7.3.9 Continue Efforts to 

Promote Diverse 

Workplaces

The Office of Personnel Management should 

develop guidance on assessing the DOS’s 

recruitment, retention and promotion of employees 

with disabilities following the completion of 

reporting requirements under EO13458. 

Equitable

7.3.10 Ensure 

Accessibility for 

Visa Applications

Processes such as visa applications should be 

reviewed for accessibility and user friendliness, 

both online and at embassies and consulates.

7.3.11 Provide Clear, 

Accessible, Public 

Information 

Operating policies for all bureaus within the DOS 

should be publicly available and easily located 

online.

7.3.12 Standardize 

Accessibility 

Measures

Evaluation of DOS development projects should 

include accessibility measures.

7.3.13 Highlight Best 

Practices and 

Progress

The Bureau of Overseas Buildings Operations 

(OBO) should highlight accessibility efforts in its 

building and renovation projects. Embassy staff 

should be trained and held accountable for the 

procedural accessibility of DOS properties. 

Complaints should be centralized and solutions 

monitored.

7.4. Recommendations: USAID 

The following targeted recommendations build upon the general agency 

recommendations above and respond to findings described in the text of this report. 

Collaborative

7.4.1 Promote 

Intersectionality

Promote the intersectionality of disability among 

other mainstream development initiatives by 

developing working groups and advisory 

committees.

7.4.2 Improve CrossSector 

Communication

Improve communication between disability-related 

projects/activities (i.e., wheel chair program and 

construction assessment/accessibility)

7.4.3 Engage Diverse 

Employees

Develop strategies for engaging employees with 

disabilities in cross-sector decision making and 

program development 
96

7.4.4 Develop Best 

Practices

Use knowledge of successes and challenges to 

develop best practices for disability inclusion that 

can be shared with partners and stakeholders

Operationalized

7.4.5 Update Disability 

Policy

Prioritize updating the agency’s disability policy

7.4.6 Clarify Roles and 

Responsibilities 

Clarify disability-related roles and responsibilities 

among divisions and bureaus

7.4.7 Standardize Data 

Collection/Reporting

Standardize data collection and reporting; provide 

sources of information for publically shared 

documents

7.4.8 Add Disability “Key 

Words”

Prioritize disability inclusion by adding disability 

keywords to all searchable databases

Resourced

7.4.9 Fill Disabilities 

Coordinator Role

Prioritize filling the vacant Disabilities Coordinator 

Role

7.4.10 Track and Report 

Investment

Improve transparency related to measuring 

investment in disability inclusive development to 

ensure equitable distribution of resources

7.4.11 Improve 

Transparency

Use improved transparency measures to advocate 

for greater resources and investment for disability 

inclusive programs and projects

Equitable

7.4.12 Improve Web 

Accessibility 

Promote accessible resources (web and print) by 

limiting redirection and multiple landing pages

7.4.13 Feature Employees 

with Disabilities in 

Outreach Materials

Highlight employees with disabilities on career 

pages and diversity and inclusion materials

7.4.14 Reinstate Progress 

Reporting

Reinstate bi-annual/quarterly reporting on disability 

policy 

7.5. Recommendations: Peace Corps 

The following targeted recommendations build upon the general agency 

recommendations above and respond to findings described in the text of this report. 

Collaborative

7.5.1 Increase 

Employee Training

Increase employee training and knowledge of 

disability-related issues

7.5.2 Improve Access to 

Information

Prioritize communications with stakeholders, 

including improving access to public-facing 

information

7.5.3 Map 

Intersectionality

Map intersectionality of disability across agency 

sectors of work

7.5.4 Offer Peer Support Provide peer support for volunteers with disabilities

7.5.5 Promote Diverse 

Working Groups

Engage diverse stakeholders in advisory 

committees and groups
97

Operationalized

7.5.6 Develop Disability 

Policy

Develop formal disability policy and guidance that 

includes internal Peace Corps strategies and 

mandates the inclusion of people with disabilities 

across all sectors of work

7.5.7 Improve Disability 

Inclusion in 

Strategic Planning

Prioritize inclusion of disability in “culture of 

inclusion” planning and reporting

7.5.8 Include Disability 

Keywords

Ensure that disability is included as a keyword for 

all searchable reporting and databases

Resourced

7.5.9 Mirror Current 

Best Practices

Develop a disability program that mirrors LGBT and 

50+ initiatives, including fiscal and human 

resources to support programming

7.5.10 Provide Staff 

Contact

Designate staff and provide their contact 

information to respond to disability-related inquiries

7.5.11 Market Inclusive 

Opportunities

Consider developing disability-specific marketing 

materials and content

Equitable

7.5.12 Prioritize HumanCentered Eligibility 

Reviews

Re-envision approach to eligibility, including 

prioritizing human-centered, consistent, 

individualized reviews 

7.5.13 Improve Reporting Improve reporting on EEOC and workforce 

diversity issues

7.5.14 Focus on 

Transparent Data

Ensure that data and reporting are transparent and 

accurate and consistently include demographic 

information related to disability

7.5.15 Include Disability 

Inclusive Stories 

and Experiences

Focus on better representation of people with 

disabilities in current volunteer stories and videos 

and outreach materials

7.5.16 Promote 

Accessibility

Promote web accessibility and disability 

representation on website and landing pages and 

ensure that links to content and material are 

current and working 

7.5.17 Standardize Data 

Collection

Standardize data collection and reporting on the 

inclusion of people with disabilities in projects and 

the inclusion of volunteers with disabilities in 

programs

7.5.18 Disaggregate Data 

by Disability

Ensure that all surveys and outreach materials for 

staff and volunteers have specific criteria and 

indicators for disability data collection 

7.5.19 Build Partnerships 

and Opportunities

Consider partnering with host countries and 

programs that are specifically designed to 

accommodate people with disabilities and increase 

collaboration with Disabled Peoples Organizations
98

7.6. Recommendations: Millennium Challenge Corporation 

The following targeted recommendations build upon the general agency 

recommendations above and respond to findings described in the text of this report. 

Collaborative

7.6.1 Ensure Stakeholder 

Engagement

Improve public/private partnerships with 

Disabled Peoples Organizations and ensure 

decision making related to MCC programs 

includes people with disabilities

7.6.2 Develop Best 

Practices

Use lessons learned from successes and 

challenges to develop best practices for 

disability inclusion that can be shared with 

partners and stakeholders when designing 

compact and threshold agreements

Operationalized

7.6.3 Clarify Policies and 

Develop Guidance

Explicitly include disability as part of the Gender 

and Social Inclusion Policy and develop 

guidance notes for ensuring inclusion of 

disability in compacts and threshold 

agreements

7.6.4 Ensure Equitable 

Hiring Practices and 

Trainings

Improve the hiring and retention of people with 

disabilities through human resource trainings on 

disability inclusion and reasonable 

accommodation; ensure hiring of people with 

disabilities is reported according to EEOC 

guidelines and that information is publically 

available

7.6.5 Standardize Data 

Collection/Reporting

Standardize data collection and reporting 

related to disability inclusion; provide sources of 

information for publically shared documents

Resourced

7.6.6 Continue Efforts to 

Promote Diverse 

Workplaces

Focus efforts on the recruitment and retention 

of employees with disabilities

7.6.7 Improve Data 

Transparency and 

Awareness

Use improved transparency and awareness 

measures to advocate for greater resources 

and investment for disability inclusive programs 

and projects
99

Equitable

7.6.8 Improve Monitoring 

and Evaluation

Develop and implement interactive beneficiary 

feedback loops to evaluate progress towards 

disability inclusive goals

7.6.9 Improve Web 

Accessibility

Ensure all web content is not only accessible, 

but is representative of people with disabilities 

7.6.10 Improve 

Accountability

Develop accountability measures to support 

improved tracking of investment in disability 

inclusive development 

7.6.11 Standardize 

Accessibility 

Measures

Evaluate all MCC agreements for physical and 

informational accessibility to ensure 

consistency; consider adopting international 

accessibility guidelines, as national guidelines 

can be ineffective

7.7. Conclusions and Limitations 

Findings from this report show that, for the most part, agency discourse around 

disability inclusive development programming is encouraging, but inclusive policies and 

practices are inconsistently applied. Agencies are aware of the need to explicitly include 

people with disabilities in foreign assistance, but most lack systemic processes and 

procedures. To ensure that people with disabilities are consistently and effectively 

included across all sectors of work, agency leadership must promote a culture of 

inclusion that begins within its own walls. This will not only support US commitments to 

diversity and inclusion in the executive branch, but also creates opportunities for 

individuals with disabilities to actively engage in the change process, bringing valuable 

lived experiences and knowledge to the proverbial table. 

While this report followed strict evidence-based methodology for data collection and 

analysis, there are limitations. Researchers were unable to connect with every 

employee at the federal agencies and, despite a thorough investigation into agency 

programs, may have missed some inclusive activities. In addition, data collection 

approval efforts were limited and/or delayed in some instances. Researchers were 

directed to only one source of information for the Peace Corps in particular, and the 

amount of data obtained was lacking in depth and breadth. Consistent agency reporting, 

program monitoring and evaluation, and data collection are recommended to promote 

transparency and ensure comprehensive program and policy reviews. 
100

7.7.1. Methodology and Sources of Information 

The development of this report would not have been possible without agency 

cooperation and transparency. During initial data collection, individuals from multiple 

departments and programs provided researchers with documentation, clarification and 

individual expertise. Additionally, prior to publication, this report underwent a thorough 

agency-directed technical review. NCD granted DOS with extensions of time to conduct 

a technical review, however DOS provided only a partial technical review by the final 

date of the extended review period. All print and web sources are identified in the 

endnotes (and in many cases hyperlinked in digital versions). Communications (inperson, e-mail and telephone) are designated as “key informant interviews”. The lack of 

individualized referencing of interviewees is a reflection of the team approach and 

reflects the collaborative nature of the data collection and reporting. 

A Full Text, accessible (Word) version of this report is also available at 

https://www.ncd.gov. 
101

Appendix A. 

Summary of Previous NCD Foreign Policy and Disability Recommendations 

National Council on Disability (1996). Foreign Policy and Disability. 

(https://ncd.gov/publications/1996_Publications/08011996)

General Recommendations: 

 creating a comprehensive foreign policy on disability to advocate for people with 

disabilities through activities on international levels 

 extending U.S. disability law by legislation or executive order to include 

unambiguously the international operations of the U.S. government; 

 employing domestic standards of nondiscrimination in U.S.-sponsored 

international activities 

 training U.S. foreign affairs agencies and their contractors to plan for 

programmatic accessibility 

 establishing the principle that no U.S. international activity should have a lower 

standard of inclusion than its domestic correlate. 

Specific Recommendations: 

 The Rehabilitation Act protections should be extended by legislation or executive 

order to include unambiguously the international operations of the U.S. 

government 

 All U.S. government agencies active abroad should carry out Rehabilitation Act 

self-evaluations to identify barriers to participation and to establish transition 

plans to eliminate these barriers 

 Medical requirements for participants in U.S. Foreign Service or other 

international activities should be developed more clearly to prevent discrimination 

against people with disabilities. 

 Prominent disability organizations and community representatives in cooperation 

with governmental bodies should formulate and carry out a program to train 

senior foreign affairs officials and their contractors in planning for programmatic 

accessibility. 

 U.S. international activities should be evaluated to ensure that no program has a 

lower standard of inclusion than its domestic correlate. For example, activities 

supporting education in developing countries should provide opportunities 

consistent with those of the Individuals with Disabilities Education Act. 

 In keeping with its role as the world’s democratic leader, the United States should 

promote international disability policy in international organizations; provide 

disability foreign assistance; and set a high standard for accessibility and 

nondiscriminatory employment by U.S. government agencies abroad. 

 AID should create a disability development policy with measurable goals and 

timelines. Such a policy would: 

 develop goals and timelines in close cooperation with U.S. and other disability 

organizations; 

 develop mission strategic objectives that are disability-specific in conjunction with 

indigenous organizations of people with disabilities 
102

 broadly increase participation by people with disabilities in all aspects of the 

development process 

 identify and incorporate the successful strategies of other nations into U.S.-

sponsored development projects; routinely evaluate the agencies progress in 

achieving goals and time lines. 

 U.S. foreign policy-making should be modified to include a mechanism for 

including disability objectives 

 Create disability policy standards to guide U.S. delegations and permanent 

representatives to international organizations in effectively and consistently 

advocating for positions and policy that bring the spirit of ADA into international 

relations; 

 Coordinate with U.S. disability leaders, policymakers, and relevant domestic 

agencies to identify the disability implications of U.S. overseas activities; 

 Ensure consistency between U.S. national goals toward people with disabilities 

and the government’s activities abroad; and 

 Enable the United States to assume its rightful role as the world’s leading 

proponent of equality for all people, including people with disabilities 

 Medical requirements for participants in U.S. Foreign Service or other 

international activities should be developed more clearly to prevent discrimination 

against people with disabilities. 

 Prominent disability organizations and community representatives in cooperation 

with governmental bodies should formulate and carry out a program to train 

senior foreign affairs officials and their contractors in planning for programmatic 

accessibility. 

 U.S. international activities should be evaluated to ensure that no program has a 

lower standard of inclusion than its domestic correlate. For example, activities 

supporting education in developing countries should provide opportunities 

consistent with those of the Individuals with Disabilities Education Act. 

 In keeping with its role as the world’s democratic leader, the United States should 

promote international disability policy in international organizations; provide 

disability foreign assistance; and set a high standard for accessibility and 

nondiscriminatory employment by U.S. government agencies abroad. 

 AID should create a disability development policy with measurable goals and 

timelines. Such a policy would: 

 develop goals and timelines in close cooperation with U.S. and other disability 

organizations; 

 develop mission strategic objectives that are disability-specific in conjunction with 

indigenous organizations of people with disabilities 

 broadly increase participation by people with disabilities in all aspects of the 

development process 

 identify and incorporate the successful strategies of other nations into U.S.-

sponsored development projects; 

 routinely evaluate the agencies progress in achieving goals and time lines. 

 U.S. foreign policy-making should be modified to include a mechanism for 

including disability objectives 

 Create disability policy standards to guide U.S. delegations and permanent 

representatives to international organizations in effectively and consistently 
103

advocating for positions and policy that bring the spirit of ADA into international 

relations; 

 Coordinate with U.S. disability leaders, policymakers, and relevant domestic 

agencies to identify the disability implications of U.S. overseas activities; 

 Ensure consistency between U.S. national goals toward people with disabilities 

and the government’s activities abroad; and 

 Enable the United States to assume its rightful role as the world’s leading 

proponent of equality for all people, including people with disabilities 

National Council on Disability (2003). Foreign Policy and Disability: Legislative 

Strategies and Civil Rights Protections To Ensure Inclusion of People with Disabilities 

(https://ncd.gov/publications/2003/Sept92003)

Recommendations: 

 GAO should conduct a study of current practices 

o Determine whether agencies have developed programs have developed 

disability inclusion in FA 

o Overcome specific barriers to access by PWD as identified in NCD Report 

o New investigation to see whether there is barriers in policy marking, 

program development, and implementation abroad 

 Amend Foreign Aid Assistance Act to ensure full inclusion of PWD in foreign 

assistance programs 

o Create a disability advisor at State Department to ensure disability rights is 

a priority in programs and programs and to coordinate inter-agency work 

on disability task force on foreign policy and disability 

o Require documentation of disability rights in State Department Country 

Report including specific information like human rights violations. Provide 

support for human right groups for PWD through Funds for Inclusion 

 Ensure inclusion in foreign assistance programs 

o Amending 22 U,SC, 2151 23404 to include disability following race, sex, 

language, and inclusion 

 Create Office on Disability in Development at USAID 

o Provide technical assistance on accommodations, workshops, data 

collection and long term reform and implementation of inclusion in all 

USAID proposals, contracts, agreements, etc 

o Create regional mission level disability program officers 

o Include PWD in post conflict societies 

o Inclusion should be required as part of Millennium Challenge Account 

 Establish fund for inclusion, leadership, and human rights for PWD 

o Support creation of NGO and strengthen existing ones 

o Promote educational exchanges, technical assistance, and collaboration 

o Provide technical assistance to foreign governments and NGOs 

o Assist governments in creating human rights oversight or ombudsman 

programs 

 Enforce the Application of Rehabilitation Act of 1973 to US government programs 

overseas 
104

National Council on Disability (2013). Toward the Full Inclusion of People with 

Disabilities: Examining the Accessibility of Overseas Facilities and Programs Funded by 

the United States (https://ncd.gov/publications/2013/032013)

Recommendations for Congress: 

 Apply Federal Disability Standards to Overseas Programs and Employment NCD 

recommends that Congress instruct USAID, DOS, DOD, and other U.S. 

Government agencies operating overseas that Sections 501, 503, and 504 of the 

Rehabilitation Act of 1973 apply to overseas programs and employment 

opportunities operated by the U.S. Government. 

 Ensure respect for domestic disability laws in implementation of host countries 

 Limit disability waivers and exception in infrastructure to avoid future 

redevelopment projects 

 Ratify Convention on the Rights of Persons with Disabilities 

USAID, DOS, DOD 

 Promote inclusion and employment of PWD in overseas offices and programs 

USAID: 

 Revise the USAID Disability Policy 

 Provide adequate resources for Coordinator for Disability Rights and Inclusion in 

Developments 

 Require disability inclusive guidance in statements of work 

 Incorporate Disability Inclusion in Technical Evaluation Criteria in USAID 

solicitations 

 Develop Disability Indicators and Strengthening monitors of inclusion 

 Provide specifications of costing reasonable recommendations 

 Strengthen capacities of DPOs 

State Department: 

 Issue Policy Statement on Rehabilitation Act Compliance 

 Provide adequate resources for Office of Special Advisor on International 

Disability Rights 

 Improve Embassy Accessibility 

 Deepen Disability Rights coverage in country human rights reports 

 Enhance access to information on cultural exchange programs, encourage them 

to adopt disability specific policies 
105

Appendix B. 

Disabled People’s Organization Survey Summary

A survey was sent out to existing research contacts in Disabled People’s Organization’s 

(DPOs) in 10 countries in the Global South. The goal was to source information on their 

input, knowledge and experience with disability inclusive development through 

participation and/or involvement in projects funded by the agency’s of interest. 

Participation in the survey (conducted via web) was poor and the results were 

inconclusive and not suitable for publication. 

Information obtained from participants in Malawi and Rwanda indicates that majority of 

the DPOs do not have any form of involvement in development projects implemented in 

their respective countries. Respondents also reports of limited accommodation, lack of 

assistance, lack of information in accessible formats, for persons living with disability 

participating in a development project. There is some indication that embassy locations 

in these countries are accessible, however, extent was unable to be measured with the 

information provided. 

Continued engagement with DPO’s is a critical aspect of disability inclusive foreign 

assistance and the need for participatory engagement is explored throughout the report 

and in the recommendations. 

Appendix C. 

Detailed Review of Human Rights Reporting 

The Department of State compiles country reports on human rights annually, using 

information gathered embassy and consular staff. Since 2003, that report has 

incorporated information on the treatment of people with disabilities. Early in this time 

period, the reports varied tremendously, with some reports constituting little more than a 

line or two. However, since that time, and with help from the office of the Special 

Advisor for Disability Rights, the reports now have a section in which the treatment of 

people with disabilities is specifically reported, and many country reports contain 

coverage in other sections as well. However, there is still wide variation in the overall 

length and depth of reportage about people with disabilities. 

Progress and Findings 

The Office for Democracy, Human Rights, and Labor (DLR) has compiled reports on the 

human rights practices of other countries for over 60 years, and since 2003 has included 

a section specifically focused on countries’ human rights records with respect to people 

with disabilities.118 The 2013 NDC Report used this information to assess countries’ 

reportage as of 2009 by examining information in Section 6 (Discrimination, Societal 

Abuses, and Trafficking in People) specific to people with disabilities. The analysis took 

the form of: 1) A country-by-country survey of the reports that tracked responses in nine 

areas; and, 2) A more qualitative analysis of reports filed by a selected group of nine 

countries. It is important to note that the survey information was not designed to evaluate 

countries’ human rights records per se, but rather the inclusion or omission of information 

specific to people with disabilities in the reports themselves.118
106

This report follows-up the 2013 NCD report’s survey of 2009’s data by examining the 

Country Reports on Human Rights Practices for 2015. As was done in 2013, each of the 

197 country reports was tracked in nine areas: 1) concrete statistics on employment, 

education, and health care; 2) the rights of workers with disabilities; 3) laws that prohibit 

discrimination or require accommodations for people with disabilities; 4) specific 

government agencies or departments; 5) specific international and domestic NGOs and 

DPOs; 6) specific examples of human rights violations; 7) political/civic participation; 

additional information on women or children with disabilities; and 9) additional information 

located outside the “People with Disabilities” subsection.

118 Using the table from the 2013 

NCD report as a baseline, similar information from the 2015 human rights reports will be 

added in an effort to assess changes in the reportage between 2009 and 2015. 

 

The more qualitative, “Selected Country Analysis” conducted on nine reports (Ghana, 

Uganda, Russia, Armenia, India, Namibia, Zambia, Nepal, and Colombia) will be 

evaluated according to recommendations made in 2013. These countries were 

originally selected on the basis of being, “both good models for reporting on the rights of 

people with disabilities and examples of human rights reporting on people with 

disabilities that could be improved.”

118 Using the 2013 recommendations for each 

country to evaluate the 2015 reports will reveal whether or not any improvement in the 

reporting has in fact occurred since 2009. 

Disability Rights Coverage, 2015 

Category % in 2013 % in 2017

Concrete statistics on employment, education, and 

health care

23.20% 28.93%

The rights of workers with disabilities 22.70% 70.56%

Laws that prohibit discrimination or require 

accommodations for people with disabilities

98.50% 98.98%

Specific government agencies or departments 67.50% 81.73%

Specific international and domestic DPOs and NGOs 34.50% 40.10%

Specific examples of human rights violations 13.90% 18.27%

Political/civic participation 10.80% 29.95%

Additional information on women or children with 

disabilities

20.10% 68.02%

Additional information located outside “People with 

Disabilities” section

24.70% 97.95%
107

In general, reportage seems to have improved between 2009 and 2015. However, 

there are several caveats to take into consideration: 

 The data only indicates whether or not the described information appears 

somewhere in a given country. No qualitative analysis of that information was 

available for the 2009 data, and so if a report met the threshold for the descriptor 

of a given category, then it was noted as such. 

 This comparison avoided making assumptions about various aspects of the data, 

which affected the overall percentages. For instance, in the area of “Additional 

information on women or children with disabilities”, the existence of educational 

opportunities was often a factor in determining whether or not the report in 

question met the threshold for that descriptor. However, numerous reports 

contained information about the existence of educational programs, but did not 

specify the level of schooling or the age of the students. Unless some other 

reference made it clear that the program was for children, the existence of an 

educational program was not taken to mean that it was meant to serve children. 

Conversely, anything in a report that specified children would have qualified as 

“specific mention”.

 The comparison of the 2009 and 2015 reports only looked for information outside 

the People with Disabilities section of the reports where it was specifically 

mentioned in the description of the category. 

 

The data indicates a significant improvement in countries’ reports between 2009 and 

2015. All nine categories show an increase, and several are dramatic. Perhaps most 

telling, however, is the improvement in final category, “Additional information located 

outside the “People with Disabilities” category. In 2009, 24% of the reports incorporated 

information about people with disabilities somewhere outside of the specified 

subsection. As of 2015 that figure has risen to 97.95%. Many reports include mention 

of disabilities in the Executive Summary, but that alone did not qualify a country report 

as having met the threshold for this category. Thus, while the qualitative treatment of 

human rights and disability contained in the country reports varies significantly, disability 

is far more incorporated into all aspects of human rights reportage than was the case in 

2009. The Department attributes this to an effort to provide instruction and review the 

individual country reports to expand reportage and work with the language used in 

those reports. This does meet the 2013 recommendation to standardize the reporting, 

but represents a significant improvement. 

In addition to the full survey of countries contained in the Country Reports on Human 

Rights Practices for 2009, nine countries were selected for further analysis based on the 

overall quality of its reporting around disability. Five countries (Ghana, Uganda, Russia, 

Armenia, and India) are held up as exemplars of good human rights reporting on the 

basis of their detail, documentation, and willingness to address shortcomings. The 

other four countries—Namibia, Zambia, Nepal, and Colombia are included for the 

purpose of highlighting areas where reporting could be improved by way of,118 “deeper 

research garnering detail from additional sources; going into greater detail and depth; 

and eliciting information directly from in-country DPOs or international organizations 

working in country or having knowledge of the local disability community”. The following 
108

table takes stock of the four countries cited in the 2013 NCD report for their relative 

shortcomings, and highlights that country’s 2015 report in an effort to determine whether 

or not there has been any improvement. Nominally, such improvement would be 

indicated on the basis of whether or not the country in question implemented at least 

one of the 2013 NCD suggestions. 

Country 2013 NCD Commentary 2015 Report Highlights

Namibia “[W]hile the embassy’s report did

reference the previous year’s report, the 

report only mentioned the role of one 

government agency and included mostly 

generalized statements. More depth into 

legal mechanisms of action and specific 

examples of discrimination would be 

helpful.”

· A constitutional ban on 

discrimination (p. 2359)

· Prohibition on infanticide and 

enforcement (p. 2362)

· The People With Disabilities 

section cites general and 

employment discrimination, 

building accessibility, student 

mainstreaming, voting, and the 

naming of a deputy minister for 

disability working through the 

National Disability Council of 

Namibia (p. 2362)

· Employment discrimination (p. 

2365)
109

Zambia “Zambia’s 2009 Country Report was 

extremely brief and provided little useful 

information on the status of people with 

disabilities. The report only referenced 

one news source and one government 

agency. The embassy did not reach out 

to local DPOs and thus did not properly 

address the human rights of people with 

disabilities in its research.”

· Disability is included in the 

Executive Summary (p. 3725)

· Treatment of PWDs in the Prisons 

as assessed by a Zambian NGO 

(p. 3727)

· The People With Disabilities 

section cites a 2012 PWD Act, and 

the responsibility of the Minister of 

Gender and Child development for 

better inclusion via the Zambia 

Agency for PWDs. A second NGO, 

the Zambian Federated Disability 

Organization is mentioned, as is a 

2014 Human Rights Watch report 

that finds a lack of data about even 

number of PWDs in Zambia. In the 

area of education, five schools for

children with disabilities are cited, 

while other students are in 

mainstream schools (p. 3740)

· The employment sections says 

that antidiscrimination laws and 

reality are not the same (p. 3744)
110

Nepal “The sparseness of the disability section 

in Nepal’s 2009 Country Report 

was...one paragraph... More specific 

examples of discrimination, an in-depth 

review of disability law, and the use of 

additional sources would very likely 

have... made for a more enlightening 

read.”

· Disability rights are in the Exec 

Summary (p. 2375)

· Discussion of Internally Displaced 

People includes disabled people 

(p. 2384)

· The section on political 

participation cites a constitutional 

requirement for representation in 

the upper house of Parliament (p. 

2387). There is also a 

constitutional prohibition of 

discrimination against PWDs (p. 

2390)

· A mandatory five year (additional) 

penalty for rape of a PWD (p. 

2390)

· The People With Disabilities 

section reports a 2012 Supreme 

Court decision to demand that the 

government provide more benefits, 

with the Ministry of Women, 

Children and Social Welfare in 

charge. Additional commentary 

covers work, statistics, education, 

a local development aid earmark 

(1-2% of funds targeted), and NGO 

involvement (p. 2396).

· Section 7 on employment states 

that discrimination against PWDs 

is prohibited, but persists. It also 

highlights a 5% public jobs quota 

for PWDs. (p.2401)
111

Colombia “The “People with Disabilities” section 

only mentioned the government agency 

designated to protect the rights of people

with disabilities and that some disability 

law preventing discrimination existed. 

There was no mention of communication 

with DPOs or NGOs...[C]ommunication 

between the Human Rights Officer at the 

embassy and the democracy and 

governance staff at USAID might foster 

the kind of information flow that is 

essential to meaningful human rights 

reporting.

· There is mention of PWDs in the 

Executive Summary (p. 761.

· The section on PWDs cites 

protections under law and a 

Presidential Advisor for Human 

Rights. NGOs are reported 

unsatisfied with law enforcement. 

The right to education for PWDs is 

stated, as is their later entry into 

and dropout rate from school. Also 

reported is the legality of some 

forced sterilizations of people with 

cognitive and psychosocial 

disabilities. Accessibility in public 

buildings has been mandates, but 

there is no data on compliance (p. 

763)

· The employment section states 

that 85% of PWDs are unemployed 

(p. 771).

All four countries substantially addressed the overall criticisms leveled at them in 2013, 

and at least in part addressed the NCDs concerns. Namibia did not delve into legal 

mechanisms as such in dealing on the state of disability rights, but did invoke specific 

laws and protections for people with disabilities. The report also highlighted areas of 

concern in the area of disability rights. Zambia significantly expanded its reportage, and 

answered the concern that it did not take advantage of the information and perspective 

NGOs could have offered by including both domestic and international organizations’ 

input into the report. Nepal also went beyond the sparse information it gave in 2009; 

and while it seems to have relied fairly exclusively on government sources of 

information, more areas of concern were given attention in 2015. Colombia’s 

information is more descriptive, but does not appear to have taken up the advice that 

better communication with USAID would benefit its reportage on disability rights; but to 

a lesser degree than the other countries, Colombia did report more information than 

was the case in 2009. 

The survey and qualitative data suggest that countries have expanded and deepened 

their coverage of people with disabilities in their human rights reports since 2009, and 

while that breadth and depth varies from country to country, there is little doubt that it 

has improved overall. 
112

 

EndNotes 

1

 World Health Organization, World Report on Disability (2011) 

http://who.int/disabilities/world_report/2011/en/. 

2

 Office of Personnel Management (2016) Report on the Employment of People with 

Disabilities in the Federal Executive Branch, https://www.opm.gov/policy-dataoversight/diversity-and-inclusion/reports/disability-report-fy2015.pdf. 

3

 National Council on Disability (1996), Foreign Policy and Disability, 

https://ncd.gov/publications/1996_Publications/08011996. 

4

 National Council on Disability (2003). Foreign Policy and Disability: Legislative 

Strategies and Civil Rights Protections To Ensure Inclusion of People with Disabilities, 

https://ncd.gov/publications/2003/Sept92003. 

5

 National Council on Disability (2013). Toward the Full Inclusion of People with 

Disabilities: Examining the Accessibility of Overseas Facilities and Programs Funded by 

the United States, https://ncd.gov/publications/2013/032013. 

6

“About State”, US Department of State, accessed January 2017, 

https://www.state.gov/aboutstate/. 

7

 USAID, 2013, https://www.usaid.gov/who-we-are/mission-vision-values. 

8

“About,” USAID, accessed January 2017, https://www.usaid.gov. 

9

 Peace Corps, accessed February 15, 2018, https://www.peacecorps.gov/about/. 

10 “Millenium Challenge Corporation”, Millenium Challenge Corporation, accessed 

January 2017, https://www.mcc.gov. 

11 WHO, World Report on Disability. 

12 United Nations General Assembly, CRPD, Article 1 (2007), accessed January 1, 

2017, http://www.un.org/disabilities/documents/convention/convoptprot-e.pdf. 

13 UN Enable, (2006), http://www.un.org/esa/socdev/enable/diswpa04.htm. 

14 World Health Organization, World Report on Disability (2011). 

15 NCD, Foreign Policy and Disability-2013. 

16 United Nations General Assembly, CRPD, (2007), accessed January 1, 2017, 

http://www.un.org/disabilities/documents/convention/convoptprot-e.pdf. 

17 UN.org. (2015). United Nations Millennium Development Goals. [online] Available at: 

http://www.un.org/millenniumgoals/gender.shtml [Accessed 5 Jan. 2017]. 

18 The Borgen Project (2017), accessed January 2017, https://borgenproject.org/foreignaid/. 

19 InterAction, https://www.interaction.org/fabb2016/member-insight/inclusion-andmobilization-disabled-us-foreign-assistance. 

20 Included in this framework are the Individuals with Disabilities in Education Act 

(IDEA), 20 U.S.C.A. §§ 1400 et seq.; the Fair Housing Amendments Act, 42 U.S.C. §§ 

3601-3619, 3631 (1988); the Air Carriers Access Act, 49 U.S.C. 41795 (1986); and the 

Telecommunications Act, 47 U.S.C. §§ 153, 255 (1996). 

21 29 U.S.C. § 791 (1973); 29 C.F.R. 1614.101(a): “It is the policy of the Government of 

the United States to provide equal opportunity in employment for all people, to prohibit 

discrimination in employment because of...disability...and to promote the full realization 

of equal employment opportunity through a continuing affirmative program in each 

agency”; see also, e.g., Redd v. Summers, 232 F.3d 933 (D.C. Cir. 2000). 

22 See, e.g., Flynn v. Distinctive Home Care Inc., 812 F.3d 422 (5th Cir. 2016) 

114

 

provision allows Congress to “condition the receipt of federal moneys upon compliance 

with federal statutory and administrative directives.” Alliance for Open Society Intern. 

Inc. v. US Agency for Intern. Development, 651 F.3d 218, 230 (2d Cir. 2011). It is well 

settled that Congress is entitled to further policy goals indirectly through its spending 

power that it might not be able to achieve through direct regulation, and that the power 

to do so is broad. Id.

42 Sharma and Mszyco (2017) Human Rights Watch, 

https://www.hrw.org/news/2017/07/18/indonesian-childhood-chains. 

43 USAID, 2014, https://www.usaid.gov/ethiopia/speeches/disability-inclusivedevelopment-round-table. 

44 “State.gov” 

45 Key Informant Interview, Department of State, (2016–2017) E-mail, telephone, in-person. 

46 USAID (1997) Disability Policy Paper. http://pdf.usaid.gov/pdf_docs/Pdabq631.pdf. 

47 Hayes et. al (2015) Inclusion of Disability in USAID Solicitations for Funding. 

http://usicd.org/doc/Inclusion-of-Disability-in-USAID-Solicitations-for-Funding.pdf. 

48 InterAction (2016) Inclusion And Mobilization Of People With Disabilities In U.S. 

Foreign Assistance, accessed January 2017, 

https://www.interaction.org/FABB2016/member-insight/inclusion-and-mobilizationdisabled-us-foreign-assistance 

49 Key Informant Interviews, USAID, (2016-2017), E-mail, telephone, in-person. 

50 Key Informant Interview, USAID. 

51 USAID (2016) USAID 2016 Financial Report, 

https://www.usaid.gov/sites/default/files/documents/1868/USAIDFY2016_AFR_508.pdf. 

52 Advancing Disability Inclusive Development, accessed February 2, 2018, 

https://www.usaid.gov/what-we-do/democracy-human-rights-andgovernance/protecting-human-rights/disability. 

53 Dollars to Results, accessed February 2, 2018, https://results.usaid.gov/results. 

54 Development Experience Clearinghouse, accessed February 2, 2018, 

https://dec.usaid.gov/dec/home/Default.aspx. 

55 Peace Corps, accessed February 2, 2018, https://www.peacecorps.gov/. 

56 Peace Corps (2015) Peace Corps 2015 Performance and Accountability Report, 

http://files.peacecorps.gov/multimedia/pdf/policies/annrept2015.pdf. 

57 Peace Corps (2017) Peace Corps, 2017 Congressional Budget Justification, 

http://files.peacecorps.gov/documents/open-government/peacecorps_cbj_2017.pdf. 

58 Peace Corps (2014-2018) Strategic Plan, 

http://files.peacecorps.gov/multimedia/pdf/policies/pc_strategic_plan_2014-2018-

annual_plan_2016-2017.pdf 

59 Peace Corps, 2017, Annual Performance Report 

https://s3.amazonaws.com/files.peacecorps.gov/documents/open-government/annualperformance-report-fy16-plan-fy18.pdf. 

60 Peace Corps, Strategic Plan, 46. 

61 Peace Corps video, How Is Packing for Peace Corps Different for People with 

Disabilities?, accessed February 2, 2018, https://www.peacecorps.gov/stories/how-ispacking-for-peace-corps-different-for-people-with-disabilities/. 
115

 

62 Peace Corps video, accessed February 2, 2018, 

https://www.youtube.com/watch?v=XFT3O-aptgk. 

63 Peace Corps video, accessed February 2, 2018, 

https://www.youtube.com/watch?v=RLW-4I4OUVo. 

64 Peace Corps video, accessed February 2, 2018, 

https://www.youtube.com/watch?v=yo0DA_0cepk. 

65 Peace Corps video, accessed February 2, 2018, 

https://www.youtube.com/user/peacecorps/videos. 

66 Key Informant Interview, Millennium Challenge Corporation,(2016/2017), E-mail, 

telephone, in-person. 

67 Freedom House (2004-2012) Countries at the Crossroads, Accessed January 2017, 

https://freedomhouse.org/report-types/countries-crossroads. 

68 Bureau of Resource Management, accessed February 2, 2018, 

https://www.state.gov/s/d/rm/rls/dosstrat/2007/html/82948.htm. 

69 Office of Personnel Management (2016) Report on the Employment of People with 

Disabilities in the Federal Executive Branch, https://www.opm.gov/policy-dataoversight/diversity-and-inclusion/reports/disability-report-fy2015.pdf. 

70 Schedule A regulations specify that a person must have an intellectual 

disability, a severe physical disability, or a psychiatric disability to be eligible to be 

hired through Schedule A. The regulations do not specifically include or exclude 

particular disabilities under those three categories of disabilities, and they are not limited 

to the examples in the previous question of impairments that will almost always meet 

the Rehabilitation Act’s definition of a disability. A person may not have a "targeted 

disability" as defined by Standard Form (SF) 256 (http://www.opm.gov/policy-dataoversight/disability-employment/reference-materials/sf256.pdf) and still be eligible for 

Schedule A. Additionally, an agency should not request that an applicant fill out the SF 

256 until after being hired. SF 256 cannot be used to determine eligibility for 

Schedule A. (https://www.eeoc.gov/eeoc/publications/abc_ada_program_

manager.cfm#_Toc417389575)

71 Key Informant Interview, Peace Corps, (2016/2017), E-mail, telephone, in-person. 

72 Office of Personnel Management (2016) Report on the Employment of People with 

Disabilities in the Federal Executive Branch, https://www.opm.gov/policy-dataoversight/diversity-and-inclusion/reports/disability-report-fy2015.pdf. 

73 Don Steinberg, CEO, World Learning, 2016, accessed February 2, 2018, 

https://www.devex.com/news/aid-groups-fall-short-on-disability-commitmentsadvocates-say-89300. 

74 Department of State (2016), HR Fact Sheet, 

https://www.state.gov/documents/organization/254217.pdf. 

75 Department of State (2016) Workforce Succession Plan, 

https://www.state.gov/documents/organization/262725.pdf. 

76 DOS, Key Informant Interview. 

77 US Department of State, International Disability Rights, accessed February 2, 2018, 

https://www.state.gov/j/drl/sadr/. 
116

 

78 Office of Civil Rights and Diversity, accessed February 2, 2018, 

https://www.usaid.gov/who-we-are/organization/independent-offices/office-civil-rightsand-diversity. 

79 USAID, Careers, accessed February 2, 2018, https://www.usaid.gov/careers. 

80 “Careers”, USAID, accessed January 2017. https://www.usaid.gov/workusaid/careers/hiring-mechanisms/disabilities-employment-program 

81 EEOC, accessed February 2, 2018, https://www.eeoc.gov/federal/. 

82 Disability.gov, accessed February 2, 2018, 

https://www.dol.gov/odep/topics/disability.htm. 

83 DOL, accessed February 2, 2018, https://www.dol.gov/odep/about/. 

84 USAID (2015) Federal Employee Viewpoint Survey, Question 34. 

85 USAID, Advancing Disability Inclusive Development, accessed February 2, 2018, 

https://www.usaid.gov/what-we-do/democracy-human-rights-andgovernance/protecting-human-rights/disability. 

86 The Peace Corps Act (22 U.S.C. Sec. 2504(a)), 

https://legcounsel.house.gov/Comps/Peace%20Corps%20Act.pdf. 

87 29 CFR part 1614, http://files.peacecorps.gov/documents/MS-653-Policy.pdf. 

88 Peace Corps, Key Informant Interview. 

89 Peace Corps, (2015) Annual Report. Accessed January 2017. 

http://files.peacecorps.gov/multimedia/pdf/policies/annrept2015.pdf 

90 FY 2016 Annual Performance Report and FY 2018 Annual Performance Plan, 

https://s3.amazonaws.com/files.peacecorps.gov/documents/open-government/annualperformance-report-fy16-plan-fy18.pdf. 

91 Peace Corps, Strategic Plan. 

92 Peace Corps, Congressional Budget Justification. 

93 Peace Corps, Strategic Plan. 

94 The US Office of Personnel Management’s (OPM) Report on the Employment of 

Individuals with Disabilities in the Federal Executive Branch lists the total number of 

Peace Corps employees with disabilities for 2015 as one. OPM reports from previous 

years show similar single digit numbers that conflict with the agency report that puts 

their total disabled workforce at close to 4,000. Additional information provided by the 

Peace Corps has been included in the report, however; the EEOC reporting that is the 

source of the information is not publically available and was not verified by researchers. 

95 Equal Opportunity Employment Commission (2003) Management Directive 715, 

https://www.eeoc.gov/federal/directives/md715.cfm. 

96 EEOC, Remarks of President George Bush, 

https://www.eeoc.gov/eeoc/history/35th/videos/ada_signing_text.html. 

97 https://overseasbuildings.state.gov/excellence. 

98 Department of State, Overseas Building Report, Accessed January 2017, 

https://overseasbuildings.state.gov/about 

99 Department of State, (no date) Internal Building Report. Not publically available. 

100 DOS, Key Informant Interview (2016). 

101 USAID (2014) Construction Assessment, 

http://pdf.usaid.gov/pdf_docs/PBAAB700.pdf

http://pdf.usaid.gov/pdf_docs/PBAAB700.pdf [accessed July 2017]. 
117

 

102 USAID (2014) Construction Assessment, p.48. 

103 USAID, Wheelchair Program, updated February 19, 2016, 

https://www.usaid.gov/documents/2496/empowerment-and-inclusion-divisionwheelchair-program. 

104 https://www.usaid.gov/sites/default/files/documents/2496/wheelchair%20briefer% 

202_2016.pdf. 

105 https://www.usaid.gov/sites/default/files/documents/1866/WC%20Product%20 

Table.pdf. 

106 http://www.who.int/disabilities/publications/technology/English%20Wheelchair%20 

Guidelines%20(EN%20for%20the%20web).pdf?ua=1. 

107 https://www.usaid.gov/sites/default/files/documents/2496/USAID-Five-Focus-AreasWheelchairs.pdf. 

108 Peace Corps, Medical Information for Applicants, Accessed January 2017, 

http://files.peacecorps.gov/learn/medical/Medical_info_for_applicants.pdf. 

109 Leadership camp for the Deaf, https://www.youtube.com/watch?v=yX4nUqwGcKE. 

110 Peace Corps and HIV, http://files.peacecorps.gov/images/learn/whatvol/hivaids/ 

PC_HIV_AIDS_Global_Summary.pdf. 

111 Peace Corps and Special Olympics, 

http://medialibrary.peacecorps.gov/p852976792/ 

h42239315#h42239315. 

112 Millennium Challenge Corporation, International Finance Corporation’s 

Environmental and Social Performance Standards, not publically available. 

113 Millennium Challenge Corporation, IFC Environment, Health and Safety Guidelines, 

not publically available. 

114 MCC, Key Informant Interview. 

115 Some members of society were relocated due to the road reconstruction. 

116 InterAction (2016) Inclusion And Mobilization Of People With Disabilities In U.S. 

Foreign Assistance, https://www.interaction.org/fabb2016/member-insight/inclusion-andmobilization-disabled-us-foreign-assistance. 

117 Department of State (2009) Human Rights Country Report. 

https://www.state.gov/j/drl/rls/hrrpt/2009/index.htm

118 Department of State (2015) Human Rights Country Report. 

https://www.state.gov/j/drl/rls/hrrpt/2015humanrightsreport/index.htm#wrapper

119 https://eca.state.gov/about-bureau. 

120 https://eca.state.gov/files/bureau/diversity.pdf. 

121 https://eca.state.gov/fulbright/about-fulbright. 

122 https://www.humphreyfellowship.org/about-program. 

123 http://culturalvistas.org/muskie/. 

124 https://exchanges.state.gov/us/program/kennedy-lugar-youth-exchange-study-yesabroad. 

125 https://eca.state.gov/impact/facts-and-figures. 

126 ECA Disabilities in Exchange, https://eca.state.gov/programs-initiatives/disabilitiesexchange-programs. 
118

 

127 USAID, Nondiscrimination for Beneficiaries, accessed February 2, 2018, 

https://www.usaid.gov/what-we-do/democracy-human-rights-andgovernance/protecting-human-rights/nondiscrimination-faq. 

128 USAID (2016) Nondiscrimination for Beneficiaries: Frequently Asked Questions. 

https://www.usaid.gov/what-we-do/democracy-human-rights-andgovernance/protecting-human-rights/nondiscrimination-faq [accessed July 2017]. 

129 Inclusion of Disability in USAID Solicitations for Funding, accessed February 2, 

2018, http://usicd.org/doc/Inclusion-of-Disability-in-USAID-Solicitations-for-Funding.pdf. 

130 http://files.peacecorps.gov/documents/opengovernment/Building_Capacity_Building_Peace.pdf. 

131 https://obamawhitehouse.archives.gov/the-press-office/2011/12/06/presidentialmemorandum-international-initiatives-advance-human-rights-l.

132 https://www.peacecorps.gov/volunteer/is-peace-corps-right-for-me/50plus/. 

133 http://files.peacecorps.gov/documents/opengovernment/Building_Capacity_Building_Peace.pdf. 

134 US Bureau of Resource Management, 

https://www.state.gov/s/d/rm/rls/dosstrat/2007/html/82948.htm. 

National Council on Disability 

1331 F Street, NW, Suite 850 

Washington, DC 20004