DISABILITY 

EMPLOYMENT

Further Action 

Needed to Oversee 

Efforts to Meet 

Federal Government 

Hiring Goals

Report to the Chairman, Subcommittee on 

Oversight of Government Management, the 

Federal Workforce, and the District of 

Columbia, Committee on Homeland Security 

and Governmental Affairs, U.S. Senate

May 2012

GAO-12-568

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-568, a report to the 

Chairman, Subcommittee on Oversight of 

Government Management, the Federal 

Workforce, and the District of Columbia, 

Committee on Homeland Security and 

Governmental Affairs, U.S. Senate 

May 2012 

DISABILITY EMPLOYMENT 

Further Action Needed to Oversee Efforts to Meet 

Federal Government Hiring Goals

Why GAO Did This Study

In July 2010, the president signed

Executive Order 13548 committing the 

federal government to become a model 

employer of individuals with disabilities

and assigned primary oversight 

responsibilities to OPM and Labor. 

According to OPM, the federal 

government is not on track to meet the 

goals of the executive order, which

committed the federal government to 

hire 100,000 workers with disabilities 

over the next 5 years. GAO was asked 

to examine the efforts that (1) OPM

and Labor have made in overseeing

federal efforts to implement the

executive order; and (2) selected 

agencies have taken to implement the 

executive order and to adopt leading 

practices for hiring and retaining 

employees with disabilities. To conduct 

this work, GAO reviewed relevant 

agency documents and interviewed 

appropriate agency officials. GAO 

conducted case studies at Education, 

SSA, VA, and OMB.

What GAO Recommends

GAO recommends that OPM: 

(1) incorporate information about plan 

deficiencies into its required regular 

reporting to the president on 

implementing the executive order and 

inform agencies about this process; 

(2) expedite the development of the

mandatory training programs required 

by the executive order; and (3) assess 

the accuracy of the data used to

measure progress toward the 

executive order’s goals and, if needed,

explore options for improving its ability 

to measure the population of federal 

employees with disabilities, including 

strategies for encouraging employees 

to voluntarily disclose disability status. 

OPM agreed with GAO’s 

recommendations.

What GAO Found

The Office of Personnel Management (OPM) and the Department of Labor

(Labor) have taken steps to implement the executive order and help agencies 

recruit, hire, and retain more employees with disabilities. OPM provided guidance 

to help agencies develop disability hiring plans and reviewed the 66 plans

submitted. OPM identified deficiencies in most of the plans. For example, though 

40 of 66 agencies included a process for increasing the use of a special hiring 

authority to increase the hiring of people with disabilities, 59 agencies did not 

meet all of OPM’s review criteria, and 32 agencies had not addressed plan 

deficiencies as of April 2012. In response to executive order reporting 

requirements, OPM officials said they had briefed the White House on issues 

related to implementation, but they did not provide information on deficiencies in 

all plans. While the order does not specify what information these reports should 

include beyond addressing progress, providing information on deficiencies would 

enable the White House to hold agencies accountable. OPM is still developing

the mandatory training programs for officials on the employment of individuals 

with disabilities, as required by the executive order. Several elective training

efforts exist to help agencies hire and retain employees with disabilities, but 

agency officials said that more information would help them better use available

tools. To track and measure progress towards meeting the executive order’s 

goals, OPM relies on employees to voluntarily disclose a disability. Yet, agency 

officials, including OPM’s, are concerned about the quality of the data. For 

example, agency officials noted that people may not disclose their disability due 

to concerns about how the information may be used. Without quality data, 

agencies may be challenged to effectively implement and assess the impact of 

their disability hiring plans. 

The Department of Education (Education), Social Security Administration (SSA), 

Office of Management and Budget (OMB), and Department of Veterans Affairs 

(VA) submitted disability hiring plans, and have taken steps to implement leading 

practices for increasing employment of individuals with disabilities, such as 

demonstrating top leadership commitment. The executive order provided SSA, 

VA, and Education an opportunity to further develop existing written plans.

However, officials at these agencies cited funding constraints as a potential 

obstacle to hiring more employees with disabilities. In terms of leading practices,

all four agencies have communicated their commitment to hiring and retaining 

individuals with disabilities and coordinated within or across other agencies to 

improve their recruitment and retention efforts. For example, each agency has a 

single point of contact to help ensure that employees with disabilities have 

access to information that is comparable to that provided to those without 

disabilities, and for overseeing activities related to hiring and retaining employees 

with disabilities. In addition, VA holds senior managers accountable for meeting 

hiring goals by including targets in their contracts. Each agency requires training 

for managers and supervisors on procedures for hiring individuals with 

disabilities, and VA further requires that all employees receive training on the 

legal rights of individuals with disabilities. Education, SSA, and VA rely on 

View GAO-12-568. For more information, centralized funding accounts to pay for reasonable accommodations. contact Yvonne D. Jones at (202) 512-2717 or 

JonesY@gao.gov; or Daniel Bertoni at (202) 

512-7215 or BertoniD@gao.gov. 
Page i GAO-12-568 Disability Employment 

Letter 1 

Background 3

OPM and Labor Have Taken Steps to Implement the Executive 

Order, but Further Action Is Needed to Meet Hiring Goals 7

Selected Agencies Have Plans in Place to Hire and Retain 

Employees with Disabilities and Have Adopted Many Leading 

Practices 16

Conclusions 23

Recommendations for Executive Action 24

Agency Comments and Our Evaluation 25

Appendix I Comments from the Office of Personnel Management 27

Appendix II GAO Contacts and Staff Acknowledgments 29

Related GAO Products 30

Tables

Table 1: Key Responsibilities of OPM and Labor in Implementing 

the 2010 Executive Order 4

Table 2: Assessment of Selected Agencies’ Initial Plans 17

Figure

Figure 1: Percentage of Agency Plans That Met OPM’s Criteria 

during Initial Review 9

Contents
Page ii GAO-12-568 Disability Employment 

Abbreviations

CHCO Chief Human Capital Officer

EEOC Equal Employment Opportunity Commission

FECA Federal Employees’ Compensation Act

HR Human Resources

MAX MAX Information System

MD-715 Management Directive 715

OMB Office of Management and Budget

OPM Office of Personnel Management

OWCP Office of Workers’ Compensation Programs

POWER Protecting Our Workers and Ensuring Reemployment

SF-256 Standard Form 256, Self-Identification of Disability

SSA Social Security Administration

VA Department of Veterans Affairs

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-12-568 Disability Employment 

United States Government Accountability Office 

Washington, DC 20548

May 25, 2012

The Honorable Daniel K. Akaka

Chairman

Subcommittee on Oversight of Government Management,

 the Federal Workforce, and the District of Columbia

Committee on Homeland Security and Governmental Affairs

United States Senate

Dear Mr. Chairman:

Section 501 of the Rehabilitation Act of 1973, as amended (Rehabilitation 

Act), requires federal agencies to develop affirmative action program 

plans for hiring, placement, and advancement of people with disabilities, 

as well as to ensure employment nondiscrimination and reasonable 

accommodation.1 To encourage the federal government to become a 

model employer of individuals with disabilities through effective 

recruitment, hiring, and retention efforts, Executive Order 13548 was 

issued in July 2010.2

Because of concerns about the federal government’s ability to meet the 

goals set out by Executive Order 13548, you asked us to assess the 

efforts that (1) OPM and the Department of Labor (Labor) have made in 

overseeing the implementation of the executive order across the federal 

government, and (2) selected agencies have taken to implement the 

executive order and to adopt leading practices for hiring and retaining 

This executive order called for increasing the 

number of individuals with disabilities in the federal government through 

the hiring of 100,000 individuals with disabilities over the next 5 years and 

through greater efforts to retain federal workers with disabilities, including 

ensuring the return to work of individuals injured on the job. According to 

draft data from the Office of Personnel Management (OPM), the 

government is not on track to meet the goals of the executive order, 

having hired approximately 20,000 employees with disabilities during 

fiscal years 2010 and 2011; however, as discussed later in this report, we 

were unable to verify these data.

 

1

Section 501 of the Rehabilitation Act of 1973, as amended, is codified at 29 U.S.C. §791. 

2

Exec. Order No. 13548, Increasing Federal Employment of Individuals with Disabilities, 

75 Fed. Reg. 45039 (July 30, 2010). 

 
 

Page 2 GAO-12-568 Disability Employment 

employees with disabilities. To assess OPM and Labor’s oversight efforts, 

we examined relevant documents from OPM and Labor, including OPM’s 

guidance to federal agencies for implementing the executive order, 

agency plans for hiring and employing people with disabilities, and OPM’s 

review of these plans. We also interviewed key agency officials at OPM, 

Labor, and other agencies cited in the executive order such as the Equal 

Employment Opportunity Commission (EEOC) and the Office of 

Management and Budget (OMB).3

We conducted this performance audit from January 2011 to May 2012 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

We also interviewed advocates for 

individuals with disabilities from the American Association of People with 

Disabilities, the National Council on Disabilities, and the National 

Disability Rights Network to obtain their opinions on the executive order. 

To determine how selected agencies are implementing the executive 

order and leading practices, we focused our review on four federal 

agencies: (1) the Department of Education (Education), (2) the Social 

Security Administration (SSA), (3) the Department of Veterans Affairs 

(VA), and (4) OMB. We selected this nongeneralizable sample among 

many agencies within the federal government to provide a cross section 

for review. Education, SSA, and VA have programs with missions and 

goals related to assisting people with disabilities and OMB is specifically 

cited in the executive order. We developed and administered a structured 

questionnaire, and conducted follow-up interviews with agency officials. 

We also reviewed agency specific disability hiring plans and other 

documents related to hiring, reasonable accommodation policies, and 

strategic planning efforts to better understand their experiences with 

hiring and retaining employees with disabilities.

 

3

EEOC has significant responsibilities with regard to overseeing federal agency equal 

employment opportunity laws. As such, EEOC plays a significant role in ensuring that 

federal agencies identify barriers to equal employment opportunity and actions to mitigate 

those barriers for individuals with disabilities. While EEOC was not given any new 

responsibilities in the executive order, it has provided technical assistance and conducted 

training for agencies implementing the executive order.
 

Page 3 GAO-12-568 Disability Employment 

Under the Rehabilitation Act, a person is considered to have a disability if 

the individual has a physical or mental impairment that substantially limits 

one or more major life activities.4 Existing federal efforts are intended to 

promote the employment of individuals with disabilities in the federal 

workforce and help agencies carry out their responsibilities under the 

Rehabilitation Act. For example, federal statutes and regulations provide 

special hiring authorities for people with disabilities. These include 

Schedule A excepted service hiring authority—which permits the 

noncompetitive appointment of qualified individuals with intellectual, 

severe physical, or psychiatric disabilities without posting and publicizing 

the position5

—and appointments and noncompetitive conversion for 

veterans who are 30 percent or more disabled.6 To qualify for a Schedule 

A appointment, an applicant must generally provide proof of disability and 

a certification of job readiness.7

 

4

A person is also considered to have a disability for purposes of the Rehabilitation Act if 

the person has a record of such an impairment or is regarded as having such an 

impairment. 29 U.S.C. § 705(9)(B), § 705(20)(B), and 42 U.S.C. § 12102(1).

Proof of disability can come from a 

number of sources, including a licensed medical professional, or a state 

agency that issues or provides disability benefits. The proof of disability 

document does not need to detail the applicant’s medical history or need 

for an accommodation.

5

5 C.F.R. § 213.3102(u). Under its authority to except positions from competitive 

examination requirements, OPM has established several categories (or schedules) of 

excepted service positions. Schedule A authorizes a number of different excepted service 

appointments for positions that are not of a confidential or policy determining character for 

which it is impractical to use traditional competitive hiring procedures. In addition to the 

specific authority noted above, Schedule A also includes the appointment of attorneys and 

chaplains.

6

5 U.S.C. § 3112 provides authority for the noncompetitive appointment and conversion to 

career employment of disabled veterans with compensable service-connected disabilities 

of 30 percent or more. 

7

OPM has recently proposed eliminating the requirement that an applicant supply a 

certification of job readiness under this authority. Under the proposed regulations, the 

agency determination of job readiness may be based upon any relevant work, 

educational, or other experience. OPM is also proposing a change in terminology in 5 

C.F.R. § 213.3102(u), substituting “intellectual disability” for “mental retardation.” 77 Fed. 

Reg. 6022 (Feb. 7, 2012). We are using the proposed terminology when referring to this 

authority. 

Background
 

Page 4 GAO-12-568 Disability Employment 

Executive Order 13548 committed the federal government to many of the 

goals of an executive order issued a decade earlier,8

Table 1: Key Responsibilities of OPM and Labor in Implementing the 2010 Executive 

Order 

but went further by 

requiring federal agencies to take certain actions. For example, Executive 

Order 13548 requires federal agencies to develop plans for hiring and 

retaining employees with disabilities and to designate a senior-level 

official to be accountable for meeting the goals of the order and to 

develop and implement the agency’s plan. In addition, OPM and Labor 

have oversight responsibilities to ensure the successful implementation of 

the executive order (see table 1).

Responsible 

agency Key responsibilities

OPMa Design model recruitment and hiring strategies for agencies. 

Develop mandatory training programs for human resource officials 

and hiring managers. 

Identify strategies for retaining federal workers with disabilities. 

Assist agencies with the development and implementation of their 

plans. 

Approve agency plans (the executive order provides that agency 

plans are subject to OPM and OMB approval, as appropriate.)

Assist agencies in implementing strategies for retaining federal 

workers with disabilities. 

Implement a system for reporting regularly to the president, heads of 

agencies, and public on agencies’ progress in implementing their 

plans and the executive order’s objectives.

Compile and post on its website governmentwide statistics on the 

hiring of persons with disabilities. 

Review the effectiveness of the definition of targeted disability in the 

Standard Form 256. 

Laborb Pursue innovative reemployment strategies and develop policies, 

procedures, and structures that foster improved return-to-work 

outcomes. 

Pursue overall reform of the Federal Employees’ Compensation Act 

(FECA) system. 

 

8

Exec. Order No. 13163, Increasing the Opportunity for Individuals with Disabilities To Be 

Employed in the Federal Government, 65 Fed. Reg. 46563 (July 26, 2000). According to 

the 2010 executive order, few steps were taken toward implementing the 2000 executive 

order.
 

Page 5 GAO-12-568 Disability Employment 

Responsible 

agency Key responsibilities

Propose specific outcome measures and targets by which each 

agency’s progress in carrying out return-to-work and FECA claims 

processing efforts can be assessed. 

Source: GAO analysis of the 2010 executive order.

a

As noted in the executive order, OPM was directed to consult with the Secretary of Labor, the Chair 

of EEOC, and the Director of OMB in meeting some of its responsibilities. 

b

As noted in the executive order, Labor was to consult with OPM on some of its responsibilities. 

For the purposes of determining agency progress in the employment of 

people with disabilities and setting targeted goals, the federal government 

tracks the number of individuals with disabilities in the workforce through 

OPM’s Standard Form 256, Self-Disclosure of Disability (SF-256). 

Federal employees voluntarily submit this form to disclose that they have 

a disability, as defined by the Rehabilitation Act. For reporting purposes, 

disabilities are separated into two major categories: Targeted and Other 

Disabilities. Targeted disabilities, generally considered to be more severe, 

include such conditions as total deafness, complete paralysis, and 

psychiatric disabilities. Other disabilities include such conditions as partial 

hearing or vision loss, gastrointestinal disorders, and learning disabilities.

Further, Labor is given responsibilities in the executive order to improve 

efforts to help employees who sustain work-related injuries and illnesses 

return to work. In July 2010, the Protecting Our Workers and Ensuring 

Reemployment (POWER) Initiative was established, led by Labor.9

The executive order also requires Labor to pursue reform of the Federal 

Employees’ Compensation Act (FECA) system. FECA provides benefits 

to federal employees who sustain injuries or illnesses while performing 

their federal duties.

This 

initiative aims to improve agency return-to-work outcomes by setting 

performance targets, collecting and analyzing injury and illness data, and 

prioritizing safety and health management programs that have proven 

effective in the past.

10

 

9

Memorandum: The Presidential POWER Initiative: Protecting Our Workers and Ensuring 

Reemployment, 75 Fed. Reg. 43029 (July 22, 2010).

The FECA program covers over 2.7 million civilian 

federal and postal employees in more than 70 agencies, providing wageloss compensation and payments for medical treatment. Labor’s Office of 

105 U.S.C. §8101, et seq. 
 

Page 6 GAO-12-568 Disability Employment 

Workers’ Compensation Programs (OWCP) reviews FECA claims and 

makes decisions on eligibility and payments.11

We have completed a number of reviews that have identified steps that 

agencies could take to provide equal employment opportunity to qualified 

individuals with disabilities in the federal workforce. In July 2010, we held 

a forum that identified barriers to the federal employment of people with 

disabilities and leading practices to overcome these barriers.12

(1) top leadership commitment;

Participants said that the most significant barrier keeping people with 

disabilities from the workplace is attitudinal and identified eight leading 

practices that agencies could implement to help the federal government 

become a model employer:

(2) accountability, including goals to help guide and sustain efforts;

(3) regular surveying of the workforce on disability issues;

(4) better coordination within and across agencies;

(5) training for staff at all levels to disseminate leading practices 

throughout the agency;

(6) career development opportunities inclusive of people with 

disabilities;

(7) a flexible work environment; and

(8) centralized funding at the agency level for reasonable 

accommodations.

 

11Currently, there are two bills in Congress aiming to address FECA reform, one in the 

House of Representatives and one in the U.S. Senate. H.R. 2465, the Federal Workers’ 

Compensation Modernization and Improvement Act, which passed the full House of 

Representatives in November 2011, and S.1789, the 21st Century Postal Service Act of 

2011, which passed the full Senate in April 2012.

12GAO, Highlights of a Forum: Participant-Identified Leading Practices that Could Increase 

the Employment of Individuals with Disabilities in the Federal Workforce, GAO-11-81SP

(Washington, D.C.: Oct. 5, 2010). 
 

Page 7 GAO-12-568 Disability Employment 

OPM, in consultation with EEOC, OMB, and Labor, issued a 

memorandum in November 2010 to heads of executive departments and 

agencies outlining the key requirements of the executive order and what 

elements must be included in agency disability hiring plans. These 

elements include listing the name of the senior-level official to be held 

accountable for meeting the goals of the executive order and describing 

how the agency will hire individuals with disabilities at all grade levels and 

in various job occupations. The memorandum also described strategies 

that agencies could take to become model employers of people with 

disabilities, such as reviewing all recruitment materials to ensure 

accessibility for people with disabilities. To help implement the strategies, 

OPM contracted in December 2010 with a private firm to recruit and to 

manage a list of Schedule A-certified individuals from which federal 

agencies can hire.13

OPM received 66 agency plans for promoting the employment of 

individuals with disabilities, representing over 99 percent of the federal 

civilian executive branch workforce.14

 

13The firm adds an average of 30 to 50 individuals to the list each month, according to 

OPM. OPM includes the resumes of these individuals in a database that federal agencies 

can search using variables such as an individual’s expertise and desired work location.

OPM officials reviewed all the 

14OPM required and received plans from 50 agencies. Other agencies were exempt from 

the requirement to submit a plan because they met certain criteria, such as having fewer 

than 200 employees and not being actively engaged in hiring. Sixteen of these exempted 

agencies submitted plans to OPM for review and the results are included in our analysis. 

Another 4 agencies submitted plans that were excluded from our analysis because they 

are subcomponents of a department or office that also submitted a plan. The 99 percent 

estimate excludes intelligence agencies, the Postal Service, the Tennessee Valley 

Authority, and other agencies for which employment data are unavailable through OPM’s 

online database of statistical information about the federal civilian workforce.

OPM and Labor Have 

Taken Steps to 

Implement the 

Executive Order, but 

Further Action Is 

Needed to Meet 

Hiring Goals

OPM Helped Agencies 

Develop Plans to Employ 

More Individuals with 

Disabilities, Yet Many 

Plans Lacked Required 

Elements and Have Not 

Been Corrected
 

Page 8 GAO-12-568 Disability Employment 

plans, recording whether they met criteria developed by OPM based on 

the executive order and its model strategies memorandum.15

In reviewing the plans, OPM found that many agency plans did not meet 

one or more of its review criteria (see fig. 1). For example, OPM’s review 

found that 29 of the 66 agency plans did not include numerical goals for 

the hiring of people with disabilities. OPM also found that 9 of the 66 

agency plans did not identify a senior-level official responsible for the 

development and implementation of the plan. Finally, only 7 of the 66 

plans met all of the criteria; over half of the plans met 8 or fewer of the 13 

criteria. However, OPM expected agencies to begin implementing their 

plans immediately, regardless of any unaddressed deficiencies.

OPM also 

identified and informed agencies about innovative ideas included in plans.

 

15Labor officials also reviewed agency plans, focusing their review on the FECA 

component, and in particular those 14 agencies with a statistically significant volume of 

serious injury claims, or generally those agencies having an average of 50 or more new 

claims annually. According to the executive order, agency plans were to be developed in 

consultation with and, as appropriate, subject to approval of OPM and OMB. According to 

OMB officials, OPM reviewed the plans and discussed the results of the review with OMB 

officials. 
 

Page 9 GAO-12-568 Disability Employment 

Figure 1: Percentage of Agency Plans That Met OPM’s Criteria during Initial Review

Note: n=66. 

Agencies met some criteria more successfully than others. For example, 

OPM found that 40 of the 66 agency plans included a process for 

increasing the use of Schedule A to increase the hiring of people with 

disabilities. In contrast, 29 of the 66 agency plans provided for the 
 

Page 10 GAO-12-568 Disability Employment 

quarterly monitoring of the rate at which employees injured on the job 

successfully return to work.

OPM provided agencies with written feedback on plan deficiencies and 

strongly encouraged agencies to address them numerous times 

beginning in June 2011. However, 32 out of the 59 agencies with 

deficiencies in their plans had not addressed them as of April 2012. 

Specifically, in June 2011, OPM provided agencies with access to 

reviews of their plans, which identified deficiencies, through OMB’s Max 

Information System (MAX).16

Though the executive order does not specifically authorize OPM to 

require agencies to address plan deficiencies, it calls for OPM to regularly 

report on agencies’ progress in implementing their plans to the White 

House and others. In response to the executive order’s reporting 

requirement, OPM officials told us that they had briefed White House 

officials on issues related to agencies’ implementation of the executive 

order, but did not provide information on the deficiencies in all of the 

agency plans. In addition, OPM does not think that the federal 

government is on target to achieve the goals set in the executive order. 

While the executive order did not provide additional detail as to what 

information should be reported, providing information on the extent to 

which agencies’ plans have met OPM’s criteria would better enable the 

White House to hold agencies accountable for addressing plan 

deficiencies.

According to OPM, in July 2011, a White 

House official told agency senior executives that they were required to 

address deficiencies in their plans. In October and November 2011, OPM 

provided agencies with a list of the deficiencies identified in their plans, 

and asked agencies to determine how their plans could be improved. In 

December 2011, OPM again told agencies they were strongly 

encouraged to review and address plan deficiencies and provided 

agencies with several examples of plans that met all of the criteria.

 

16MAX is a federal online resource used to collect, validate, analyze, model, and publish 

information relating to government-wide management and budgeting activities. It can also 

be used as an information sharing and communication portal between government 

organizations. OPM used MAX to allow agencies to access candidates to the Chief 

Human Capital Officer shared list of people with disabilities and enable agencies to share 

information on disability hiring.
 

Page 11 GAO-12-568 Disability Employment 

In addition to reviewing agency plans, the executive order required OPM 

to develop mandatory training programs on the employment of people 

with disabilities for both human resources personnel and hiring managers, 

within 60 days of the executive order date. We have previously reported 

that training at all staff levels, in particular training on hiring, reasonable 

accommodations, and diversity awareness, can help disseminate leading 

practices throughout an agency and communicate expectations for 

implementation of policies and procedures related to improving 

employment of people with disabilities.17 Such policies and procedures 

could be communicated across the federal government with training on 

topics such as how to access and efficiently use the list of Schedule Acertified individuals, the availability of internships and fellowships, such as 

Labor’s Workforce Recruitment Program, and online communities of 

practice established to help officials share best practices on hiring people 

with disabilities, such as eFedlink.18

In its November 2010 model strategies memorandum to heads of 

executive agencies, OPM stated that, in consultation with Labor, EEOC, 

and OMB, it was developing the mandatory training programs required by 

the executive order and that further information would be forthcoming. 

OPM officials told us in March 2012 that they are working with federal 

Chief Human Capital Officers (CHCO) to develop modules on topics such 

as using special hiring authority that will be available through HR 

University.19

 

17

Officials explained that they need to ensure that the training 

is uniform to ensure all personnel receive consistent information, and they 

expect the training modules to be ready by August 2012.

GAO-11-81SP. 

18The Workforce Recruitment Program connects agencies with college students and 

recent graduates with disabilities who wish to prove their abilities in the workplace through 

summer or permanent jobs. eFedlink is managed by the National Technical Assistance, 

Policy, and Research Center for Employers on Employment of People with Disabilities at 

Cornell University funded by Labor’s Office of Disability Employment Policy. According to 

eFedlink, it is designed to support federal managers and human resource personnel to 

advance the hiring and advancement of persons with disabilities in the federal 

government. 

19HR University, the federal government’s one-stop human resources career development 

center, is designed to address competency and skill gaps within the human resources 

community. 

OPM Has Yet to Fully 

Develop the Required 

Mandatory Training 

Programs 
 

Page 12 GAO-12-568 Disability Employment 

Although it has yet to fully develop mandatory training programs, OPM 

has taken steps to train and inform federal officials about tools available 

to them. For example, OPM partnered with Labor, EEOC, and other 

agencies to provide elective training courses for federal officials involved

in implementing the executive order on topics including: the executive 

order, model recruitment strategies, guidance on developing disability 

hiring plans, and return-to-work strategies.20

Nevertheless, agency officials we interviewed told us that they would like 

to have more comprehensive training on strategies for hiring and retaining 

individuals with disabilities, confirming the need for OPM to complete the 

development of the training programs required by the executive order. For 

example, officials from one agency said that more training on the 

relationship between return-to-work efforts and providing reasonable 

accommodations is needed, while officials from another agency identified 

a need for increased awareness of the Schedule A hiring process.

OPM also conducted training 

on implementation of the executive order in July 2011 specifically for 

senior executives accountable for their agencies’ plans. It also offers 

short online videos for hiring managers on topics such as Schedule A 

hiring authority. Further, other governmentwide training on employing 

people with disabilities exists. For example, Labor’s Job Accommodation 

Network offers online training on relevant issues like applying the 

Americans with Disabilities Amendments Act and providing reasonable 

accommodations. Moreover, the Department of Defense’s 

Computer/Electronic Accommodations Program offers online training 

modules to help federal employees understand the benefits of hiring 

people with disabilities.

21

Executive Order 13548 requires OPM to implement a system for reporting 

regularly to the president, heads of agencies, and the public on agencies’ 

progress in implementing the objectives of the executive order. OPM is 

also to compile, and post on its website, governmentwide statistics on the 

hiring of individuals with disabilities. This is important because effectively 

 

20The national training is offered through the Federal Executive Boards, which are a forum 

for communication and collaboration among federal agencies outside of Washington, D.C.

21OPM and EEOC have also concluded that agencies are not using Schedule A to its 

fullest extent. According to OPM, in fiscal year 2011, 1,093, or less than 1 percent, of all 

new full-time, permanent hires and transfers, were appointed under Schedule A.

OPM Tracks the Hiring of 

People with Disabilities, 

but Concerns about Data 

Quality Exist
 

Page 13 GAO-12-568 Disability Employment 

measuring workforce demographics requires reliable data to inform 

decisions and to allow for individual and agencywide accountability.

To measure and assess their progress towards achieving the goals of the 

executive order, agencies and OPM use data about disability status that 

employees voluntarily self-report on the SF-256.22 OPM’s guidance to 

agencies for implementing the executive order explained that the data 

gathered from the SF-256 is crucial for agencies to determine whether 

they are achieving their disability hiring goals. Agencies also report these 

data to EEOC in an effort to identify and develop strategies to eliminate 

potential barriers to equal employment opportunities.23 According to the 

form, the data are used to develop reports to bring to light agency specific 

or governmentwide deficiencies in the hiring, placement, and 

advancement of individuals with disabilities. The information is 

confidential and cannot be used to affect an employee in any way. Only 

staff who record the data in an agency’s or OPM’s personnel systems 

have access to the information. According to draft data from OPM, as 

stated earlier, the government hired approximately 20,000 employees 

with disabilities during fiscal years 2010 and 2011.24

However, according to officials at OPM, EEOC, VA, Education, and SSA, 

accurately measuring the number of current and newly hired employees 

with disabilities is an ongoing challenge. While the accuracy of the SF256 data is unknown, agency officials and advocates for people with 

disabilities believe there is an undercount of employees with disabilities. 

For example, despite the safeguards in place explaining the 

confidentiality of the data, agency officials and advocates for people with 

disabilities told us that some individuals with disabilities may not disclose 

 

22Standard Form 256, Self-Identification of Disability. The executive order states that it 

“shall not be construed to require any federal employee to disclose disability status 

involuntarily.” 

23EEOC’s Management Directive 715 (MD-715) provides policy guidance and standards 

for establishing and maintaining effective affirmative programs of equal employment 

opportunity under section 717 of Title VII of the Civil Rights Act of 1964 as amended, and 

effective affirmative action programs under section 501 of the Rehabilitation Act of 1973, 

as amended. See, 42 U.S.C. § 2000e-16 and 29 U.S.C. § 791. The MD-715 includes a 

framework for agencies to determine whether barriers to equal employment opportunities 

exist and to identify and develop strategies to eliminate the barriers to participation. Under 

MD-715, EEOC requires agencies to report the results of their analyses annually. 

24We were not able to independently verify these data. 
 

Page 14 GAO-12-568 Disability Employment 

their disability status out of concern that they will be subjected to 

discrimination. Similarly, EEOC reported that some persons with 

disabilities are reluctant to self-identify because they are concerned that 

such disclosure will preclude them from advancement.25

Additionally, some individuals may develop disabilities during federal 

employment and may not know how to or why they should update their 

disability status. We have reported that regularly encouraging employees 

to update their disability status allows agencies to be aware of any 

changes in their workforce. EEOC guidance recommends that agencies 

request that employees update their disability status every 2 to 4 years.26

During the course of our review, we heard about potentially useful options 

for improving the accuracy of these data by attempting to increase 

voluntary disclosure, as well as alternative sources of information that 

may be used to augment the data provided on the SF-256. For example, 

in its disability hiring plan, Labor described plans to increase the accuracy 

of its workforce data by implementing a marketing campaign to promote 

the voluntary disclosure of one’s disability status by having employees 

update their personnel profiles, including disability status. Labor plans to 

assure employees of the confidentiality of the information, and inform 

them that the information collected on the SF-256 will only be used for 

statistical purposes and to determine progress in achieving agency hiring 

and retention goals. As a source of alternative data, officials at SSA 

suggested examining the types of reasonable accommodations provided. 

Likewise, OPM is exploring options for using other federal personnel data, 

such as information on veterans with disabilities hired under a special 

hiring authority, to supplement its SF-256 data in measuring progress 

toward the executive order’s goals.27

 

25See EEOC, Improving the Participation Rate of People with Targeted Disabilities in the 

Federal Work Force (Washington, D.C.: January 2008).

These data could be used to better 

understand the makeup of an agency’s workforce and improve the 

26Many federal agencies use different automated systems for employees to update their 

own personal information, including disability status. For example, HR Connect and the 

National Finance Center’s Employee Personal Page are both automated systems used 

across the federal government. 

27As previously noted, disabled veterans with a compensable service-connected disability 

of 30 percent or more may be noncompetitively appointed and converted to a career 

appointment under 5 U.S.C. § 3112. 
 

Page 15 GAO-12-568 Disability Employment 

agency’s ability to establish appropriate policies and goals, and assess 

progress towards those goals.

Labor has taken several steps toward meeting the requirements of the 

executive order to improve return-to-work outcomes for employees 

injured on the job, including pursuing overall reform of the FECA system. 

Specifically, Labor developed new measures and targets to hold federal 

agencies accountable for improving their return-to-work outcomes within 

a 2-year period. Agencies were expected to improve return-to-work 

outcomes by 1 percent for fiscal year 2011 and an additional 2 percent in 

each of the following 3 years over the 2009 baseline. In fiscal year 2011, 

the federal government had a cumulative return-to-work rate of 91.6 

percent, almost 5 percent better than the target rate of 86.7 percent. 

Goals such as these are useful tools to help agencies improve 

performance. Labor is also researching strategies that agencies can use 

to increase the successful return-to-work of employees who have 

sustained disabilities as a result of workplace injuries or illnesses.28

Another Labor initiative is aimed at helping the federal government rehire 

injured federal workers who are not able to return to the job at which they 

were injured. OWCP initiated a 6-month pilot project in May 2011 to 

explore how Schedule A noncompetitive hiring authority might be used to 

rehire injured federal workers under FECA. As part of the project, OWCP 

provided guidance to claims staff, rehabilitation specialists, rehabilitation 

counselors, and employing agencies on the process of Schedule A 

certification and the steps it will take to facilitate Schedule A placements. 

According to Labor, the pilot identified obstacles to reemployment and 

provided input needed to determine whether such an effort can be 

expanded to other federal agencies. Identified obstacles included 

unanticipated questions from potential workers, such as if acceptance of 

a Schedule A designation would require a “probationary” period, and what 

impact acceptance of a Schedule A position would have on their 

The 

results of this study are expected to be released in September 2012.

 

28According to Labor, the vast majority of workers either incur no time lost from work or 

return to work during the first 45 days of injury. Of the approximately 20,000 new cases 

each year where workers lose wages, approximately 90 percent either return to work or 

the cases are resolved through other means. In fiscal year 2011, 2,000 FECA cases 

pertained to workers who did not return to work. Such cases provide the best opportunity 

to improve return-to-work outcomes for federal workers who may have become disabled 

through their work. 

Labor Has Taken Steps to 

Develop Return-to-Work 

Strategies
 

Page 16 GAO-12-568 Disability Employment 

retirement benefits. Of the 48 individuals Labor screened for Schedule A 

certification, 45 obtained certification, of whom 5 have been placed into 

federal employment.

Each of the four agencies we reviewed submitted a plan for implementing 

the executive order as required. Only VA’s plan, as initially submitted, met 

all of OPM’s criteria for satisfying the requirements of the executive order 

(see table 2). Education and SSA revised their plans based on feedback 

from OPM. Specifically, Education’s revised plan states that Education 

will hire individuals with disabilities in all occupations and across all job 

series and grades. Education also clarified its commitment to coordinate 

with Labor to improve return-to-work outcomes through the POWER 

Initiative, and to engage and train managers on Schedule A hiring 

authority. Further, Education increased its goals for the percentage of job 

opportunity announcements that include information related to individuals 

with disabilities. SSA revised its plan to include goals and planned 

activities under the POWER Initiative, including quarterly monitoring of 

return-to-work successes under the program and a strategy for identifying 

injured employees who would benefit from reasonable accommodations 

and reassignment. OMB submitted its plan in March 2012 but, according 

to OMB officials, the agency has not received feedback from OPM.

Selected Agencies 

Have Plans in Place to 

Hire and Retain 

Employees with 

Disabilities and Have 

Adopted Many 

Leading Practices

Agencies Are 

Implementing Plans to 

Improve Hiring and 

Retention of Employees 

with Disabilities
 

Page 17 GAO-12-568 Disability Employment 

Table 2: Assessment of Selected Agencies’ Initial Plans 

Criteria ED OMBa SSA VA

Identifies a senior executive who is accountable for 

implementation.

 c  

Provides evidence of senior executive review.   

Includes hiring goals.   

Accounts for hiring people with disabilities at all grade 

levels.

b  

Accounts for hiring people with disabilities in all job 

series. 

b  

Identifies training necessary to advance and/or 

implement plan.

 c  

Includes plan for providing and assessing 

effectiveness of training.

 

Includes plan to increase return-to-work outcomes to 

make accommodations available to injured employees 

who sustain serious workplace injuries and illnesses.

b c  

Includes a plan to coordinate with OWCP to make 

accommodations available to injured federal 

employees.

b c  

Provides for quarterly monitoring of return-to-work 

successes under the POWER Initiative.

b c b 

Includes plan for identifying injured employees, as 

defined under FECA, who would benefit from 

accommodations and reassignment.

b c b 

Has a process for increasing the use of Schedule A as 

a means to increase hiring of people with 

disabilities/targeted disabilities.

b c  

Addresses the agency’s reasonable accommodation 

policy and procedures and whether they have been 

updated.

 

Source: GAO analysis of OPM data.

a

OMB submitted its own disability hiring plan to OPM, but has not received feedback on it. 

b

The agency has addressed this issue in a revised plan. 

c

OPM determined that this criterion had been met in the Executive Office of the President’s disability 

hiring plan. 

Agencies had positive views about the executive order’s requirement that 

they develop written plans to increase the number of federal employees 

with disabilities. In particular, Education, SSA, and VA said that the 

executive order provided an opportunity to further develop the written 

plans they already had in place for hiring and retaining employees with 

disabilities.
 

Page 18 GAO-12-568 Disability Employment 

Agencies were supportive of the goal of increasing the hiring and 

retention of federal employees with disabilities, and reported few 

challenges in implementing their plans to achieve this goal. Officials at all 

of the agencies we interviewed cited funding constraints as a potential 

obstacle to hiring more employees with disabilities. OMB officials also 

said that it was a challenge to identify individuals with the right skills and 

experience to fill their positions. For example, officials said that many of 

the candidates on OPM’s list of Schedule A-certified individuals have 

entry level skills and not the more advanced skills and experience that are 

required for positions at OMB.29 Agency officials cited no special 

challenges with respect to retaining employees with disabilities at their 

agencies.

In October 2010, we reported on eight leading practices that could help 

the federal government become a model employer for individuals with 

disabilities.30

Top leadership commitment: Involvement of top agency leadership is 

necessary to overcome the resistance to change that agencies could face 

when trying to address attitudinal barriers to hiring individuals with 

disabilities. When leaders communicate their commitment throughout the 

organization, they send a clear message about the seriousness and 

business relevance of diversity management. Leaders at the agencies we 

talked with have, to varying degrees, communicated their commitment to 

hiring and retaining individuals with disabilities to their employees. 

Education has issued annual policy statements to its employees ensuring 

equal employment opportunity for all applicants and employees, including 

those with targeted disabilities, and officials told us that they routinely 

host events that address issues related to hiring and promoting equal 

employment opportunity. For example, in October 2008, Education 

hosted an event to encourage hiring individuals with disabilities and 

These practices, which are consistent with the executive 

order’s goal of increasing the number of individuals with disabilities in the 

federal government, have been implemented to varying degrees by the 

four agencies we contacted for this review.

 

29According to OPM officials, when the agreement was developed, the CHCO Council 

requested that Bender Consulting identify individuals for entry-level positions. The list has 

since expanded to include individuals with a range of experience.

30GAO-11-81SP. 

Agencies Have Taken 

Steps to Implement 

Leading Practices for 

Increasing Employment of 

Individuals with 

Disabilities
 

Page 19 GAO-12-568 Disability Employment 

distributed a written guide about using Schedule A hiring authority to 

facilitate hiring individuals with targeted or severe disabilities, as well as 

disabled veterans. OMB officials said that it is briefing managers on the

requirements of the executive order and that it planned to communicate 

the agency’s commitment to implementing the executive order to all staff 

in May 2012. SSA’s Commissioner announced his support for employing 

individuals with disabilities and encouraged employees to continue efforts 

to hire and promote these individuals in a March 2009 broadcast to all 

employees. VA said that the Secretary regularly communicates his 

commitment to hiring and retaining employees with disabilities through 

memorandums to all employees. In a September 2010 memorandum, the 

Secretary announced the agency’s goal of increasing the percentage of 

individuals with targeted disabilities that it hires and employs to 2 percent 

in fiscal year 2011.31

Accountability: Accountability is critical to ensuring the success of an 

agency’s efforts to implement leading practices and improve the 

employment of individuals with disabilities. To ensure accountability, 

agencies should set goals, determine measures to assess progress 

toward goals, evaluate staff and agency success in helping meet goals, 

and report results publicly. Education, SSA and VA’s disability hiring 

plans all include goals that will allow them to measure their progress 

toward meeting the goals of the executive order. Prior to the executive 

order, Education issued a Disability Employment Program Strategic Plan 

for fiscal years 2011-2013 that established goals related to reasonable 

accommodations, and recruitment and retention, and offered strategies 

for meeting these goals, as well as ways to track and measure agency 

progress. At SSA, accountability for results related to the executive order 

is included in the performance plan of the senior-level official responsible 

for implementing it. VA specifically holds senior executives accountable 

for meeting agency numerical goals by including these goals in their 

contracts. Additionally, VA senior executives’ contracts include a 

performance element for meeting hiring goals for individuals with targeted 

disabilities. OMB has not yet developed such goals.

Regular surveying of the workforce on disability issues: Regularly 

surveying their workforces allows agencies to have more information 

 

31As previously noted, targeted disabilities include deafness, blindness, partial and total 

paralysis, missing limbs, distorted limbs or spine, mental disabilities, and convulsive 

disorders.
 

Page 20 GAO-12-568 Disability Employment 

about potential barriers to employment for people with disabilities, the 

effectiveness of their reasonable accommodation practices, and the 

extent to which employees with disabilities find the work environment 

friendly. To collect this information, agencies should survey their 

workforces at all stages of their employment, including asking employees 

to complete the SF-256 when they are hired, and asking relevant 

questions on employee feedback surveys and in exit interviews. VA 

officials said that they encourage new employees to complete the SF256, and SSA reminds all employees to annually review their human 

resource records and update or correct information, including disability 

data. In addition, all of the agencies we contacted survey employees to 

solicit feedback on a range of topics. However, only SSA and VA include 

a question on disability status or reasonable accommodations on these 

surveys. In addition, Education and SSA said that they routinely conduct 

exit surveys to solicit information from employees who separate from 

service about their reasons for leaving. While VA has an exit survey, 

officials said it is not consistently administered to all employees who 

separate. Education officials said that they have additional means of 

obtaining information about barriers for employees with disabilities. For 

example, senior managers hold open forums with staff, and employees 

can submit feedback to management through the agency’s Intranet. 

Education officials also reported that employees with disabilities have 

formed their own group to address access to assistive technology, which 

has helped Education to obtain improved technology, such as 

videophones. OMB officials said that their Diversity Council and 

Personnel Advisory Board provide forums for employees to discuss 

diversity issues, including those related to disabilities, and share them 

with senior leadership.

Better coordination of roles and responsibilities: Often the 

responsibilities related to employment of people with disabilities are 

dispersed, which can create barriers to hiring if agency staff defer taking 

action, thinking that it is someone else’s responsibility.32

 

32See 

Coordination 

across agencies can encourage agencies with special expertise in 

addressing employment obstacles for individuals with disabilities to share 

their knowledge with agencies that have not yet developed this expertise. 

All of the agencies we interviewed had, to some extent, coordinated 

within and across agencies to improve their recruitment and retention 

GAO-11-81SP, p. 13.
 

Page 21 GAO-12-568 Disability Employment 

efforts. Specifically, each agency has a designated section 508 

coordinator who assists the agency in ensuring that, as required by 

section 508 of the Rehabilitation Act, employees with disabilities have 

access to information and data that are comparable to that provided to 

those without disabilities.33

Officials at all of the agencies we talked to said their agencies engaged in 

one or more interagency efforts to address disability issues. All of these 

agencies participate in the CHCO Council, which facilitates sharing of 

best practices and challenges related to human capital issues, including 

those related to employees with disabilities. In addition, Education, OMB 

and SSA officials said that they work with state vocational rehabilitation 

agencies, which can help them identify accommodations that may be 

needed for new hires with disabilities. Education and SSA also participate 

in the Federal Disability Workforce Consortium, an interagency 

partnership working to improve recruitment, hiring, retention, and 

advancement of individuals with disabilities by sharing information on 

disability employment issues across government. SSA and VA have also 

participated in the Workforce Recruitment Program for College Students 

with Disabilities;

In addition, each agency has a single office or 

primary point of contact that is responsible for overseeing activities 

related to hiring and retaining employees with disabilities.

34

OPM encourages agencies to coordinate their efforts by sharing 

information in its online workspace in the MAX system. For example, 

Education, SSA, and VA used MAX to submit and receive OPM’s 

feedback on their disability hiring plans, and all four agencies have used 

the system to access OPM’s list of Schedule A-certified individuals from 

which federal agencies can hire. However, only Education reported using 

the online workspace to share other information that could facilitate 

implementation of the executive order. Specifically, Education officials 

VA and Education have also worked together to assist 

disabled veterans by providing unpaid work experience at Education, 

which may lead to permanent employment.

 

3329 U.S.C. § 794d.

34Managed by Labor’s Office of Disability Employment Policy and the Department of 

Defense’s Office of Diversity Management and Equal Opportunity, this program is a 

recruitment and referral effort that connects federal sector employers nationwide with 

highly motivated college students and recent graduates with disabilities.
 

Page 22 GAO-12-568 Disability Employment 

said that the site is useful for seeing what other agencies are doing, and 

that they have also shared their own practices on the site.

Training for staff at all levels: Agencies can leverage training to 

communicate expectations about implementation of policies and 

procedures related to improving employment of people with disabilities, 

and help disseminate leading practices that can help improve outcomes. 

All of the selected agencies provide some training for staff at all levels on 

the importance of workforce diversity. They also require managers and

supervisors to take training on hiring procedures related to individuals 

with disabilities, and the use of Schedule A hiring authority. In addition, 

VA requires employees at all levels to take training specifically devoted to 

the legal rights of individuals with disabilities. At Education, this training is 

required for managers and supervisors, while at SSA it is available but 

optional for all employees.35

Career development opportunities: Opportunities for employees with 

disabilities to participate in work details, rotational assignments, and 

mentoring programs can lead to increased retention and improved 

employee satisfaction, and improve employment outcomes by helping 

managers identify employees with high potential. All of the agencies we 

interviewed provided special work details or rotational assignments for all 

employees; one reported having a program exclusively for those with 

disabilities. Specifically, Education uses Project SEARCH to provide 

internships for students with disabilities to help them become ready to 

work through on-the-job training. Education officials reported that some of 

these internships have led to permanent employment at Education.

A flexible work environment: Flexible work schedules, telework, and 

other types of reasonable accommodations are valuable tools for the 

recruitment and retention of employees, regardless of disability status. 

Such arrangements can make it easier for employees with health 

impairments to successfully function in the work environment or facilitate 

an injured employee’s return to work. All of the agencies we interviewed 

provide flexible work arrangements, including flexible work schedules and 

 

35Under the Notification and Federal Employee Antidiscrimination and Retaliation Act of 

2002 (No Fear Act), agencies are required, among other things, to provide their 

employees with training regarding the rights and remedies afforded to them under federal 

antidiscrimination and whistleblower protection laws. Pub. L. No. 107-174, 116 Stat. 566 

(May 15, 2002). 
 

Page 23 GAO-12-568 Disability Employment 

teleworking. These agencies also make assistive technologies, such as 

screen reader software, available for employees with disabilities, which 

can facilitate their ability to take advantage of flexible work arrangements. 

Education, OMB, and SSA also offer all employees opportunities for job 

sharing.

Centralized funding for reasonable accommodations: Having a 

central budget at the highest level of the agency can help ensure that 

employees with disabilities have access to reasonable accommodations 

by removing these expenses from local operational budgets and thus 

reducing managers’ concerns about their costs. Education, SSA, and VA 

use centralized funding accounts to pay for reasonable accommodations 

for employees with disabilities. At Education, a centralized fund is usually 

used to cover expenses related to providing readers, interpreters, and 

personal attendants. However, in cases where these services are needed 

on a daily basis, Education may require the operating unit to hire 

someone full-time and pay for this from their unit budget. OMB provides 

funding from its own budget to pay for reasonable accommodations, 

rather than receiving funding from the Executive Office of the President. 

OMB officials also told us that they also have been able to rely on the 

Department of Defense’s Computer/Electronic Accommodations Program 

to help provide reasonable accommodations for some of the employees. 

This program facilitates access to assistive technology and services to 

people with disabilities, federal managers, supervisors, and information 

technology professionals by providing a single point of access for 

executive branch agencies.

As the nation’s largest employer, the federal government has the 

opportunity to be a model for the employment of people with disabilities. 

Consistent with the July 2010 executive order, OPM, Labor, and other 

agencies have helped provide the framework for federal agencies to take 

proactive steps to improve the hiring and retention of persons with 

disabilities.

However, nearly 2 years after the executive order was signed, the federal 

government is not on track to achieve the executive order’s goals. 

Although federal agencies have taken the first step by submitting action 

plans to OPM for review, many agency plans do not meet the criteria 

identified by OPM as essential to becoming a model employer of people 

with disabilities. Though the executive order does not specifically 

authorize OPM to require agencies to address deficiencies, regularly 

reporting to the president and others on agency progress in addressing 

Conclusions
 

Page 24 GAO-12-568 Disability Employment 

these deficiencies may compel agencies to address them and better 

position the federal government to reach the goals of the executive order.

Further, officials responsible for hiring at federal agencies need to acquire 

the necessary knowledge and skills to proactively recruit, hire, and retain 

individuals with disabilities. Agency officials we spoke with said more 

comprehensive training on the tools available to them, including the 

requirements of Schedule A hiring authority, is needed. While the 

mandatory training program remains in development, until it is fully 

developed and communicated to agencies, opportunities to better inform 

relevant agency officials on how to increase the employment of 

individuals with disabilities may be missed.

Finally, concerns have been raised by stakeholders, including EEOC, 

OPM, and advocates for people with disabilities, about the reliability of 

government statistics on the number of individuals with disabilities in the 

federal government. Most of the concerns focus on the likelihood of 

underreporting given the reliance on voluntary disclosure, but the extent 

of the underreporting is unknown. Unreliable data hinder OPM’s ability to 

measure the population of federal workers with disabilities and may 

prevent the federal government from developing needed policies and 

procedures that support efforts to become a model employer of people 

with disabilities. Determining the accuracy of SF-256 data, for example, 

by examining the extent to which employees voluntarily disclose their 

disability status and reasons for nondisclosure, is an essential step for 

ensuring that OPM can measure progress towards the executive order’s 

goals.

To ensure that the federal government is well positioned to become a 

model employer of individuals with disabilities, we recommend that the 

Director of OPM take the following three actions: 

1. Incorporate information about plan deficiencies into its regular 

reporting to the president on agencies’ progress in implementing their 

plans, and inform agencies about this process to better ensure that 

the plan deficiencies are addressed.

2. Expedite the development of the mandatory training programs for 

hiring managers and human resource personnel on the employment 

of individuals with disabilities, as required by the executive order.

3. Assess the extent to which the SF-256 accurately measures progress 

toward the executive order’s goal and explore options for improving 

the accuracy of SF-256 reporting, if needed, including strategies for 

Recommendations for 

Executive Action
 

Page 25 GAO-12-568 Disability Employment 

encouraging employees to voluntarily disclose their disability status. 

Any such strategies must comply with legal standards governing 

disability-related inquiries, including ensuring that employee rights to 

voluntarily disclose a disability are not infringed upon.

We provided a draft of this report to Education, EEOC, Labor, OMB, 

OPM, SSA, and VA for review and comment. In written comments, OPM 

agreed with findings and recommendations identified in the report, and 

described actions being implemented in an effort to address them. To 

better ensure agencies address deficiencies identified in their disability 

hiring plans, OPM has begun notifying agencies that it plans to report 

remaining deficiencies to the president and on the OPM website by 

August 2012. With regard to the need to expedite the development of the 

mandatory training program, OPM, in coordination with partner agencies 

has identified training for hiring managers and supervisors, and Human 

Resource personnel. Finally, OPM stated that it is engaged in discussions 

with the White House and stakeholder agencies to better define questions 

on the SF-256 to increase response rates. OPM also said it plans to work 

with EEOC and Labor to develop guidance for agencies to encourage 

voluntary self-disclosure through annual re-surveying of the workforce 

and providing employees with the option to complete the SF-256 when 

they request a reasonable accommodation. OPM expects to complete 

these efforts by January 2013. While these actions may help improve the 

accuracy of the SF-256 data, we think taking steps to assess the 

accuracy of the data will enhance OPM’s efforts. For example, 

understanding the extent to which employees do not voluntarily selfdisclose their disability status and the reasons why may help target the 

messages agencies can use to encourage voluntary self-disclosure. 

Without such an understanding, OPM and agencies may miss 

opportunities to increase the accuracy of the data collected on the SF256.

Education, EEOC, OMB, OPM, and SSA provided technical comments, 

which have been incorporated into the report as appropriate. Labor and 

VA had no comments.

Agency Comments 

and Our Evaluation
 

Page 26 GAO-12-568 Disability Employment 

We are sending copies of this report to Education, EEOC, Labor, OMB, 

OPM, SSA, and VA and to the appropriate congressional committees and 

other interested parties. In addition, the report will be available at no

charge on GAO’s website at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

Yvonne Jones at (202) 512-2717 or JonesY@gao.gov, or Daniel Bertoni 

at (202) 512-7215 or BertoniD@gao.gov. Contact information for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. Key contributors to this report are listed in 

appendix II.

Sincerely yours,

Yvonne D. Jones, Director 

Strategic Issues

Daniel Bertoni, Director

Education, Workforce, and

Income Security Issues 
Appendix I: Comments from the Office of 

Personnel Management

Page 27 GAO-12-568 Disability Employment 

Appendix I: Comments from the Office of 

Personnel Management
Appendix I: Comments from the Office of 

Personnel Management

Page 28 GAO-12-568 Disability Employment 
Appendix II: GAO Contacts and Staff 

Acknowledgments

Page 29 GAO-12-568 Disability Employment 

Daniel Bertoni, (202) 512-7215, bertonid@gao.gov. 

Yvonne D. Jones, (202) 512-2717, jonesy@gao.gov. 

In addition to the contacts named above, Neil Pinney, Assistant Director; 

Debra Prescott, Assistant Director; Charlesetta Bailey; Benjamin 

Crawford; Catherine Croake; Karin Fangman; David Forgosh; Robert 

Gebhart; Michele Grgich; Amy Radovich; Terry Richardson; and Regina 

Santucci made key contributions to this report.

Appendix II: GAO Contacts and Staff 

Acknowledgments 

Contacts

Acknowledgments
Related GAO Products

Page 30 GAO-12-568 Disability Employment 

Federal Employees’ Compensation Act: Preliminary Observations on 

Fraud-Prevention Controls. GAO-12-402. Washington, D.C.: January 25, 

2012.

Coast Guard: Continued Improvements Needed to Address Potential 

Barriers to Equal Employment Opportunity. GAO-12-135. Washington, 

D.C.: December 6, 2011.

Federal Workforce: Practices to Increase the Employment of Individuals 

with Disabilities. GAO-11-351T. Washington, D.C.: February 16, 2011.

Highlights of a Forum: Participant-Identified Leading Practices That Could 

Increase the Employment of Individuals with Disabilities in the Federal 

Workforce. GAO-11-81SP. Washington, D.C.: October 5, 2010.

Highlights of a Forum: Actions that Could Increase Work Participation for 

Adults with Disabilities. GAO-10-812SP. Washington, D.C.: July 29, 2010.

Federal Disability Programs: Coordination Could Facilitate Better Data 

Collection to Assess the Status of People with Disabilities. GAO-08-872T. 

Washington, D.C.: June 4, 2008.

Federal Disability Programs: More Strategic Coordination Could Help 

Overcome Challenges to Needed Transformation. GAO-08-635. 

Washington, D.C.: May 20, 2008.

Highlights of a Forum: Modernizing Federal Disability Policy. 

GAO-07-934SP. Washington, D.C.: August 3, 2007.

Equal Employment Opportunity: Improved Coordination Needed between 

EEOC and OPM in Leading Federal Workplace EEO. GAO-06-214. 

Washington, D.C.: June 16, 2006.

Results-Oriented Government: Practices That Can Help Enhance and 

Sustain Collaboration among Federal Agencies. GAO-06-15. Washington, 

D.C.: October 21, 2005.

Related GAO Products

(450876)
The Government Accountability Office, the audit, evaluation, and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and 

policies; and provides analyses, recommendations, and other assistance 

to help Congress make informed oversight, policy, and funding decisions. 

GAO’s commitment to good government is reflected in its core values of 

accountability, integrity, and reliability.

The fastest and easiest way to obtain copies of GAO documents at no 

cost is through GAO’s website (www.gao.gov). Each weekday afternoon, 

GAO posts on its website newly released reports, testimony, and 

correspondence. To have GAO e-mail you a list of newly posted products, 

go to www.gao.gov and select “E-mail Updates.”

The price of each GAO publication reflects GAO’s actual cost of 

production and distribution and depends on the number of pages in the 

publication and whether the publication is printed in color or black and 

white. Pricing and ordering information is posted on GAO’s website, 

http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card, 

MasterCard, Visa, check, or money order. Call for additional information.

Connect with GAO on Facebook, Flickr, Twitter, and YouTube. 

Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts. 

Visit GAO on the web at www.gao.gov. 

Contact:

Website: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-

4400, U.S. Government Accountability Office, 441 G Street NW, Room 

7125, Washington, DC 20548

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548

GAO’s Mission

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Phone

Connect with GAO

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Congressional 

Relations

Public Affairs

Please Print on Recycled Paper.