U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 

Office of Federal Operations 

Washington, D.C. 20036 

Improving the Participation Rate of People with Targeted 

Disabilities in the Federal Work Force

 

 January 2008 

 iii 

Table of Contents 

Executive Summary..................................................................................................................v

Objectives, Scope, and Methodology ...................................................................................... 1

Background ............................................................................................................................. 2

I. Agencies Required Under Law to Be Model Employers of PWTD....................................... 3

 A. Affirmative Action Program...................................................................................... 3

 B. Individuals with a Reportable Disability ................................................................... 4

 C. Individuals with a Targeted Disability ...................................................................... 4

 D. Initiatives to Improve Equal Opportunity for People with Disabilities ....................... 5

II. Statistics Related to PWTD in the Federal Workforce ....................................................... 11

 A. Participation Rate of PWTD Has Fallen to 0.94% of Total Work Force ................. 11

 B. Federal Agencies Are Not Establishing Goals for PWTD ...................................... 13

 C. Participation Rate for PWTD Among Cabinet Level Agencies............................... 13

 D. PWTD Are Employed at Grade Levels Below Government-Wide Average ........... 15

 E. Mental Illness and Deafness Represent 42% of All Targeted Disabilities.............. 15

 F. Schedule A Hiring Authority Under Utilized............................................................ 17

 G. Separations of PWTD Are Close to Twice the Rate of New Hires......................... 19

 H. Promotions for PWTD Decreased Disproportionately as Compared to the 

 Federal Work Force .............................................................................................. 20

 I. PWTD Received a Smaller Increase in the Percentage of Awards as Compared 

 to the Total Work Force ......................................................................................... 20

 J. Harassment Is Most Frequently Alleged Issue in Disability-Related 

 EEO Complaints .................................................................................................... 21

III. Findings and Recommendations: Suggestions for Overcoming Impediments to the 

Employment of People with Targeted Disabilities in the Federal Work Force............. 23

 1: Improve Coordination Among Partner Agencies................................................... 24

 2: Combat Myths and Stereotypes About Employing PWTD .................................... 25

 3: Demonstrate Top-Level Commitment for Employing PWTD ................................ 26

 4: Improve the Daunting Application Process for Federal Employment .................... 27

 5: Encourage Persons With Disabilities to Self-Identify, and Ensure This 

 Information is Kept Confidential ............................................................................ 28

 6: Provide Managers with Training on Special Hiring Authorities for PWTD ............. 29

 7: Provide Managers with Training on Reasonable Accommodation........................ 30

 8: Enhance Clout of Disability Programs Within Federal Agencies........................... 31

 9: Ensure Accountability ........................................................................................... 32

 10: Recognize Success ............................................................................................. 32

Conclusion............................................................................................................................. 33

Appendix................................................................................................................................ 35
 iv 
 v 

 

 

Executive Summary 

As a part of U.S. Equal Employment Opportunity Commission’s (EEOC) responsibility to monitor 

federal agency compliance with Section 501 of the Rehabilitation Act of 1973, as amended, the 

Office of Federal Operations (OFO) has prepared this report on the participation of people with 

targeted disabilities1 (PWTD) in the federal work force. The purpose of this report is to educate 

the public about recent disability initiatives in the federal sector, highlight data showing the 

declining participation rate of PWTD in the federal government, and provide recommendations that 

may improve employment opportunities for PWTD in the federal government. The ultimate goal is 

to make the federal government the employer of first choice for PWTD.

Despite the initiatives of multiple administrations and the efforts of various agencies charged with 

administering programs for the employment of PWTD (partner agencies), the percentage of 

federal employees with targeted disabilities has declined each year since reaching a peak of 

1.24% in fiscal years (FY) 1993 & 1994. In FY 2006, the participation rate of PWTD fell to 0.94% 

of the federal government’s total work force, the lowest participation rate in 20 years. Similarly, 

the participation rate for the federal government’s permanent workforce also declined in FY 2006, 

to 0.97%. Moreover, despite medical and technological advancements that afford greater 

opportunities for PWTD to work, the participation rate of PWTD has declined while the federal 

workforce overall has actually grown. As noted in the EEOC’s Annual Report on the Federal 

Workforce for FY 2006, from FY 1997 to FY 2006, the Total Work Force increased by 135,732 

employees, a net change of 5.48%. However, the number of federal employees with targeted 

disabilities decreased from 28,671 in FY 1997 to 24,442 in FY 2006, a net change of –14.75%. 

Given the federal government’s mandate to be a model employer, OFO undertook this review to 

examine impediments in the federal sector to the hiring and advancement of PWTD.2

 It is 

imperative that people with disabilities who can and want to work are supported in their efforts to 

do so. In the Findings and Recommendations section of this report, OFO addresses some 

conditions that are deemed to be systemic impediments to the employment of PWTD and 

incorporates best practices and innovative measures that some agencies have taken to improve 

the participation rate of PWTD. Several common obstacles are highlighted below: 

• There is inadequate coordination between the federal agencies and/or programs that were 

created specifically to meet the employment needs of individuals with disabilities; 

1 Targeted disabilities are those disabilities that the federal government, as a matter of policy, has identified for special 

emphasis. The targeted disabilities (and the codes that represent them on the Office of Personnel Management's 

Standard Form 256) are: deafness (16 and 17); blindness (23 and 25); missing extremities (28 and 32 through 38); 

partial paralysis (64 through 68); complete paralysis (71 through 78); convulsive disorders (82); mental retardation (90); 

mental illness (91); and distortion of limb and/or spine (92). 

2

 Questions about data contained in this report, as well as information in the Annual Reports referenced herein, can be 

directed to EEOC’s Office of Federal Operations at 202.663.4599. 
 vi 

• Within the federal government, unfounded fears, myths and stereotypes persist regarding 

the employment of people with disabilities. These beliefs may unlawfully influence some 

employment decisions; 

 • Few agencies have developed strategic plans to improve the recruitment, hiring and 

 retention of PWTD; 

 • The federal application process is daunting to most, but especially to individuals with 

 disabilities; 

 • Agency officials lack knowledge about how to use/implement the Schedule A appointing 

 authority; 

 • Agency officials lack knowledge about how to appropriately respond to reasonable 

 accommodation requests and how to implement retention strategies for PWTD; and 

 • There is insufficient accountability among all levels of the federal government in setting 

 and attaining goals to hire people with disabilities. This is the case among the senior 

 leadership of most agencies. This is also true within agencies created to meet the 

 employment needs of PWTD. 

 Highlighted below are several of the recommendations agencies should consider to improve the 

 hiring and advancement of PWTD. 

 It is recommended that partner agencies consider: 

 • Establishing a cross-agency task force among partner agencies and private organizations, 

 with the goal of improving the hiring, promotion, and advancement of PWTD in the federal 

 government; 

 • Appointing a single disability coordinator to serve as a point of contact for all agencies and 

 the public, as well as a clearinghouse of information on PWTD in the federal government; 

 • Developing a disability training CD/DVD for distribution to all management officials in the 

 federal government; 

 • Publishing guidance for applicants on how to prepare an application for a federal job. 

 Such guidance should include tips on how to use USAJOBS and how to write effective 

 Knowledge, Skills and Abilities (KSA) responses; 

 • Developing a single online application bank to store the resumes of PWTD, by job 

 category/occupational series; and 

 • Establishing an award to recognize agencies that have increased the percentage of PWTD 

 in their work force. 
 vii 

It is recommended that all agencies consider: 

• Establishing numerical hiring goals for PWTD on an annual basis, and incorporating those 

goals into the strategic mission of the agency. Indeed, this task is required by EEOC 

Management Directive 715; 

• Providing mandatory training on disability for all management officials. This training 

should include information on the agency’s current hiring goals, special hiring authorities 

(including Schedule A), reasonable accommodation, and advancement/retention strategies 

for PWTD; 

• Developing procedures for ensuring management accountability, as well as verification 

that goals are obtained; 

• Ensuring that a diversity element is included in senior leaders’ performance appraisals, 

making EEO a critical element; and 

• Issuing a policy statement from the agency head, emphasizing the agency’s policy of 

providing equal employment opportunity for applicants and employees with disabilities, 

and encouraging managers to increase their use of special hiring authorities to fill 

vacancies. 
 viii 
 1 

Objectives, Scope, and Methodology

Consistent with its responsibility to evaluate federal agencies= equal employment opportunity 

(EEO) programs, operations, and activities, the EEOC’s OFO conducted an evaluation to 

(1) educate the public about the history of recent disability initiatives in the federal sector; 

(2) highlight data regarding PWTD in the federal government; and (3) provide recommendations 

that may improve employment opportunities for PWTD in the federal government. Moreover, this 

report is to serve as the foundation for further evaluation of employment trends for PWTD in the 

federal government. The ultimate goal is to make the federal government the employer of first 

choice for PWTD. 

Initially, OFO conducted trend analysis of work force data contained in EEOC’s Annual Report on 

the Federal Work Force (Annual Report), paying particular attention to the trends among the 

largest agencies. OFO subsequently interviewed officials from 12 entities (federal and state) to 

collect information concerning perceived impediments to equal employment opportunity for PWTD 

and best practices for improving the hiring and advancement of PWTD in the federal work force. 

OFO also reviewed various executive orders involving PWTD in the federal work force, and reports 

generated by federal agencies, the National Task Force on Employment of Adults with Disabilities, 

and Cornell University. In addition, OFO examined EEOC Form 715-01 PART J (Part J) of the FY 

2005 MD-715 reports that agencies submitted to EEOC. Finally, OFO considered the issues 

raised in formal complaints that were filed against federal agencies alleging discrimination based 

on mental and/or physical disability. 

Part I of this report provides an overview of the various laws and initiatives that exist within the 

federal government to provide and improve PWTD participation rates. Part II provides statistical 

data on PWTD in the federal workforce. Part III of the report contains our findings and 

recommendations. 
 2 

 

Background

Despite initiatives and efforts by numerous administrations and federal agencies, there has been 

no appreciable improvement in the hiring and advancement of PWTD in the federal work force 

since OFO began monitoring their progress. In fact, the percentage of federal employees with 

targeted disabilities has declined each year since reaching a peak of 1.24% in FYs 1993 & 1994. 

In FY 2006, the participation rate of PWTD fell to 0.94% of the federal government’s total work 

force, the lowest participation rate in over 20 years. 

The decline is evident from numerous perspectives. When looking at the total work force, we note 

that while the total work force increased by 135,732 employees between FY 1997 and FY 2006, a 

net change3 of 5.48%, the number of federal employees with targeted disabilities still decreased 

during the same ten year period from 28,671 in FY 1997 to 24,442 in FY 2006, representing a net 

change of -14.75%. 

The picture is even less promising when looking solely at the permanent work force. The number 

of PWTD in the permanent federal work force declined at a much sharper rate than that of the 

overall permanent federal work force. From FY 1997 to FY 2006, the participation rate for PWTD 

saw a net change of -18.1%. This was disproportionately higher than the net change of -1.75% for 

the overall permanent work force. Moreover, it is notable that although the permanent work force 

increased in five of the ten years from FY 1997 to FY 2006, the participation rate of PWTD 

decreased every year. Essentially, during the last decade, the federal government has lost more 

PWTD each year than it has hired. 

3

 Net change is calculated by subtracting the current year number of employees from the number of employees ten 

years ago and then dividing that result by the number of employees ten years ago and multiplying by 100 to get the 

percentage of change. 
 3 

I. Agencies Required Under Law to Be Model Employers of PWTD

Section 501 of the Rehabilitation Act of 1973 establishes that the federal government may not 

discriminate against people with disabilities in the workplace.4

 Various laws and regulations also 

require federal agencies to attain model employer status for people with targeted disabilities. 

Specifically, the Rehabilitation Act provides that affirmative action program plans must be an 

integral part of ongoing agency personnel management programs, with the goal of hiring, 

placement, and advancement of persons with disabilities. 29 U.S.C. § 791(b). EEOC’s 

regulations similarly establish that the federal government become a model employer of individuals 

with disabilities, and give full consideration to the hiring, placement, and advancement of qualified 

individuals with disabilities. 29 C.F.R. § 1614.203(a). Moreover, federal agencies must promote 

the full realization of equal employment opportunity through a continuing affirmative program for 

people with disabilities. 29 C.F.R. § 1614.101(a). 

Each agency must maintain a continuing affirmative program to promote equal opportunity and 

eliminate discriminatory practices and policies. 29 C.F.R. § 1614.102(a). Such affirmative 

employment programs shall communicate the agency’s EEO policy and program, and its 

employment needs, to all sources of job candidates without regard to disability. 29 C.F.R. 

§ 1614.102(a)(4). 

A. Affirmative Action Program

EEOC Management Directive 715 (MD-715), which became effective on October 1, 2003, 

provides policy guidance and standards for establishing and maintaining an effective affirmative 

action program for the hiring, placement, and advancement of people with disabilities. See MD715, Part B(I). To become a model employer of people with disabilities, the federal government 

must take proactive steps to ensure equal employment opportunity for people with disabilities. Id.

On an annual basis, agencies must conduct an internal review and analysis of the effects of all 

policies, practices, procedures, and conditions that, directly or indirectly, relate to the employment 

of people with disabilities. MD-715, Part B(III). When conducting the analysis, EEOC encourages 

agencies to evaluate themselves against the work force profile of the federal government overall, 

as well as that of agencies ranked highly in EEOC’s most recent Annual Report. Id. When an 

agency=s self-assessment indicates that qualified individuals with disabilities may have been 

denied equal access to employment opportunities, the agency must take steps to identify and 

eliminate the potential workplace barriers. MD-715, Part B(IV). EEOC requires agencies with 

1,000 or more employees to maintain a special recruitment program for PWTD, and to establish 

specific goals for the employment and advancement of such individuals. MD-715, Part B (VI). All 

agencies, regardless of their size or ranking, should ensure that goals “are set and accomplished 

in such a manner that will affect measurable progress from the preceding fiscal year.” Id. 

 

 

4

 In 1992, the Rehabilitation Act, as amended, applies the standards of the Americans with Disabilities Act (ADA) to 

complaints of discrimination by federal employees or applicants for employment. 
 4 

B. Individuals with a Reportable Disability

This report refers to “individuals with a disability,” “individuals with reportable disabilities” and 

“people with targeted disabilities.” Reportable disabilities are those that can be disclosed through 

the use of Standard Form 256 (SF-256). Thus, individuals who have self-identified their disability 

to a reporting agency on the SF-256 are “individuals with a reportable disability.” PWTD are a 

subset of this group, in that targeted disabilities are also reported on the SF-256. 

The final group, “individuals with disabilities,” has a more extensive definition that is used to 

establish who is covered by the Rehabilitation Act (and the Americans with Disabilities Act, 

codified at 42 U.S.C. 12101, et seq.). Pursuant to EEOC’s regulations, an Aindividual with a 

disability@ is a person who has, has a record of, or is regarded as having a physical or mental 

impairment which substantially limits one or more of that person=s major life activities, e.g., caring 

for oneself, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, and 

working. See 29 C.F.R. ' 1630.2(g). An impairment is considered substantially limiting when it 

prevents an individual from performing a major life activity or when it significantly restricts the 

condition, manner, or duration under which an individual can perform a major life activity as 

compared to the ability of the average person in the general population to perform the activity. 

29 C.F.R. ' 1630.2(j). The individual also must show that s/he is a "qualified" individual with a 

disability within the meaning of 29 C.F.R. ' 1630.2(m). With respect to employment, the phrase 

"qualified individual with a disability" is defined as a person who, with or without a reasonable 

accommodation, can perform the essential functions of the position held or desired. Id. 

C. Individuals with a Targeted Disability

The term “targeted disabilities” was first officially recognized by EEOC in MD-703, which was 

approved on December 6, 1979. Individuals with a targeted disability are a subset of those people 

who have a reportable disability, as defined above. Criteria used to select the nine disabilities that 

make up the group of targeted disabilities included the severity of the disability, the feasibility of 

recruitment, and the availability of work force data for individuals with targeted disabilities. EEOC 

recognizes that there are disabilities that are not designated as a “targeted disability,” but may 

nevertheless be just as severe, or more severe, than some targeted disabilities. Nonetheless, 

employment statistics are only collected and maintained for the nine individual targeted disabilities. 

 The purpose of focusing on targeted disabilities is to encourage the hiring, placement, and 

advancement of selected individuals with disabilities in affirmative action planning. 

Several partner agencies have questioned whether the definition of targeted disabilities adopted in 

1979 should be reviewed, given current health issues as well as advances in medicine and 

technology. Further discussion of this issue can be found under Finding 1. 
 5 

D. Initiatives to Improve Equal Opportunity for People with Disabilities

This section describes select initiatives that were enacted to improve the hiring and advancement 

of PWTD in the federal work force. 

The Rehabilitation Act: Interagency Committee on Employment of People with Disabilities 

Pursuant to Section 501(a) of the Rehabilitation Act, as amended, the Interagency Committee on 

Employment of People with Disabilities (ICEPD) was established in 1973 to provide a focus for 

federal employment of people with disabilities and review the adequacy of hiring, placement, and 

advancement practices affecting people with disabilities. The ICEPD was required to periodically 

provide recommendations for legislative and administrative changes to the EEOC, which would 

then transmit the recommendations to Congress. Agencies in the ICEPD have included the 

EEOC, the Office of Personnel Management (OPM), the General Services Administration, the 

Federal Communications Commission, the U.S. Postal Service, and the Departments of Defense, 

Veterans Affairs, Labor, Education, and Health and Human Services. See Section 501 of 

Rehabilitation Act; Executive Orders 11830, 12106, 12450, and 12704. 

Executive Order 12640: President’s Committee on Employment of People with Disabilities

On May 10, 1988, President Ronald Reagan issued Executive Order 12640, which established the 

President’s Committee on Employment of People with Disabilities. The purpose of this Committee 

was to provide advice and information on the development of maximum employment opportunities 

for people with physical or mental disabilities. In particular, the Committee was responsible for 

advising the President about information that could be used by employers, labor unions, and 

organizations, suggesting programs for public education, and suggesting methods of enlisting 

cooperation among the various organizations and agencies. The Committee was comprised of a 

Chair, up to four Vice Chairs, and associate members consisting of heads of federal departments 

or agencies. The Committee also had the authority to invite representatives of business, industry, 

labor, private organizations, and individuals with disabilities to attend the meetings. On January 

10, 2001, the Committee was replaced by the President’s Disability Employment Partnership 

Board in Executive Order 13187. 

Executive Order 13078: National Task Force on Employment of Adults with Disabilities 

On March 13, 1998, President William J. Clinton issued Executive Order 13078, which established 

the National Task Force on Employment of Adults with Disabilities. 5

 This order sought to ensure 

that the federal government is a model employer of people with disabilities. The Task Force was 

instructed to review federal government personnel laws, regulations, and policies in order to 

recommend changes necessary to improve federal employment policies for people with 

disabilities. The Task Force issued reports in 1998, 1999, 2000, and 2002, which provided many 

recommendations to the President for improving the representation of PWTD in the federal 

workforce. 

 

5

 Chaired by OPM, the Task Force agencies included the Departments of Agriculture, Commerce, Education, Health 

and Human Services, Housing and Urban Development, Interior, Justice, Transportation, Treasury, Veterans Affairs, 

EEOC, Federal Communications Commission, National Council on Disability, Small Business Administration, and 

Social Security Administration. 
 6 

Executive Order 13163: Plan to Increase Employment of People with Disabilities 

On July 26, 2000, President William J. Clinton issued Executive Order 13163 to encourage the 

hiring of 100,000 people with disabilities at all levels and occupations of the federal government, 

and to support the goals articulated in Section 501 of the Rehabilitation Act. Based on findings 

that qualified persons with disabilities were refused employment, the Executive Order required 

agencies to: (1) use available hiring authorities; (2) expand their outreach efforts; and (3) increase 

their efforts to accommodate people with disabilities. To accomplish these goals, agencies were 

required to submit a plan to the OPM that outlined their strategies to increase the employment 

opportunities for people with disabilities within their respective agencies. The goals of this 

executive order were to be carried out over the five years following its issuance. 

Executive Order 13164: Reasonable Accommodation Procedures 

Also on July 26, 2000, President Clinton issued Executive Order 13164 to promote a model federal 

workplace that provides reasonable accommodations for: (1) individuals with disabilities in the 

application process for federal employment; (2) federal employees with disabilities in performing 

the essential functions of a position; and (3) federal employees with disabilities to enjoy benefits 

and privileges of employment equal to those enjoyed by employees without disabilities. To 

accomplish these goals, the order requires that executive branch agencies establish effective 

written procedures for processing reasonable accommodation requests under Section 501 of the 

Rehabilitation Act of 1973. The purpose of such procedures is to provide employees, as well as 

supervisors and managers, with an easy-to-understand, step-by-step explanation of the 

reasonable accommodation process. Each agency (and agency sub-components, if appropriate) 

may design procedures that best suit its organizational needs, and submit the procedures, and any 

subsequent modifications, to EEOC for review and comment. To date, EEOC has received 123 

reasonable accommodation procedures from federal agencies and subordinate components. 

Executive Order 13187: President’s Disability Employment Partnership Board

On January 10, 2001, President Clinton issued Executive Order 13187, which established the 

President’s Disability Employment Partnership Board in place of the President’s Committee on 

Employment of People with Disabilities. In promoting the employment of people with disabilities, 

the Board was ordered to (1) develop and submit to the Department of Labor’s Office of Disability 

Employment Policy a comprehensive written plan for joint public-private efforts to promote 

employment opportunities for people with disabilities, and improve their access to financial 

institutions and commercial and business enterprises; (2) identify strategies that may be used by 

employers, labor unions, national and international organizations, and federal, state, and local 

officials to increase employment opportunities for people with disabilities; and (3) submit annual 

written reports to the President on its activities, progress, and problems relating to maximizing 

employment opportunities for people with disabilities. The Board is comprised of 15 members, 

including representatives from business, labor organizations, state or local government, people 

with disabilities, organizations serving people with disabilities, disabled veterans, and researchers 

or academics. The Chairperson of the Board also serves as a member and Vice Chair of the 

National Task Force on Employment of Adults with Disabilities. 
 7 

New Freedom Initiative 

On February 1, 2001, President George W. Bush announced the New Freedom Initiative to 

promote the full integration of people with disabilities into all aspects of American life. The goals of 

this Initiative include expanding educational and employment opportunities, increasing access to 

assistive technologies and public accommodations, and providing accessible transportation and 

housing options for people with disabilities. The EEOC has taken a lead role in implementing the 

following activities, as part of the Initiative: 

• States' Best Practices Project: EEOC initiated a partnership with several states to 

promote the hiring of people with disabilities in state government jobs. In addition to 

reviewing each state's practices with respect to hiring, retention, advancement, and 

reasonable accommodation, the Commission provides consultation, outreach and 

technical assistance to the participating states. EEOC issued a final report that 

highlights best practices and barriers that were uncovered. The four states covered in 

the interim report—Florida, Maryland, Vermont, Washington—were joined by Kansas, 

Missouri, New Hampshire, New Mexico, and Utah in the final report, dated October 

2005. 

• Free workshops: EEOC conducts free workshops on the ADA for small businesses 

and individuals with disabilities. These workshops, which include information on tax 

incentives, community resources, and the rights and responsibilities of employers and 

employees, are aimed at encouraging businesses with 15 to 100 employees to hire 

individuals with disabilities and assisting individuals who are entering the work force to 

better understand the ADA. 

• Outreach Speakers: In addition to ongoing ADA outreach efforts, EEOC also offers 

free outreach speakers for various types of events for individuals with disabilities and 

employers. 

• Corporate Leadership Conferences: EEOC will work with employers to hold corporate 

leadership conferences to advance the hiring of people with disabilities in their regions. 

• Reference and research on the Web: EEOC has developed and placed on its website 

at http://www.eeoc.gov/types/ada.html information about the ADA: Reasonable 

Accommodation for Attorneys; The Americans With Disabilities Act: A Primer for Small 

Business; Telework Fact Sheet; Job Applicants and the Americans with Disabilities Act; 

and How to Comply with the Americans with Disabilities Act: A Guide for Restaurants 

and Other Food Service Employers. The website also includes the following 

information on specific types of disabilities: Blindness and Vision Impairments in the 

Workplace and the ADA; the Association Provision of the Americans with Disabilities 

Act; Diabetes in the Workplace and the ADA; Epilepsy in the Workplace and the ADA, 

Persons with Intellectual Disabilities in the Workplace and the ADA; and Cancer in the 

Workplace and the ADA. 
 8 

Additional EEOC Initiatives 

In addition to the activities listed above, the EEOC has established programs to ensure that all 

applicants and employees enjoy the freedom to compete on a level playing field and advance in 

the workplace as far as their talents and abilities allow. The LEAD Initiative focuses on the 

employment and advancement of PWTD in the federal workforce, while the Freedom to Compete 

Initiative addresses employment and advancement opportunities for all individuals, including 

people with disabilities. 

 

• LEAD (Leadership for the Employment of Americans with Disabilities): Implemented in 

June 2006, the LEAD Initiative addresses the declining number of employees with 

targeted disabilities in the federal workforce. LEAD efforts focus on outreach to senior 

leaders at federal agencies to enhance their awareness of both the employment 

challenges faced by PWTD and policies and practices that can reverse the decline of 

PWTD in the federal work force population. 

• Freedom to Compete: Implemented in 2002, the Freedom to Compete Initiative is an 

outreach, education and partnership campaign designed to emphasize the importance 

of providing equal access to employment opportunities for all individuals, including 

individuals with disabilities. As part of the Initiative, EEOC has engaged stakeholders 

regarding the need to proactively address 21st century workplace needs, established 

alliances with new organizational partners, created a series of public service 

announcements, and presented a series of panel discussions to explore existing and 

emerging employment trends affecting specific segments of the population, including 

individuals with disabilities. 

Cornell University Survey

Pursuant to a grant funded by the Task Force under Executive Order 13078, Cornell University 

conducted a survey of 1,001 supervisors concerning the hiring and advancement of people with 

disabilities. See Survey of the Federal Government on Supervisor Practices in Employment of 

People with Disabilities, Bruyère, S., Erickson, W., &; Horne, R., (2002) [Cornell University 

Survey]. The supervisors were employed by the seventeen executive branch agencies that served 

as members of the Task Force. The Task Force agencies comprised 948,867 (54%) of the total 

employees in the federal government in 2002, including 63,424 people with disabilities, of which 

11,790 were PWTD. Cornell University published the results of the survey in 2002. The findings 

pertinent to this report indicated the following: 

• Three out of five respondents (60%) were unaware of Executive Order 13163, requiring 

the hiring of 100,000 qualified individuals with disabilities over a five-year period. 

• Two out of five supervisors surveyed reported being aware of the EEOC guidelines for 

federal agencies to establish written procedures to facilitate the provision of reasonable 

accommodation (Executive Order 13164). Nearly half of those aware of this provision 

indicated that it had influenced their supervisory practice either “a great deal” or 

“somewhat.” The level of awareness and influence was higher for those who had 

experience supervising employees with disabilities. 
 9 

• Over half of the supervisors involved in recruitment reported being very familiar or 

somewhat familiar with the special hiring authorities for the federal government that 

promote hiring disabled veterans. However, only approximately one-third were familiar 

with hiring readers/interpreters and other personal assistants for employees with 

disabilities, and the special hiring authorities for hiring people with disabilities. 

• Respondents indicated visible top management commitment and skills/training for 

employees with disabilities were the most effective means of reducing remaining 

barriers to employment or advancement of people with disabilities. 

Model Federal Agency Plan for the Employment of People with Disabilities 

Based upon the plans that OPM received from agencies pursuant to Executive Order 13163, OPM 

issued the Model Federal Agency Plan for the Employment of People with Disabilities in August 

2004. The plan identifies six best practices that agencies have used to increase the hiring and 

advancement of people with disabilities, including: 

• Recruiting widely for positions at all levels, utilizing a recruitment plan; 

• Providing opportunities for students with disabilities in collaboration with colleges and 

universities; 

• Giving consideration to employees with disabilities for inclusion in developmental 

opportunities; 

• Collecting and maintaining data to monitor progress; 

• Providing reasonable accommodations for qualified applicants and employees with 

disabilities, consistent with each agencies= reasonable accommodation policies as well 

as the guidance from OPM and EEOC; and 

• Providing appropriate training to senior leadership and managers to ensure that they 

understand the agency=s commitment to employ people with disabilities and that they 

can use special programs to recruit, appoint, and provide reasonable accommodation. 

In summary, various agencies, initiatives and task forces have studied the issue of employment of 

individuals with disabilities. Many recommendations for improving the hiring and advancement of 

PWTD in the federal work force followed. Although it is unclear to what extent agencies have 

implemented the recommendations, data in Section II of this report makes clear that, despite the 

studies and initiatives, the participation rate of PWTD has steadily declined. 
 10 
 11 

II. Statistics Related to PWTD in the Federal Workforce

To understand the status of PWTD in the federal work force, we have collected data from the 

Central Personnel Data File (CPDF),6

 maintained by OPM, as well as reports that agencies have 

submitted to EEOC, including Form 462 reports and MD-715 reports. In the tables below, we 

provide data, and where appropriate, trend analysis on the following topics: (1) PWTD in the 

federal work force; (2) goals for recruitment of PWTD; (3) ranking of cabinet level agencies by 

percentage of PWTD; (4) grade groupings of PWTD; (5) participation of PWTD by type of targeted 

disabilities; (6) new hires of PWTD; (7) separations of PWTD; (8) promotions of PWTD; (9) awards 

for PWTD; and (10) most frequently raised issues in complaints alleging disability discrimination. 

A. Participation Rate of PWTD Has Fallen to 0.94% of Total Federal Work Force 

Based upon CPDF data from the OPM, the participation rate of PWTD in the total federal work 

force fell to 0.94% in FY 2006, the lowest participation rate in 20 years. See FY 2006 Annual 

Report. The participation rate of PWTD peaked at 1.24% in FYs 1993 & 1994. When looking 

strictly at those employed permanently, the decline is more pronounced. The participation rate for 

PWTD in the permanent work force fell to 0.97% in FY 2006, the lowest since 1985. See Table 1. 

Table 1 shows that since FY 1985, the participation rate of permanently employed PWTD has 

decreased at a disproportionately higher rate than that of the federal government’s overall 

permanent work force. Although the permanent work force has decreased by 15.9% since FY 

1985 and by 3.2% since FY 1995, the participation rate of PWTD declined by 19.78% and 22.18% 

during those respective time frames. 

Table 1 also shows that even when the workforce increases, the population of PWTD still declines. 

 Between FY 1997 and FY 2006, the permanent work force increased in five of the ten years. The 

participation rate of PWTD during that same ten year period nonetheless decreased every year. 

Moreover, in the five years when the size of the permanent work force decreased between FY 

1997 and FY 2006, the participation rate for PWTD had a disproportionately higher decrease. For 

example, from FY 2002 to FY 2003, the permanent work force declined by 1.27%, but PWTD 

declined by twice as much at 2.59%. Overall, the federal government is losing more PWTD than it 

is hiring each year. 

 

6

 CPDF is an automated file created by OPM. CPDF does not include data for the Tennessee Valley Authority, United 

States Postal Service, Army Air Force Exchange Service (AAFES), Federal Energy Regulatory Commission, Foreign 

Service, Central Intelligence Agency, Defense Intelligence Agency, National Security Agency, or the Federal Bureau of 

Investigation in the Department of Justice. These agencies make up approximately 30% of the federal work force. 
 12 

Table 1: Permanent Employees with Targeted Disabilities in the Federal Work Force7

FY 1985 – FY 2006 

Fiscal Total Perm. Work Force (PWF) Employees with Targeted Disabilities 

Year 

(FY) # % Change from 

Prior FY # % Change from Prior FY % of PWF 

1985 2,892,225 2.70% 29,282 8.46% 1.01% 

1986 2,894,732 0.09% 30,320 3.54% 1.05% 

1987 2,943,878 1.70% 32,149 6.03% 1.09% 

1988 2,790,287 -5.22% 30,736 -4.40% 1.10% 

1989 2,807,546 0.62% 31,956 3.97% 1.14% 

1990 2,786,143 -0.76% 32,145 0.59% 1.15% 

1991 2,772,396 -0.49% 32,950 2.50% 1.19% 

1992 2,737,331 -1.26% 33,379 1.30% 1.22% 

1993 2,656,033 -2.97% 32,989 -1.17% 1.24% 

1994 2,616,393 -1.49% 32,337 -1.98% 1.24% 

1995 2,512,776 -3.96% 30,185 -6.65% 1.20% 

1996 2,532,507 0.79% 29,930 -0.84% 1.18% 

1997 2,475,761 -2.24% 28,671 -4.21% 1.16% 

1998 2,479,199 0.14% 28,035 -2.22% 1.14% 

1999 2,462,152 -0.69% 27,601 -1.55% 1.13% 

2000 2,442,643 -0.79% 27,231 -1.34% 1.12% 

2001 2,445,335 0.11% 26,834 -1.46% 1.10% 

2002 2,459,505 0.58% 26,230 -2.25% 1.07% 

2003 2,428,330 -1.27% 25,551 -2.59% 1.05% 

2004 2,437,458 0.38% 24,816 -2.87% 1.02% 

2005 2,441,287 0.16% 24,086 -2.94% 0.99% 

2006 2,432,314 -0.37% 23,490 -2.47% 0.97% 

The Census Bureau provides data reflecting general and specific civilian labor force participation 

rates categorized by race, national origin, and gender. There is no comparable data, however, 

currently collected or reported by the Census Bureau for people with disabilities. Thus, it is difficult 

to conduct analysis and/or determine expected participation rates for people with disabilities, as is 

done for all other groups based on race and gender. Because of the absence of Census data 

concerning the general availability of people with disabilities in the work force, EEOC requires 

agencies to benchmark themselves against both the agency with the highest percentage of 

PWTD, which is published in EEOC’s Annual Reports, and against its own participation rate in the 

previous year to determine if progress is being made. In FY 2006, the federal high was 2.37% for 

agencies with 500 or more total employees. 

In addition to the absence of Census availability data for people with disabilities, any statistical 

analysis is complicated by the fact that the types of disabilities vary tremendously, making gross 

statistical comparisons of limited value. These limitations notwithstanding, analysis of the above 

information can help facilitate an assessment concerning the extent to which PWTD are provided 

equal employment opportunities within every agency. 

 

7

Table 1 includes only permanent in pay status work force data, which varies from the data reported in the FY 2004 – 

FY 2006 Annual Reports on the Federal Work Force. Since MD-715 was issued in 2003, EEOC’s Annual Report has 

included the total work force when calculating the participation rate for PWTD: 0.99% in FY 2004, 0.96% in FY 2005 

and 0.94% in FY 2006. 
 13 

B. Many Federal Agencies Are Not Establishing Goals for PWTD

Through MD-715, EEOC requires agencies with 1,000 or more employees to maintain a special 

recruitment program for PWTD and to establish specific goals for the employment and 

advancement of such individuals.8

 MD-715, Part B(VI). Fulfillment of this requirement is 

monitored with the use of Part J submissions. Agencies should set goals with an eye toward 

affecting measurable progress from year to year. To accomplish hiring and/or advancement goals, 

agencies should, as appropriate: (1) engage in targeted outreach and recruitment; (2) take 

advantage of special appointing authorities; (3) create training and development plans for people 

with disabilities; and (4) take disability into account in selection decisions where an individual with 

a disability is otherwise qualified with or without a reasonable accommodation. Id.

A review of PART Js submitted as part of FY 2005 MD-715 reports reveals that despite the 

declining participation rate of PWTD in the federal government, only 15.82% of agencies 

established a numerical goal for increasing the employment of PWTD in their work force. A total of 

41.14% of agencies reported that they established non-numerical objectives9 for PWTD in their 

work force. These figures indicate that 43% of agencies failed to establish any type of goal to 

improve the employment outlook for PWTD at their agency. This may account for why little 

progress is actually being realized. According to the Cornell University Survey, only 51% of 

supervisors reported that their agency made a “great deal of effort” to achieve affirmative 

employment goals, and another 30% stated that their agency made “somewhat” of an effort to 

achieve the goals. 

C. Participation Rate for PWTD Among Cabinet Level Agencies

Cabinet level agencies play an important role in the hiring and advancement of PWTD in the federal 

workforce. The agencies included in Table 2 comprise 66% of the entire federal work force.10 In FY 

2006, only seven of the 15 cabinet agencies had a participation rate for PWTD that met or 

exceeded the government-wide rate of 0.94% in the total work force. See Table 2: Ranking Cabinet 

Level Agencies by PWTD.

11 

Several cabinet level agencies had numerical increases in their populations of PWTD over the ten 

year period of FY 1997 to FY 2006. However, only two cabinet level agencies realized participation 

rate increases over that time period: (1) Department of the Treasury increased from 1.59% to 

1.73%; and (2) Department of Labor increased from 1.19% to 1.21%. 

 

8

 For purposes of this requirement, the term “agencies” includes any and all sub-components, field offices, regions, 

etc., within an agency or department that has 1,000 or more employees. 

9

 A non-numerical goal is one where the agency indicates it will hire PWTD within the next few years, without regard to 

the number of PWTD it would need to hire to improve the participation rate, given any loss of PWTD it may experience. 

10 The federal government’s total work force population was 2,611,493 in FY 2006. The total population of cabinet 

level agencies in FY 2006 was 1,668,450. See FY 2006 Annual Report.

11 Unlike Table 1, which reflects the participation rate of PWTD in the permanent work force, Table 2 utilizes 

participation rates of PWTD in the total work force as of September 30, 2006. 
 14 

Table 2: Ranking Cabinet Level Agencies by PWTD 

FY 1997 – FY 200612

Fiscal Year (FY) 

Agencies 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 

# 2,184 2,176 2,167 2,144 2,204 2,150 2,157 2,105 1,964 1,842 

1. Treasury % 1.59% 1.58% 1.55% 1.54% 1.53% 1.53% 1.99% 1.90% 1.82% 1.73% 

# 3,725 3,621 3,517 3,512 3,501 3,399 3,623 3,692 3,566 3,566 

2. Veterans Affairs % 1.85% 1.83% 1.80% 1.79% 1.74% 1.69% 1.75% 1.56% 1.52% 1.49% 

# 80 78 79 81 74 73 73 73 63 59 

3. Education % 1.88% 1.81% 1.81% 1.85% 1.68% 1.69% 1.73% 1.59% 1.42% 1.36% 

4. Housing & Urban # 162 144 137 137 136 138 148 139 134 130 

 Development % 1.62% 1.53% 1.45% 1.39% 1.40% 1.41% 1.45% 1.36% 1.35% 1.32% 

# 182 197 185 186 190 184 221 206 207 186 

5. Labor % 1.19% 1.29% 1.21% 1.19% 1.19% 1.16% 1.40% 1.30% 1.35% 1.21% 

# 1,082 1,041 1,013 1,001 988 990 1077 1,068 1,000 1,009 

6. Agriculture % 1.24% 1.21% 1.19% 1.17% 1.12% 1.09% 1.20% 0.95% 0.91% 0.96% 

# 533 530 579 603 609 598 702 692 678 684 

7. Interior % 0.95% 0.94% 1.02% 1.05% 1.03% 0.99% 1.15% 0.89% 0.88% 0.94% 

8. Health & Human # 564 567 567 574 614 619 673 651 624 576 

 Services % 1.16% 1.15% 1.13% 1.12% 1.18% 1.14% 1.27% 1.02% 0.97% 0.91% 

# 8,734 8,245 7,827 7,526 7,133 6,922 6,021 5,747 5,643 6,053 

9. Defense % 1.20% 1.18% 1.16& 1.13% 1.08% 1.05% 0.89% 0.84% 0.81% 0.86% 

# 304 321 338 340 341 313 334 319 358 334 

10. Commerce % 0.95% 0.98% 0.99& 1.00% 0.97% 0.87% 0.94% 0.84% 0.89% 0.82% 

# 131 124 116 129 128 127 122 119 116 111 

11. Energy % 0.78% 0.78% 0.75% 0.84% 0.82% 0.81% 0.80% 0.79% 0.77% 0.74% 

# 348 338 333 334 356 498 307 322 298 285 

12. Transportation % 0.55% 0.53% 0.53% 0.54% 0.55% 0.49% 0.53% 0.56% 0.55% 0.53% 

# -- -- -- -- -- -- 756 740 720 709 

13. Homeland Security % -- -- -- -- -- -- 0.69% 0.45% 0.44% 0.42% 

# 453 474 500 493 485 485 396 406 406 413 

14. Justice % 0.41% 0.40% 0.42% 0.41% 0.40% 0.39% 0.40% 0.39% 0.39% 0.39% 

# 68 63 63 69 64 67 93 93 90 88 

15. State % 0.58% 0.54% 0.53% 0.52% 0.48% 0.49% 0.53% 0.39% 0.37% 0.36% 

# 28,671 28,035 27,601 27,231 26,834 26,230 25,551 25,917 25,142 24,442 

Total Work Force % 1.16% 1.13% 1.12% 1.11% 1.10% 1.07% 1.05% 0.99% 0.96% 0.94% 

 

12 Table 2 identifies participation rates based on total work force for FY 2000 – FY 2006. For years prior to FY 

2000, the data reflects participation rates based on permanent employees only. The total work force figures are as 

reported in CPDF plus AAFES & the Foreign Service. 
 15 

D. PWTD Are Employed at Grade Levels Below Government-Wide Average

In addition to the declining numbers of PWTD employed in the federal work force, there is also 

evidence that PWTD are compensated at a lower rate than other employees. In FY 2006, the 

average general schedule and related (GSR) grade level for PWTD was 8.5, a full grade and a half 

below the government-wide average of 10. See EEOC Annual Report (FY 2006), Table A-6a in 

App. III. As noted in Table 3 below, over 51% of the federal employees with targeted disabilities 

were employed in GSR grades 1 to 8, as compared to only 32% of the total work force in FY 2006. 

See Table 3. It is worth noting, however, that pay distribution is improving. The participation rates 

for PWTD in grades 1-8 have declined from 58.95% in FY 1997 to 51.37% in FY 2006, while the 

participation rates for PWTD in grades 12 and above have steadily increased. During FY 2006, 

6.41% of all PWTD participated in Senior Grade levels (GS-14 to Senior Pay), which is a little 

more than half the rate of participation for the total work force (10%). From FY 1997 to FY 2006, 

the highest net change in the participation rate of PWTD occurred at the GS-14/15 pay levels 

(+27.59%), with the senior pay level (+13.92%) ranking second. 

Table 3: Targeted Disabilities by Grade Groupings among PWTD13

FY 1997 – FY 2006 

Fiscal Year (FY) 

Grade Grouping 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 

# 10,105 9,754 8,627 9,313 9,146 8,738 8,499 8,227 7,905 7,429 GSR 

1 to 8 % 58.95% 57.67% 54.08% 57.09% 56.27% 54.64% 53.74% 53.25% 52.49% 51.37% 

# 3,341 3,283 3,202 3,150 3,160 3,233 3,185 3,134 3,046 3,010 GSR 

9 to 11 % 19.49% 19.58% 19.47% 19.31% 19.44 20.22% 20.14% 20.29% 20.23% 20.81% 

# 2,962 2,985 3,000 3,061 3,151 3,168 3,242 3,163 3,170 3,097 GSR 

12 to 13 % 17.28% 17.81% 18.24% 18.77% 19.39% 19.81% 20.50% 20.47% 21.05% 21.41% 

# 656 666 684 708 718 769 806 841 850 837 GSR 

14 to 15 % 3.83% 3.97% 4.16% 4.34% 4.42% 4.81% 5.10% 5.44% 5.64% 5.79% 

# 79 75 75 80 79 84 82 84 88 90 Senior 

Pay % 0.46% 0.45% 0.46% 0.49% 0.49% 0.53% 0.52% 0.54% 0.58% 0.62% 

Total 

PWTD 

# 

17,143 16,763 16,443 16,312 16,254 15,992 15,814 15,449 15,059 14,463 

 E. Mental Illness and Deafness Represent 42% of All Targeted Disabilities 

Among all targeted disabilities, mental illness has represented the highest percentage of PWTD in 

the federal work force since it surpassed deafness in FY 1998. From FY 1997 to FY 2006, federal 

employees with mental illness and deafness have represented at least 38% of all PWTD, 

combining for 42.39% in FY 2006. See Table 4. In contrast, employees with distortion of 

limb/spine have represented the fewest, at less than 3%. Although the participation rate for all 

PWTD has declined overall from FY 1997 to FY 2006, the participation rates for three individual 

targeted disability groups increased slightly during this time period: mental illness, blindness, and 

 

13 This table does not include the data for employees in the Wage and Non-GSR pay systems. 
 16 

convulsive disorders. During the same time period, the individual targeted disability groups that 

experienced the greatest decline in participation rates were mental retardation (decrease of 

23.23%), missing extremities (decrease of 12.98%), and deafness (decrease of 7.22%). 

Table 4: Percentage of Disability Types Among PWTD 

FY 1997 – FY 2006 

Type of Targeted 

Disabilities 

FY 

1997 

FY 

1998 

FY 

1999 

FY 

2000 

FY 

2001 

FY 

2002 

FY 

2003 

FY 

2004 

FY 

2005 

FY 

2006 

# 5,639 5,512 5,368 5,220 5,088 4,949 4,796 4,745 4,614 4,460 

Deafness % 19.67% 19.66% 19.45% 19.17% 18.96% 18.87% 18.77% 18.31% 18.35% 18.25% 

# 2,676 2,615 2,570 2,603 2,636 2,582 2,588 2,687 2,606 2,573 

Blindness % 9.33% 9.33% 9.31% 9.56% 9.82% 9.84% 10.13% 10.37% 10.37% 10.53% 

# 1,856 1,812 1,733 1,697 1,627 1,556 1,525 1,505 1,446 1,376 Missing 

Extremities % 6.47% 6.46% 6.28% 6.23% 6.06% 5.93% 5.97% 5.81% 5.75% 5.63% 

# 3,694 3,585 3,503 3,475 3,346 3,283 3,219 3,229 3,111 2,984 Partial 

Paralysis % 12.88% 12.79% 12.69% 12.76% 12.47% 12.52% 12.60% 12.46% 12.37% 12.21% 

# 1,559 1,507 1,459 1,435 1,415 1,387 1,316 1,328 1,258 1,222 Complete 

Paralysis % 5.44% 5.38% 5.29% 5.27% 5.27% 5.29% 5.15% 5.12% 5.00% 5.00% 

# 3,967 3,860 3,826 3,811 3,767 3,730 3,637 3,660 3,537 3,452 Convulsive 

Disorders % 13.84% 13.93% 13.86% 14.00% 14.04% 14.22% 14.23% 14.12% 14.07% 14.12% 

# 2,837 2,770 2,672 2,533 2,428 2,261 2,106 2,057 1,946 1,857 Mental 

Retardation % 9.90% 9.88% 9.68% 9.30% 9.05% 8.62% 8.24% 7.94% 7.74% 7.60% 

# 5,622 5,579 5,690 5,697 5,801 5,786 5,695 6,043 5,982 5,900 Mental 

Illness % 19.61% 19.90% 20.62% 20.92% 21.62% 22.06% 22.29% 23.32% 23.79% 24.14% 

# 821 795 780 757 726 696 669 663 642 618 Distortion 

Limb/Spine % 2.86% 2.84% 2.83% 2.78% 2.71% 2.65% 2.62% 2.56% 2.55% 2.53% 

# 28,671 28,035 27,601 27,231 26,834 26,230 25,551 25,917 25,142 24,442 Total 

Targeted 

Disabilities % 1.16% 1.14% 1.13% 1.12% 1.10% 1.07% 1.05% 0.99% 0.96% 0.94% 

Federal 

Work Force # 2,475,761 2,479,199 2,462,152 2,442,643 2,445,335 2,459,505 2,428,330 2,606,903 2,610,920 2,611,493 
 17 

 F. Schedule A Hiring Authority is Under Utilized

Several hiring authorities designed specifically for use by and for people with disabilities are 

available for the federal hiring process. The broadest of these authorities is the Schedule A 

appointing authority, which allows for non-competitive appointment of individuals with disabilities. 

See 5 C.F.R. § 213.3102(u). This non-competitive appointment authority is an alternative to the 

traditional, and often arduous competitive process.14 Schedule A was designed to provide job 

opportunities to persons with severe physical disabilities, psychiatric disabilities, and/or mental 

retardation.15 In FY 2006, 326 individuals were hired under Schedule A, which amounts to 0.14% 

of all new hires. See Table 5. This represents a slight percentage increase from 0.13% in FY 

2002. Id. 

In addition to Schedule A, there is Schedule B, another non-competitive hiring authority. See

5 C.F.R. § 213.3202. Schedule B applies to jobs and situations for which it is impractical to rate 

applicants using competitive procedures; however, applicants must meet the qualification 

standards for the job. Schedule B includes hiring authorities for the Student Temporary 

Employment Program, the Student Career Experience Program, and the Federal Career Intern 

Program. Id. In FY 2006, 0.06% of new PWTD hires in the federal government arose through 

Schedule B appointment authority. See Table 5. This represents a decrease from the 0.07% of 

PWTD hired under Schedule B in FY 2002. 

From FY 2002 to FY 2006, PWTD were hired at rates well below their participation rate in the 

federal work force (0.94%), and well below the federal highs reported in EEOC Annual Reports. 

When looking at all new hires, the rate of hire for PWTD declined from 0.60% in FY 2002 to 0.55% 

in FY 2006. Further, although the total number of new hires in the federal government decreased 

by 15.23% from FY 2002 to FY 2006, the number of new hires of PWTD decreased at a higher 

rate – 23.15% – in that same period. These figures indicate that PWTD are subjected to a 

disproportionate negative impact resulting from most federal employment trends. 

 

14 As reported by the Merit Systems Protection Board (MSPB) in Reforming Federal Hiring -- Beyond Faster and 

Cheaper, September 2006. The MSPB, using data from OPM, reported that it takes an average of 102 days to 

complete all of the steps in the competitive hiring process (from making the request to fill the position to making 

the appointment). 

15 Detailed information concerning criteria and options for using special hiring authorities, including Schedule A, can be 

found on the Office of Personnel Management's (OPM) website at www.opm.gov. 
 18 

Table 5: New Hires for PWTD in the Total Work Force (TWF) 

FY 2002 – FY 2006 

New Hires of FY 2002 FY 2003 FY 2004 FY 2005 FY 2006 

PWTD # % # % # % # % # % 

Schedule A Total 358 34.46% 301 35.79% 345 41.32% 355 43.83% 326 25.12%

% of TWF 

New Hires 0.13% 0.12% 0.15% 0.15% 0.14% 

Schedule A 

Permanent 154 14.82% 120 14.27% 129 15.45% 119 14.69% 126 9.71% 

% of TWF 

New Hires 0.05% 0.05% 0.05% 0.05% 0.05% 

Schedule A 

Time Limited 0 0.00% 0 0.00% 0 0.00% 0 0.00% 0 0.00% 

% of TWF 

New Hires 0.00% 0.00% 0.00% 0.00% 0.00% 

Schedule A 

Temporary 204 19.63% 181 21.52% 216 25.87% 236 29.14% 200 15.41%

% of TWF 

New Hires 0.07% 0.07% 0.09% 0.10% 0.08% 

CareerConditional 458 44.08% 356 42.33% 317 37.96% 286 35.31% 303 23.34%

% of TWF New 

Hires 0.16% 0.14% 0.13% 0.12% 0.13% 

Schedule B 190 18.29% 151 17.95% 135 16.17% 142 17.53% 145 11.17%

% of TWF New 

Hires 0.07% 0.06% 0.06% 0.06% 0.06% 

Career 39 3.75% 38 4.52% 39 4.67% 28 3.46% 30 2.31% 

% of TWF New 

Hires 0.01% 0.01% 0.02% 0.01% 0.01% 

1,689 100% 1,515 100% 1,368 100% 1,263 100% 1,298 100% Total New Hires 

of PWTD 0.60% 0.58% 0.58% 0.54% 0.55% 

All New Hires 281,514 259,499 236,440 235,029 237,612 
 19 

 G. Separations of PWTD are Close to Twice the Rate of New Hires

 

From FY 2002 to FY 2006, PWTD have separated from the federal work force at nearly twice their 

rate of hire. Compare each year’s separation rate for PWTD (0.98%, 0.97%, 0.92%, 0.95%, and 

0.92% respectively) to each year’s hire rate for PWTD (0.60%, 0.58%, 0.58%, 0.54%, and 0.55% 

respectively). See Tables 5 & 6. 

Table 6: Separations for PWTD in Total Federal Work Force 

FY 2002 – FY 2006 

FY 2002 FY 2003 FY 2004 FY 2005 FY 2006 

Separations # % # % # % # % # % 

Targeted 

Disabilities 2,054 0.98% 2,129 0.97% 2,038 0.92% 2,224 0.95% 2,096 0.92% 

Reportable 

Disabilities 13,053 6.25% 14,006 6.36% 13,870 6.24% 14,981 6.37% 14,095 6.20% 

No 

Disabilities 195,926 93.75% 206,130 93.64% 208,244 93.76% 220,244 93.63% 213,298 93.80% 

Total 

Separations 208,979 100.00% 220,136 100.00% 222,114 100.00% 235,225 100.00% 227,393 100.00% 

In FY 2006, 39.41% of PWTD separated from the federal government due to retirement,16

exceeding all other types of separations. See Table 7. For the past four years the second highest 

separation reason has been quitting. 

Table 7: Types of Separations of PWTD in the Total Work Force FY 2002 – FY 2006 

Types of 

Separations 

FY 

2002 

FY 

2003 

FY 

2004 

FY 

2005 

FY 

2006 

# 614 837 834 892 826 

Retirement % 29.89% 39.31% 40.92% 40.11% 39.41% 

# 693 622 606 671 622 

Quit 17 % 33.74% 29.22% 29.74% 30.17% 29.68% 

# 198 213 174 173 164 

Discharge % 9.64% 10.00% 8.54% 7.78% 7.82 

# 77 64 64 71 77 

Death % 3.75% 3.01% 3.14% 3.19% 3.67% 

# 42 43 26 62 29 

RIF % 2.04% 2.02% 1.28% 2.79% 1.38% 

# 430 350 334 355 378 

Other % 20.93% 16.44% 16.39% 15.96% 18.03% 

TOTAL # 2,054 2,129 2,038 2,224 2,096 

 

16 The types of retirement include mandatory, disability, voluntary, special option, and in lieu of involuntary action. 

17 Quit shows data for voluntary resignations or separations if an employee declines a new assignment, abandons a 

position, joins the military, or fails to return from military furlough. It excludes resignations due to in lieu of adverse 

actions, which are captured as Other, along with early-outs. 
 20 

H. Promotions for PWTD Decreased Disproportionately as Compared to the Total 

Work Force

The large numbers of PWTD leaving the federal government may be related to the apparent lack 

of promotional opportunities available to this group, as compared to the opportunities available to 

the TWF overall. See Table 8. From FY 2002 to FY 2006, the number of promotions and rate of 

promotion for PWTD decreased by 25.19%. In comparison, the rate of promotion for individuals 

with no disabilities and the rate of promotion for the total federal work force decreased by 3.99% 

and 4.36%, respectively, during the same time period. Id. Similar to hiring concerns noted above, 

PWTD also received promotions (0.70%) below their participation rate in the federal work force 

(0.94%) in FY 2006. 

Table 8: Promotions for PWTD in Federal Work Force 

FY 2002 – FY 2006 

FY 2002 FY 2003 FY 2004 FY 2005 FY 2006 

Promotions # % # % # % # % # % 

Targeted 

Disabilities 2,604 0.90% 2,255 0.83% 2,230 0.80% 2,098 0.76% 1,948 0.70% 

Reportable 

Disabilities 15,915 5.50% 14,750 5.45% 14,831 5.32% 14,321 5.21% 14,225 5.15% 

No 

Disabilities 273,658 94.50% 255,901 94.55% 264,059 94.68% 260,400 94.79% 262,730 94.86 

Total 

Promotions 289,573 100.00% 270,651 100.00% 278,890 100.00% 274,721 100.00% 276,955 100.00% 

I. PWTD Received a Smaller Increase in the Percentage of Awards as Compared 

to the Total Work Force

From FY 2002 to FY 2006, the number of PWTD who received awards increased 8.44%, while the 

representation of individuals with no disabilities among all award recipients increased 21.27%. In 

FY 2006, PWTD received awards at a rate very close to their participation rate in the total work 

force. Overall, the total number of awards given out increased by 21.20% during this period. 

Recognition of PWTD for their accomplishments provides increased disability employment 

awareness, which could result in increased hiring.

Table 9: Awards for PWTD in Federal Work Force FY 2002 – FY 2006 

FY 2002 FY 2003 FY 2004 FY 2005 FY 2006 

Awards # % # % # % # % # % 

Targeted 

Disabilities 17,843 1.03% 17,959 1.05% 18,689 1.03% 19,928 1.01% 18,958 0.93% 

Reportable 

Disabilities 103,494 6.12% 106,965 6.24% 113,937 6.26% 124,524 6.34% 124,357 6.07% 

No 

Disabilities 1,586,476 93.88% 1,606,382 93.76% 1,705,271 93.74% 1,839,497 93.66% 1,923,957 93.93% 

Total 

Awards 1,689,970 100.00% 1,713,347 100.00% 1,819,208 100.00% 1,964,021 100.00% 2,048,314 100.00% 
 21 

J. Harassment Is Most Frequently Alleged Issue in Disability-Related EEO 

Complaints

Since FY 2002, harassment has been the most frequently alleged issue in complaints of 

discrimination filed by individuals on the basis of mental or physical disability. See Tables 10 and 

11. Further, since FY 2002, the percentage of EEO complaints alleging harassment based on 

disability has steadily increased, peaking in FY 2006. As well, complaints involving reasonable 

accommodation or discipline issues have been consistently among the most frequently alleged 

issues. Id.

Table 10: Top Three Issues for EEO Complaints Based on Mental Disability 

FY 2002 – FY 2006 

Top 3 Issues FY 2002 FY 2003 FY 2004 FY 2005 FY 2006 

1 Harassment Harassment Harassment Harassment Harassment 

434 31.27% 387 27.37% 407 30.69% 431 33.46% 430 38.10% 

2 Discipline Discipline Discipline Discipline 

Reasonable 

Accommodation 

201 14.48% 232 16.41% 284 21.42% 296 22.98% 287 25.40% 

3 

Terms/Conditions 

of Employment 

Reasonable 

Accommodation 

Reasonable 

Accommodation 

Reasonable 

Accommodation Discipline 

178 12.82% 180 12.73% 177 13.35% 228 17.70% 254 22.50% 

Total Complaints of 

Mental Disability 1,388 6.32% 1,414 6.99% 1,326 6.97% 1,288 7.15% 1,130 6.76% 

Total Complaints 

Filed 21,945 20,226 19,024 18,017 16,723 

Table 11: Top Three Issues for EEO Complaints Based on Physical Disability 

FY 2002 – FY 2006 

Top 3 Issues FY 2002 FY 2003 FY 2004 FY 2005 FY 2006 

1 Harassment Harassment Harassment Harassment Harassment 

1,119 22.87% 1,006 20.53% 1,022 22.67% 1,101 26.61% 1,172 30.50% 

2 

Terms/Conditions 

of Employment 

Reasonable 

Accommodation 

Reasonable 

Accommodation 

Reasonable 

Accommodation 

Reasonable 

Accommodation 

844 17.25% 747 15.24% 801 17.73% 846 20.45% 849 22.10% 

3 Discipline 

Terms/Conditions of 

Employment Discipline Discipline 

Terms/Conditions of 

Employment 

544 11.12% 605 12.34% 696 15.41% 700 16.92% 675 17.56% 

Total Complaints of 

Physical Disability 4,892 22.29% 4,901 24.23% 4,518 23.75% 4,137 22.96% 3,843 22.98% 

Total Complaints 

Filed 21,945 20,226 19,024 18,017 16,723 
 22 
 23 

III. Findings and Recommendations: Suggestions for Overcoming Impediments to 

the Employment of People with Targeted Disabilities in the Federal Work Force

Section I & II of this report provide an overview of the current employment picture for PWTD. In 

this final section, in addition to the findings, EEOC offers concrete solutions to help improve this 

picture. These solutions are based in part on previously mentioned reports and studies, as well as 

the input of 10 federal agencies, one state agency, and one federal program.18 

OFO interviewed several groups about the declining number of federal employees with targeted 

disabilities. In particular, potential impediments to and best practices for improving the hiring and 

advancement of PWTD in the federal work force were discussed. Reasons for the decline 

included: (1) the increased use of contractors for positions at lower grade levels, which may 

adversely affect PWTD because those positions are eliminated; (2) the reluctance of managers to 

use special hiring authorities, such as Schedule A; and (3) the misperception of managers that 

people with targeted disabilities are not likely to be the best candidates, or to be qualified to 

successfully perform professional jobs within their agency. As well, because the selection process 

often relies heavily on the interview, a manager’s bias may affect how s/he judges the 

qualifications and/or interview skills of a PWTD. Further, PWTD may be discouraged from 

applying for federal jobs where the vacancy announcements are hard to understand, the online 

application process is unnecessarily difficult, or the position requires a security clearance (PWTD 

may not be eligible for a security clearance if they need a job coach or personal assistant). 

It was also noted that federal agencies are not effectively reaching out to and communicating the 

availability of vacancy announcements to PWTD. Similarly, state agencies may not be 

encouraging PWTD to work at all, much less work in the federal government. Finally, it was 

suggested by some that the numbers of PWTD in the federal workforce may, in fact, be greater 

than perceived, because PWTD may be reluctant to self-identify due to fear of harassment or 

discrimination. 

The following section provides findings and recommendations regarding the hiring and 

advancement of PWTD in the federal work force. Recommendation 1 encourages relevant 

agencies to coordinate efforts related to the employment of people with targeted disabilities. 

Recommendations 2-5 address issues related to hiring: combating stereotypes, incorporating 

goals related to PWTD into strategic plans, improving the federal employment application process, 

encouraging people with disabilities to self-identify, and ensuring that disability-related information 

remains confidential. Recommendations 6-7 propose training for hiring officials about special 

hiring authorities and reasonable accommodation. Finally, recommendations 8-10 focus on the 

institutionalization and effectiveness of federal disability programs: enhancing the stature of such 

programs within agencies, ensuring management accountability, and publicly recognizing 

successes. The findings and recommendations may be applicable solely to partner agencies, or 

to all federal agencies. Further, in addition to the recommendations proposed in this report, EEOC 

also adopts the recommendations made in OPM’s Model Federal Agency Plan for the Employment 

of People with Disabilities (August 2004). We also encourage agencies to review the 

 

18 Contributors included: the Department of Defense’s Computer/Electronic Accommodations Program (CAP), 

Executive Office of the President, OPM, National Council of Disability, Department of the Army, Department of 

Education, Department of the Interior, Department of Health and Human Services, Department of Housing and 

Urban Development, Department of Labor’s Office of Civil Rights and Office of Disability Employment Policy 

(ODEP), Department of the Navy, and Virginia’s Department of Rehabilitative Services. 
 24 

recently published National Council on Disability’s (NCD) report entitled Empowerment for 

Americans with Disabilities: Breaking Barriers to Careers and Full Employment (October 1, 2007).

 

1) Improve Coordination Among Partner Agencies

Finding 1: There is a need for improved coordination among federal programs designed to meet 

the employment needs of PWTD. 

Many different agencies play a role in furthering the public policy directive of employing and 

advancing people with disabilities. This includes agencies at the federal, state and local levels. 

However, despite (or perhaps because of) this widespread responsibility, until recently, no one 

agency has taken the lead to promote the employment of PWTD in the federal government.19 

There is a need for improved coordination among federal programs created to meet the 

employment needs of PWTD (partner agencies). See Appendix. The various federal agency 

programs that exist to address employment issues faced by PWTD do not work together efficiently 

or share information about their programs. In fact, agencies with oversight responsibilities for the 

employment of PWTD have not met together as a group since the Interagency Committee on 

Employment of People with Disabilities (ICEPD) disbanded in or about 1995. Better coordination 

among these agencies is vital to transform the program policy into employment results. 

In particular, OPM and EEOC lack clear identities in the disability field. These agencies should 

establish a point of contact to respond to disability-related questions from agencies, PWTD, and 

the public. 

Recommendations for Partner Agencies: 

• Partner agencies should organize a task force to provide a focus for federal employment of 

persons with disabilities and review the adequacy of federal agency hiring, placement, and 

advancement practices with respect to people with disabilities. In particular, the task force 

should consider whether to review the definition of targeted disabilities.20

• Partner agencies should appoint a single coordinator, who will act as point of contact for 

other agencies and the public, and serve as a clearinghouse of information on PWTD in the 

federal government. For example, this official could develop a PWTD guide on applying for 

federal jobs, maintain a disability-related webpage with links to partner agencies, 

disseminate best practices and available training, conduct web forums, schedule brown bag 

lunches, and maintain an e-mail distribution list, including partner agencies, disability 

programs, state vocation rehabilitation services and disability stakeholders. 

• Partner agencies should develop a single online application bank to store resumes for 

PWTD by job category. 

 

19 On June 28, 2007, EEOC launched the Leadership for the Employment of Americans with Disabilities (LEAD) 

Initiative. The goal for this initiative is to significantly increase the population of individuals with severe disabilities 

employed by the federal government. More information on this education and outreach campaign can be found at 

http://www.eeoc.gov/initiatives/lead/index.html. 20 We note that OPM is currently considering changes to its Standard Form (SF) 256 by capturing additional data on 

the types of disabilities, which could be used to expand the types of targeted disabilities. 
 25 

Recommendation for All Agencies: 

• Disability program managers (DPM) and selective placement coordinators (SPC) from all 

agencies should submit the resumes of PWTD to this proposed online application bank.

2) Combat Myths and Stereotypes About Employing PWTD

Finding 2: Myths and stereotypes about people with disabilities persist, presenting a barrier to the 

employment and advancement of PWTD. 

False beliefs, myths, and stereotypes about people with disabilities, including their aptitude for 

employment, persist. These attitudinal barriers within the federal work force present a significant 

obstacle to employment and advancement for PWTD. For example, some officials believe that 

people with disabilities are not as well qualified as those without disabilities. This belief results in 

PWTD not being hired, or causes PWTD to seek entry-level positions, rather than the professional 

career ladder positions for which they are qualified. 

Including issues related to the employment of PWTD in management training will combat myths 

and stereotypes about individuals with disabilities and may prevent disability-related discrimination 

and harassment. According to the Cornell University survey, respondents recognized the value of 

making disability employment a mandatory element of management training. The training was 

identified as the most effective incentive to encourage disability nondiscrimination. 

In addition, officials may also believe that it is more costly to employ people who need reasonable 

accommodations. In fact, many accommodations are cost-free or have a minimal cost.21

Recommendations for Partner Agencies: 

• Partner agencies should collaborate on the development and implementation of a multimedia, interagency campaign to eliminate stereotypes about PWTD. This campaign could 

include information about responsibilities under the Rehabilitation Act and MD-715. 

• Partner agencies should develop a disability-related CD for distribution to federal agencies, 

covering a range of disability topics. 

Recommendations for All Agencies:

• All agencies should make disability training mandatory for all management officials. The 

training should cover hiring goals, special hiring authorities, reasonable accommodation, 

and advancement/retention strategies for PWTD. 

• As is done with other applicants, human resources personnel, together with DPMs and/or 

SPCs, should work carefully to ensure PWTD being considered for employment are 

 

21 After interviewing 1,182 employers between January 2004 and December 2006, the University of Iowa’s Law, Health 

Policy, and Disability Center reported that of the 366 employers who gave cost information related to provided 

accommodations, almost half reported the accommodations cost nothing, and of those with a cost, the average 

expenditure was approximately $500. See Job Accommodation Network, Fact Sheet Series - Workplace 

Accommodations: Low Cost, High Impact (undated). 
 26 

capable of executing the essential functions of the relevant position. Poor placement may 

result in the perpetuation of fears, myths and stereotypes about PWTD. Successful 

employment will demonstrate to managers that PWTD are valuable employees. 

• When considering applicants with disabilities for job vacancies, agencies can minimize bias 

by utilizing an interview panel or different management officials in separate meetings. 

• Leaders at all agencies should work to increase the visibility of accomplishments and 

success stories of PWTD in their work force. See Recommendation 10. 

3) Demonstrate Top-Level Commitment for Employing PWTD 

Finding 3: Many senior leaders have not included PWTD in strategic plans, established hiring 

goals for PWTD, or championed the value of PWTD to their workforce. 

While EEOC’s MD-715 requires analysis and documentation of an agency's accomplishments, the 

directive cannot implement the disability program. Each federal agency must put the necessary 

resources and work into addressing the unique barriers present in their individual workplaces. The 

decline in participation of PWTD in the federal work force may partially be the result of a lack of 

vigorous support among government leaders at all levels. Agency senior leaders need to be the 

champions of PWTD. In particular, agency heads should clearly articulate their support for the 

hiring and advancement of people with disabilities. 

According to some agency officials, many senior leaders have not included PWTD in their strategic 

plans, have not established hiring goals for PWTD, and have not promoted the value of PWTD to 

their work force. In many agencies, the DPM and SPC are not consistently included in strategic 

and succession planning. Including PWTD in strategic plans will enable agencies to address the 

recruitment and retention of individuals with disabilities in an efficient, effective manner. 

As noted in Section II, most agencies (84%) have not established numerical hiring goals for 

PWTD. According to the Cornell University Survey, only 51% of supervisors reported that their 

agency made a “great deal of effort” to achieve affirmative employment goals. This study reported 

that supervisors identified visible top management commitment as one of the most effective 

means of reducing the remaining barriers to employment or advancement of people with 

disabilities. 

Recommendations for All Agencies: 

• All agencies should proactively integrate the hiring and advancement of PWTD into their 

strategic planning. For example, agencies should ensure that the DPM and SPC are 

included in strategic and succession planning meetings. 

• All agencies should issue a policy statement ensuring equal employment opportunity for 

applicants and employees with disabilities. 

• Pursuant to the Rehabilitation Act and MD-715, agencies with 1000 or more employees 

should establish numerical goals for hiring PWTD, and incorporate those goals into the 
 27 

strategic mission of the agency. Those annual goals should exceed the agency’s loss rate 

for PWTD. 

• Agencies should establish an advisory committee that addresses all disability-related 

issues in the agency, including recruitment, hiring, promotion, awards, retention, and 

reasonable accommodation. Agencies could include management officials, union 

representatives, and PWTD on the advisory committee. 

• In accordance with MD-715, agency EEO offices should coordinate with human resources 

offices on recruitment activities to increase the participation of PWTD in the work force. For 

example, types of temporary hiring strategies and appointment authorities include the use 

of Workforce Recruitment Program (WRP); Student Educational Employment Program

(SEEP), Student Career Experience Program (SCEP), and Student Temporary Program

(STEP). Use of these temporary, limited appointments for PWTD will assist PWTD in 

gaining the work experience necessary for future permanent employment. 

• To create greater opportunities for PWTD, agencies should expand vacancy 

announcements to include grade levels below that of the GS-12 journeyman level. 

• Agencies should establish a Job Shadow Program, whereby students with disabilities visit 

the worksite. 

• In addition to the WRP program, agencies should consider using The Washington Center 

for Internships and Academic Seminars, which provides funding for up to 50 students with 

disabilities interested in working in the executive, judicial or legislative branches of the 

federal government during the school year. 

4) Improve the Daunting Application Process for Federal Employment 

Finding 4: The federal application process is daunting for prospective applicants. 

During interviews, all agency officials agreed that the federal application process is daunting. 

Lengthy, vague vacancy announcements, the myriad of online application processes, and the 

interview process all contribute to this conclusion. Agency officials stated that vacancy 

announcements have too much federal jargon, which disadvantages those outside the federal 

government. Announcements are often replete with federal "buzz" words and terms – like “special 

appointing authority” – that mean nothing to the average applicant. 

In addition, the questions designed to test the applicant’s knowledge, skills, and abilities (KSAs) 

may be difficult to understand, and often do not reveal the "essential functions of the position." As 

well, vacancy announcements may read like position descriptions because they are too detailed, 

or do not always accurately reflect what the job entails. The federal application process can also 

be difficult when applying under Schedule A. PWTD are unable to attach their Schedule A 

certification and pertinent documents when applying for a position on-line. 

Additionally, an agency official explained that allowing managers to interview the top three 

candidates of the certification roster serves as a detriment to people with disabilities, who are often 
 28 

not selected for interviews because they are surpassed by veterans and applicants with previous 

federal experience. 

Recommendations for Partner Agencies: 

• Partner agencies should collaborate to develop guidance on how to prepare a federal job 

application for PWTD, including tips on how to use USAJOBS and how to write KSA 

responses. 

• Partner agencies should review the various electronic online application filing systems to 

ensure that they all allow PWTD to submit supplemental documents for Schedule A 

consideration, as appropriate. 

Recommendations for All Agencies: 

• All agencies should ensure that vacancy announcements clearly and simply explain the 

essential functions of open positions. Avoid using federal jargon. See President Clinton’s 

Memorandum for the Heads of Executive Departments and Agencies, Plain Language in 

Government Writing (June 1, 1998) (directing agencies to structure plain language 

documents with a logical organization, easy-to-read design features, and use common, 

everyday words, except for necessary technical terms). 

• All agencies should also ensure that they recruit applicants from a variety of venues, and 

publicize job opportunities widely. To do so, agencies should: develop and maintain 

relationships with organizations that assist PWTD in finding employment; provide vacancy 

announcements to state rehabilitation agencies and disability stakeholder groups; and 

make a special effort to reach out to students with disabilities when recruiting at colleges 

and universities. 

• All agencies and state vocational rehabilitation services should establish a weblink to the 

guidance proposed above, when developed. 

• All agencies should consider instituting a policy requiring that all qualified Schedule A 

applicants be interviewed for open positions, even if they are not among the top three 

qualified applicants. 

• Agencies should conduct workshops on how to write KSA responses specifically for PWTD. 

5) Encourage Persons With Disabilities to Self-Identify and Ensure this Information 

Remains Confidential

Finding 5: Some individuals with disabilities are reluctant to self-identify because they are 

concerned that such disclosure will preclude them from employment or advancement. Individuals 

with disabilities may also be concerned that their disability status will not remain confidential. 

Some individuals with disabilities choose not to disclose their status, perhaps out of concern that 

they will not be hired or that they will otherwise be subjected to discrimination. They may also fear 

that their disability status will not remain confidential. As noted in Section II, the percentage of 
 29 

EEO complaints alleging discrimination against people with disabilities increased from 28.61% in 

FY 2002 to 29.74% in FY 2006, despite the decreasing number of PWTD in the federal work 

force.22 The fact that the percentage of discrimination complaints filed based on disability 

increased during a period in which the number of PWTD in the federal work force decreased may 

indicate that people with disabilities perceive greater discrimination in the federal workplace. As a 

result, persons with disabilities, targeted or otherwise, may be more reluctant to self-identify. 

Recommendations for All Agencies: 

• Agencies should ensure that employees can modify their SF-256/disability status at any 

time. Online access to modify SF-256 forms is ideal. For example, several agencies utilize 

their payroll provider – www.employeeexpress.gov – to allow employees to update their 

personal information at anytime. 

• All agencies should re-survey the work force on a periodic basis. Every two to four years is 

recommended. 

• All agencies should advise employees that information disclosed on the SF-256 regarding 

their disability(ies) is confidential and will only be used for agency-wide work force data 

collection and reporting. Applicants should be similarly advised, when disability status 

information is requested of them. 

6) Provide Managers with Training on Special Hiring Authorities for PWTD 

Finding 6: In general, agencies have under-utilized special hiring authorities for PWTD. 

As noted in Part II, agencies have under-utilized special hiring authorities for PWTD. In particular, 

0.14% of new hires in the federal government in FY 2006 were made using Schedule A. 

Federal appointing authorities, particularly Schedule A, may be under-utilized because agency 

managers and officials, including DPMs and SPCs, may not fully understand the regulations. 

According to the Cornell University Survey, only 56% of the supervisors involved in recruitment 

reported being very familiar or somewhat familiar with the special hiring authorities for the federal 

government. In addition, many agencies do not have procedures in place for receiving and 

disbursing unsolicited applications from PWTD. As a result, these applicants may not be 

considered for employment opportunities. 

At a minimum, DPMs and SPCs should possess: (1) knowledge of laws and regulations related to 

the Rehabilitation Act; (2) knowledge of agency reasonable accommodation policies and 

procedures; (3) the knowledge and ability to recruit and place PWTD, with and without the use of 

special hiring authorities; (4) the ability to work with advocacy groups in the disability community; 

and (5) the ability to develop strategic plans for the recruitment, hiring and advancement of PWTD. 

 

22 Percentages derived from numbers that may include complaints alleging discrimination based on both mental 

and physical disabilities. 
 30 

Recommendation for Partner Agencies: 

• Partner agencies should develop and/or maintain a certification process for SPCs and 

DPMs, requiring continuing education on all disability-related issues. 

Recommendations for All Agencies: 

• All agency heads should issue a memorandum to managers, encouraging them to increase 

the use of Schedule A in filling vacancies. 

• All agencies should train their managers on Schedule A. Agencies should also advise 

managers to contact the agency DPM or SPC prior to announcing vacancies. 

• Agencies should publicize Schedule A on their website and in e-mails to managers. 

• Agencies should consider implementing procedures to determine whether Schedule A was 

used to fill vacancies. 

• Agencies should utilize the performance appraisal process to hold managers accountable 

for their use of special hiring authorities. See Recommendation 9.

7) Provide Managers with Training on Reasonable Accommodations

Finding 7: Many federal supervisors may lack familiarity with accommodations for people with 

disabilities. 

According to the Cornell University Survey of federal supervisors, more than one-third of the 

supervisors surveyed reported being unfamiliar or very unfamiliar with accommodations for 

persons with communication disabilities, such as adapting print materials, accessing sign 

language interpreters, or using a reader, a teletypewriter (TTY), or a relay service. Close to onehalf of the supervisors were not aware of the following accommodation resources: the Job 

Accommodation Network (JAN), the Disability Services Office, disabled employee advisory 

groups, and DPMs or SPCs. The top three areas where supervisors desire more information are 

accommodations for mental illness, the accommodation process generally, and the use of special 

hiring authorities. 

Officials interviewed in conjunction with this report stated that a manager’s lack of knowledge 

about providing reasonable accommodations creates fear about employing PWTD. Moreover, 

some agency officials explained that their managers believe that employing PWTD will incur 

significant costs in both time and money. Despite the availability of advanced technology, agency 

officials reported that there is still a lack of familiarity and comfort in using assistive technology. 

For example, individuals who are deaf still frequently experience difficulty communicating with 

human resources personnel or other agency officials because the officials lack access to, 

knowledge of, or familiarity with the use of TTY, relay, or other services and/or technology 

available for communication. 
 31 

Recommendations for All Agencies: 

• Agencies should provide outreach and training on reasonable accommodations to dispel 

myths about employing people with disabilities. One agency official reported that it 

established an Assistive Technology Center to allow employees to try the technology that is 

available to accommodate various disabilities. 

• Agencies should use DOD’s CAP Program (http://www.tricare.mil/cap/) to alleviate the fears 

of managers about the cost of accommodations. Agencies might also consider establishing 

a link to CAP on their website. 

• All agencies should establish a centralized fund within the agency for providing reasonable 

accommodations that are not covered by CAP. 

• Agencies should implement an Accessibility Data Management System to track facility 

accessibility. 

• Agencies should provide more publicity and information about TTY and other 

communication services to all agency employees, particularly management officials. 

Further, communication services should be available on every phone. 

8) Enhance the Clout of Disability Programs Within Federal Agencies 

Finding 8: In some cases, DPMs are employed at grade levels below that of other special 

emphasis managers and lack access to senior management officials. 

Some agencies have DPMs who are employed at grade levels below that of other special 

emphasis managers with commensurate duties. This disparity suggests that the disability program 

is not as important as other special emphasis programs. Moreover, the reporting structure in 

some agencies may not be conducive to providing the DPM with access to senior management 

officials. 

Recommendations for All Agencies: 

• Agencies should ensure that the DPM has the same title and grade level as other special 

emphasis program managers with commensurate duties. 

• Agencies should ensure that the DPM has access to senior management officials and is 

fully empowered to implement the agency’s program. 

• Agencies should encourage DPMs to attend disability related conferences, such as the 

Deaf and Hard of Hearing in Government’s National Training Conference or the 

Perspectives on Employment of Persons with Disabilities Conference. 
 32 

9) Ensure Accountability

Finding 9: The success or failure of most disability programs is directly related to the degree of 

accountability placed on agency officials and managers. 

While EEOC and other agencies are responsible for enforcing the Rehabilitation Act, all agencies 

must ensure equal employment opportunity for individuals with disabilities in their work force. The 

success or failure of most disability programs can be traced to the degree of accountability placed 

on agency heads and management officials. In this regard, partner agencies should work to hold 

all federal agencies accountable for their performance, and agency heads must hold managers 

accountable for their performance. 

Recommendations for All Agencies: 

• All agencies should develop procedures for ensuring accountability of equal employment 

opportunity for PWTD in their work force by verifying that goals are obtained, establishing 

procedures for follow-up, and conducting enforcement. 

• All agencies should consider distributing monthly reports to senior leaders and 

management, showing what progress, if any, is being made in the hiring and advancement 

of PWTD within their agency. 

• All agency EEO offices should visit with senior leaders to discuss work force profiles of 

PWTD. 

• All agencies should ensure that a diversity element is included in the performance 

standards of senior leaders, making EEO a critical element. 

10) Recognize Success 

Finding 10: There is a need for greater public recognition of practices that successfully increase 

the participation rate of PWTD. 

Although the top five agencies are recognized for their high participation rates of PWTD in EEOC’s 

Annual Reports, partner agencies could improve recognition of agencies that have been innovative 

and/or successful in increasing the participation rate of PWTD in their work force. In addition, 

many agencies have not recognized managers who have successfully hired, advanced, and 

retained PWTD in their work force. 

Recommendation for Partner Agencies: 

• Partner agencies should establish an award for the federal agencies with the best or most 

improved participation rate of PWTD in their work force. 

Recommendation for All Agencies: 

• During annual award ceremonies, all agencies should recognize managers who have 

successfully hired, promoted, or advanced diversity in the agency’s work force. 
 33 

Conclusion 

There are likely several explanations as to why the participation rate of PWTD has steadily 

declined over the years. Current medical and technological advancements afford greater 

opportunities for PWTD to work. Furthermore, the population of working-age individuals with 

targeted disabilities has increased with each passing decade. Nonetheless, the participation 

rate of PWTD in the federal government has steadily declined year after year. Moreover, the 

decline has been much faster than that of the overall federal work force. While the percentage 

of new hires of PWTD has increased over the last five years, that increase did not keep pace 

with the percentage of separations over the same period. 

Government leaders at all levels must embrace the call for the federal government to be a 

model employer for all groups, including PWTD. Agencies must take affirmative steps to 

address the numbers within their workforce. The recommendations set forth in this report 

provide a roadmap to move the federal government toward becoming the employer of first 

choice for PWTD. 
 34 
 35 

Appendix 

Several federal agencies have responsibilities in either enforcing the Rehabilitation Act or acting 

as an advocate for people with disabilities. In addition to the EEOC, some of these agencies 

include: National Council on Disability; Office of Personnel Management; Department of 

Defense’s Computer/Electronic Accommodations Program; Department of Labor’s Office of 

Disability Employment Policy; and states’ Departments of Rehabilitative Services. A brief 

description of each agency’s role is set forth below. 

The National Council on Disability (NCD) 

NCD is an independent federal agency that makes recommendations to the President and 

Congress to enhance the quality of life for all Americans with disabilities and their families. NCD is 

composed of 15 members appointed by the President and confirmed by the U.S. Senate. NCD’s 

overall purpose is to promote policies, programs, practices, and procedures that guarantee equal 

opportunity for all individuals with disabilities, regardless of the nature or severity of the disability; 

and to empower individuals with disabilities to achieve economic self-sufficiency, independent 

living, and inclusion and integration into all aspects of society. 

The Office of Personnel Management (OPM) 

OPM’s mission is to ensure the Federal government has an effective civilian workforce. OPM 

accomplishes its mission by: (1) providing human capital advice and leadership for the President 

of the United States and Federal agencies; (2) delivering human resources policies, products, and 

services; (3) ensuring compliance with merit system principles and protection from prohibited 

personnel practices; and (4) holding agencies accountable for their human capital practices. 

 

The Computer/Electronic Accommodations Program (CAP) 

CAP was established by the Department of Defense in 1990 to eliminate employment barriers for 

its employees with disabilities by providing free assistive technology and services to individuals 

with disabilities to ensure that they have equal access to the information, environment and 

opportunities in the Federal government. In 2001, it was expanded by Congress to serve as the 

government’s centrally funded program. 

The Office of Disability Employment Policy (ODEP) 

ODEP is an agency within the U. S. Department of Labor that strives to increase employment 

opportunities for adults and youth with disabilities and eliminate barriers to employment. ODEP 

develops disability-related employment policies and practices with the ultimate goal of increasing 

the number of people with disabilities who work, either as employees or entrepreneurs, in mind. 

ODEP provides policy analysis, technical assistance, innovative practices and strategies, and 

education and outreach to employers, employees and the disability community. Related to these 

efforts, ODEP also conducts a variety of employment-related programs and initiatives including: 

the Job Accommodation Network (JAN), a free information and referral service regarding job 

accommodations for people with disabilities available to employers and employees; the Employer 

Assistance and Recruiting Network (EARN), which is designed to assist employers in locating and 
 36 

recruiting qualified workers with disabilities; and the Workforce Recruitment Program (WRP) 

coordinated by the Office of Disability Employment Policy and the U.S. Department of Defense. 

WRP aims to provide summer work experience, and in some cases full-time employment, for 

students with disabilities. Students represent all majors, and range from college freshmen to 

graduate students and law students. 

States’ Departments of Rehabilitative Services (DRS) 

States’ Departments of Rehabilitative Services provide recruitment sources for federal and private 

sector employers of pre-screened job candidates with disabilities with ready job skills and support 

necessary for job maintenance and employment retention. Staff includes Placement Counselors, 

Job Coaches, Rehabilitation Engineers, Needs Assessment Specialists, and others. Business 

services provided by DRS include training and outreach: disability awareness and diversity 

training (i.e., Myths and Realities; Hidden Disabilities, etc); accessibility analysis and solutions; 

resume writing; and links to disability network resources.