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DHS Federal Law Enforcement 

Training Center

FY 2020

Affirmative Action Plan

for the Recruitment, Hiring, Advancement, and

Retention of Persons with Disabilities

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

EEOC regulations (29 C.F.R. § 1614.203(e)) and MD-715 require agencies to describe how their affirmative action plan will 

improve the recruitment, hiring, advancement, and retention of applicants and employees with disabilities.

Section I: Efforts to Reach Regulatory Goals

EEOC regulations (29 CFR §1614.203(d)(7)) require agencies to establish specific numerical goals for increasing the participation 

of persons with disabilities and persons with targeted disabilities in the federal government

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

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

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

b. Cluster GS-11 to SES (PWD) Answer No

GS-1 to GS-10 (PWD): 42.34% compared to 12% GS-11 to SES (PWD): 27.83% compared to 12%

*For GS employees, please use two clusters: GS-1 to GS-10 and GS-11 to SES, as set forth in 29 C.F.R. § 1614.203(d)(7). For all 

other pay plans, please use the approximate grade clusters that are above or below GS-11 Step 1 in the Washington, DC 

metropolitan region.

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

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

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

b. Cluster GS-11 to SES (PWTD) Answer No

GS-1 to GS-10 (PWTD): 7.21% compared to 2% GS-11 to SES (PWTD): 3.29% compared to 2%

Grade Level Cluster(GS or Alternate Pay 

Planb)

Total Reportable Disability Targeted Disability

# # % # %

Numarical Goal -- 12% 2%

Grades GS-1 to GS-10 111 47 42.34 8 7.21

Grades GS-11 to SES 913 250 27.38 30 3.29

3. Describe how the agency has communicated the numerical goals to the hiring managers and/or recruiters.

Once the EEOC establishes the numerical goals for each FY, the EEO Office and Workforce Management Branch provides 

identified goals to key stakeholders and the Diversity and Inclusion Council. These goals are communicated to senior level hiring 

managers in annual reports such as Component Recruitment Outreach Plan (CROP), Disabled Veterans Affirmative Action Plan 

(DVAAP), and Federal Equal Opportunity Recruitment Program (FEORP). They are also are shared with FLETC staff through New 

Employee Orientation, FLETC New Supervisor Training Program and in Monthly Manager and Employee Training events. 

Additionally, Federal disability hiring goals are posted on the EEO SharePoint page. Human Resource personnel discuss 

recruitment strategies with hiring managers, suggesting sources with disability in mind e.g., Schedule A direct hire authority, as 
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well as 30% or more disabled veteran hiring sources.

Section II: Model Disability Program

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

disabilities and persons with targeted disabilities, administer the reasonable accommodation program and special emphasis program, 

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

A. PLAN TO PROVIDE SUFFICIENT & COMPETENT STAFFING FOR THE DISABILITY 

PROGRAM

1. Has the agency designated sufficient qualified personnel to implement its disability program during the reporting period? 

If “no”, describe the agency’s plan to improve the staffing for the upcoming year.

Answer Yes

To ensure FLETC’s ability to implement and sustain its disability programs, the FLETC employs a dedicated Disability Program 

Manager and four EEO Specialists who process requests for reasonable accommodation (RA) and Personal Assistance Services 

(PAS). Additionally, FLETC employs a Section 508 Coordinator, a Selective Placement Coordinator, a Disability Access 

Coordinator, and alternates to ensure accessibility for employees, students and visitors to all FLETC points of service. FLETC 

established an assessment process for all requests for Reasonable Accommodation and PAS. This process requires that a 

Reasonable Accommodation Team consisting of an EEO Specialist, an Attorney from the Office of Chief Counsel, and a Labor 

Relations Specialist from the Human Capital Office individually assess each RA request. The Team provides advice and procedural 

guidance to the requestor’s supervisor to make an informed decision regarding the reasonable accommodation request. Federal 

Occupational Health Service physicians provide occupational medical opinions through contracted services, as needed.

2. Identify all staff responsible for implementing the agency's disability employment program by the office, staff 

employment status, and responsible official.

Disability Program Task

# of FTE Staff By Employment Status Responsible Official 

(Name, Title, Office 

Full Time Part Time Collateral Duty Email)

Special Emphasis Program for PWD and 

PWTD

1 0 0 Arlene Gonzalez

Disability Program 

Manager

arlene.gonzalez.@fletc.dhs.gov

Processing reasonable accommodation requests 

from applicants and employees

5 0 0 Arlene Gonzalez

Disability Program 

Manager

arlene.gonzalez@fletc.dhs.gov

Processing applications from PWD and PWTD 1 0 0 Malcolm F. Campbell

Human Resources 

Specialist (Recruitment)

malcolm.campbell@fletc.dhs.gov

Answering questions from the public about 

hiring authorities that take disability into 

account

1 0 0 Malcolm F. Campbell

Human Resources 

Specialist (Recruitment)

malcolm.campbell@fletc.dhs.gov

Section 508 Compliance 1 0 0 Rose Mary Jones

Program Manager

rosemary.jones@fletc.dhs.gov

Architectural Barriers Act Compliance 1 0 0 Arlene Gonzalez

Disability Program 

Manager

arlene.gonzalez@fletc.dhs.gov

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

reporting period? If “yes”, describe the training that disability program staff have received. If “no”, describe the training 
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planned for the upcoming year.

Answer Yes

During FY 2020, the Disability Program Manager and EEO Specialists participated in training, webinars and meetings presented by 

a variety of sources. The training sources included: DHS/CRCL, Disability Employment Advisory Council and Diversity 

Management Section and Component Meetings, Equal Employment Opportunity Commission, Job Accommodation Network, 

Department of Defense Computer/Electronic Accommodations Program, Federal Exchange on Employment and Disability, 

Department of Labor Employer Assistance & Resource Network, Department of Labor Office of Disability Employment Policy, 

LEAD Center and LRP Publications throughout the fiscal year, and Section 508 training. All EEO Specialists received their 8-hour 

refresher training through Cyberfeds E-learning that included training in Applying Disability Laws When Identifying Employees 

With Disabilities.

B. PLAN TO ENSURE SUFFICIENT FUNDING FOR THE DISABILITY PROGRAM

Has the agency provided sufficient funding and other resources to successfully implement the disability program during 

the reporting period? If “no”, describe the agency’s plan to ensure all aspects of the disability program have sufficient 

funding and other resources.

Answer Yes

All EEO, Human Capital Office, and Office of Chief Counsel staff who participate in RA and PAS processing and employee 

training, section 508 and accessibility have received sufficient training, funding, and guidance to ensure timely completion of 

requests for these services.

Section III: Program Deficiencies In The Disability Program
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Brief Description of Program 

Deficiency

C.2.b. Has the agency established disability reasonable accommodation procedures that comply with EEOC’s 

regulations and guidance? [see 29 CFR §1614.203(d)(3)]

Objective FLETC Reasonable Accommodation Procedures that are compliant with EEOC regulations and 

guidance.

Target Date Mar 31, 2020

Completion Date

Planned Activities

Target Date Completion Date Planned Activity

Jan 18, 2019 Submit FLETC Reasonable Accommodation Procedures to EEOC for 

review and approval. FLETC submitted its draft Reasonable 

Accommodation Procedures to EEOC for initial review in September 

2019, and met with EEOC in November 2019 to obtain their feedback. 

FLETC incorporated the EEOC’s guidance and submitted updated 

procedures through the FLETC Directives Review Process, which is 

projected to be complete in FY 2021.

May 1, 2019 Completion and publishing of FLETC Reasonable Accommodation 

Directive

Nov 19, 2019 November 22, 2019 Final review of Reasonable Accommodation Directive from MRSD, HCO 

and OCC.

Nov 25, 2019 July 23, 2020 Submission of Reasonable Accommodation Directive to the Director’s 

Office for the review and approval process for new FLETC Directives.

Accomplishments

Fiscal Year Accomplishment

2019 FLETC’s Reasonable Accommodation Procedures have been updated to comply 

with EEOC’s regulations and guidance and was submitted to EEOC for review 

and approval on July 18, 2019. Additionally, the EEO office, in consultation with 

key stakeholders in our Mission Readiness Support Directorate, Human Capital 

Office and Office of Chief Counsel, has also incorporated FLETC’s Reasonable 

Accommodation Procedures into a draft Directive that will be under review 

through the FLETC Directives Review Process and projected to be complete in 

FY 2020.

2020 FLETC submitted its draft Reasonable Accommodation Procedures to EEOC for 

initial review in September 2019, and met with EEOC in November 2019 to 

obtain their feedback. FLETC incorporated the EEOC’s guidance and submitted 

updated procedures through the FLETC Directives Review Process, which is 

projected to be complete in FY 2021.
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Brief Description of Program 

Deficiency

C.2.b.5. Does the agency process all initial accommodation requests, excluding ongoing interpretative services, within 

the time frame set forth in its reasonable accommodation procedures? [see MD-715, II(C)] If “no”, please provide the 

percentage of timely-processed requests, excluding ongoing interpretative services, in the comments column.

Objective

FLETC Reasonable Accommodation Procedures that are in compliance with EEOC regulations and 

guidance, and to implement procedures to assist agency in processing accommodation requests 

within the timeframe set forth in its reasonable accommodation procedures.

Target Date Jan 18, 2019

Completion Date

Planned Activities

Target Date Completion Date Planned Activity

May 31, 2020 November 22, 2019 Final review of Reasonable Accommodation Directive from MRSD, HCO 

and OCC.

Jun 15, 2020 July 23, 2020 Submission of Reasonable Accommodation Directive to the Director’s 

Office for the review and approval process for new FLETC Directives.

Sep 30, 2020 Implement the use of ACMS SMT system to process all reasonable 

accommodation requests ensuring accurate real time tracking processes 

and timeframes. The ACMS system has been revised by DHS. FLETC 

staff will be trained on the new system once revisions are complete. 

FLETC DPM and RAC continue to monitor and maintain an internal 

tracking system for reasonable accommodations for students and 

employees.

Nov 15, 2020 Completion and publishing of FLETC Reasonable Accommodation 

Directive.

Accomplishments

Fiscal Year Accomplishment

2019 FLETC’s Reasonable Accommodation Procedures have been updated to comply 

with EEOC’s regulations and guidance and was submitted to EEOC for review 

and approval on July 18, 2019. Additionally, the EEO Office, in consultation 

with key stakeholders in our Office of Chief Counsel, has incorporated FLETC’s 

Reasonable Accommodation Procedures into a draft Directive that is under 

review through the FLETC Directives Review Process and projected to be 

complete in FY 2020.

2020 The FY 2020 compliance rate reflected a 1.5 percentage point improvement over 

the FY 2019 compliance rate with 71.5% of employee Reasonable 

Accommodation Requests timely- processed in an average of 16.9 days. This 

slight percentage increase could be attributed to having two EEO Specialists 

assigned to provide SME assistance to the Disability Program Manager (DPM) 

with processing in-coming requests for reasonable accommodation; the cases 

were assigned as a “priority assignment.” EEO staff, inclusive of the DPM, also 

worked closely with Office of Chief Counsel, Human Capital Office and 

management officials, to ensure timeframes were met, to every extent possible, 

in compliance with regulatory requirements. The EEO Office also completed the 

review and update of the current EEO directive and procedures; this document is 

currently under concurrent clearance at FLETC and it is anticipated that this new 

guidance will be assistive with improving compliance rates on requests for 

accommodation.

Section IV: Plan to Recruit and Hire Individuals with Disabilities

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

individuals with disabilities. The questions below are designed to identify outcomes of the agency’s recruitment program plan for 

PWD and PWTD

A. PLAN TO IDENTIFY JOB APPLICATIONS WITH DISABILITIES

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

targeted disabilities.
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Recruitment: Over the last fiscal year, FLETC has utilized a variety of targeted outreach efforts of Individuals with Disabilities, 

veterans, members of a minority or racial groups and women to increase recruitment. FLETC was able to participate in nine 

recruitment and outreach events during FY 2020. Additionally, FLETC maintains an open continuous voluntary applicant file for 

specific series and grades of high-volume recruitment positions for those candidates with non-competitive hiring eligibility, 

including Schedule A and 30% or more disabled veterans. FLETC’s in-person recruitment and outreach efforts were significantly 

reduced and modified due to the COVID-19 pandemic. FLETC participated in four in-person recruitment events in early FY 2020: 

Gallaudet University on 10/4/2019 (PWD/PWTD); Congressman Bennie Thompson G Thompson College and Career Fair 

(Greenville, MS) on 10/11/2019 (HBCU/MSI); Technical & Engineering Job Fair (Kingsland, GA) on 2/5/2020; and the Navy TriBase Fair (Jacksonville, FL) on 3/4/2020. To ensure continued outreach, FLETC participated in the following events virtually: 

Military Spouse Virtual Hiring Fair (8/12/2020); DHS is Hiring Law Enforcement Webinar 8/28/2020; DHS is Hiring Veterans 

Webinar 9/9/2020; Warriors to the Workforce Veteran Summit 9/16/2020); the 2020 Virtual National HBCU Week Conference 

9/21/2020 through 9/25/2020 (HBCU/MSI); and the DHS is Hiring Students and Recent Grads Webinar (Virtual) on 9/23/2020. 

FLETC continuously reviews and recommends changes to the recruitment and outreach process and recruitment sources to ensure 

the continued success of FLETC’s ability to recruit and retain a diverse segment of qualified applicants. In FY 2020, FLETC 

exceeded DHS Workforce Participation Goals for People with Disabilities totaling 307 employees and comprising 28.67% of the 

permanent workforce, exceeding the requirement of 12%. People with Targeted Disabilities comprised 3.73% of the permanent 

workforce (40 employees) and exceeded the 2% requirement. Additionally, FLETC exceeded DHS Goals for Schedule A hiring 

totaling four employees and comprising 8.33% of all new hires in non-law enforcement related positions and exceeded the 1.5% 

requirement FLETC continued use of the Pathways Programs (Pathways), the federal government’s primary entry point for students 

and recent graduates. In FY 2020, one employee was hired under the Recent Graduates of the Pathways Program. Vacancy 

announcements are posted on the agency’s internal and external websites and social media accounts. Announcements are also sent 

to FLETC’s Diversity Initiative Notification Roster within Monster Government Solutions that includes diverse law enforcement, 

cultural and professional organizations, various disability related service and support organizations, colleges and universities, and 

the Wounded Warrior Project. Outreach: Vacancy announcements are posted on the agency’s internal and external websites and 

social media accounts. The WMB sends announcements to FLETC’s Diversity Initiative Notification Roster within Monster 

Government Solutions that includes diverse cultural and professional organizations, various disability related service and support 

organizations, colleges and universities, and the Wounded Warrior Project. Additionally, FLETC sends vacancy announcements to 

representatives serving on the Brunswick Glynn County Council on Disabilities. This Committee consists of representatives from 

numerous disability serving institutions including LIFE – Living Independence for Everyone, Inc., National Alliance on Mental 

Illness, Georgia Vocational Rehabilitation Agency, Veteran’s Administration, Glynn County Emergency Management Agency, and 

many others.

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

(e.g., Schedule A) to recruit PWD and PWTD for positions in the permanent workforce

FLETC maintains an open continuous voluntary applicant file for specific series and grades of high-volume recruitment positions 

for those candidates with non-competitive hiring eligibility, including Schedule A and 30% or more disabled veterans.

3. When individuals apply for a position under a hiring authority that takes disability into account (e.g., Schedule A), explain 

how the agency (1) determines if the individual is eligible for appointment under such authority; and, (2) forwards the 

individual's application to the relevant hiring officials with an explanation of how and when the individual may be 

appointed.

The GS-1801, 2210, 0201 and 1102 series are the four mission critical occupational opportunities that are offered through the 

automated on-line Voluntary Applicant File, which affords Schedule A applicants and disabled veterans consideration without 

competition for positions for which they are qualified. A 10-point preference file is also maintained that allows HCO to review and 

refer qualified applicants who are 30% or more disabled veterans to hiring managers for the possibility of non-competitive 

selections. The Human Capital Office offers these recruitment/hiring options to hiring managers as a first recruitment strategy. 

Human Capital Office staff completes a qualifications review of all applicants placed in the status file based on the same criteria as 

all other veteran applicants.

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

(e.g., Schedule A)? If “yes”, describe the type(s) of training and frequency. If “no”, describe the agency’s plan to provide 

this training.
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Answer Yes

Managers receive training initially and biennially through on-line training modules in PALMS titled: Employment of People with 

Disabilities: A Roadmap to Success, and through Managers Workshops provided by HCO and EEO. Additionally, HCO provides 

training on the Recruitment Process for Supervisors that includes information about special hiring authorities to include 

employment of individuals with disabilities is included in the FLETC New Supervisor Training Program.

B. PLAN TO ESTABLISH CONTACTS WITH DISABILITY EMPLOYMENT ORGANIZATIONS

Describe the agency’s efforts to establish and maintain contacts with organizations that assist PWD, including PWTD, in 

securing and maintaining employment.

FLETC’s Disability Program Manager is a member of the Brunswick Glynn County Council on Disabilities. The mission of the 

Committee is to improve the quality of life of persons with disabilities in the Brunswick Glynn County area by promoting 

opportunities to work and live in an environment free of architectural or attitudinal barriers. The Disability Program Manager shares 

vacancy announcements with the Council members, as well as various other disability related service and support organizations, 

colleges and universities, and the Wounded Warrior Project. The Human Capital Office utilizes a listing of diversity and disability 

related contacts and sends those contacts email notification of vacancy announcements.

C. PROGRESSION TOWARDS GOALS (RECRUITMENT AND HIRING)

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

the new hires in the permanent workforce? If “yes”, please describe the triggers below.

a. New Hires for Permanent Workforce (PWD) Answer No

b. New Hires for Permanent Workforce (PWTD) Answer No

New Hires for Permanent Workforce (PWD): 34.33% as compared to 12% New Hires for Permanent Workforce (PWTD): 2.99% as 

compared to 2%

New Hires Total

Reportable Disability Targeted Disability

Permanent 

Workforce

Temporary 

Workforce

Permanent 

Workforce

Temporary 

Workforce

(#) (%) (%) (%) (%)

1436 10.93 0.00 4.04 0.00

1339 10.90 0.00 3.73 0.00

19 26.32 0.00 0.00 0.00

% of Total 

Applicants

% of Qualified 

Applicants

% of New Hires

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

of the mission- critical occupations (MCO)? If “yes”, please describe the triggers below. Select “n/a” if the applicant data 

is not available for your agency, and describe your plan to provide the data in the text box.

a. New Hires for MCO (PWD) Answer No

b. New Hires for MCO (PWTD) Answer Yes

New Hires for MCO (PWD): 26.32% compared to 10.90% qualified applicant pool New Hires for MCO (PWTD): 0% compared to 

3.73% qualified applicant pool = trigger Mission critical occupational GS-1801 series have physical and/or medical requirements 

that cause lower than expected selection rates for both PWD and PWTD.
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New Hires to 

Mission-Critical 

Occupations

Total

Reportable Disability Targetable Disability

Qualified 

Applicants New Hires Qualified Applicants New Hires

(#) (%) (%) (%) (%)

Numerical Goal -- 12% 2%

1801GENERAL 

INSPECTION, 

INVESTIGATION 

& COMPLIANCE

0 0.00 0.00 0.00 0.00

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

applicants for any of the mission-critical occupations (MCO)? If “yes”, please describe the triggers below. Select “n/a” if 

the applicant data is not available for your agency, and describe your plan to provide the data in the text box.

a. Qualified Applicants for MCO (PWD) Answer Yes

b. Qualified Applicants for MCO (PWTD) Answer No

Qualified internal applicants for MCO (PWD): 9.98% compared to 29.29% relevant applicant pool = trigger Qualified internal 

applicants for MCO (PWTD): 3.57% compared to 3.14% relevant applicant pool Although the qualified internal applicants fall 

below the relevant applicant pool, the selection rate exceed the qualified applicant pool. FLETC will continue to monitor the 

qualified applicant rate trends

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

to any of the mission- critical occupations (MCO)? If “yes”, please describe the triggers below. Select “n/a” if the 

applicant data is not available for your agency, and describe your plan to provide the data in the text box.

a. Promotions for MCO (PWD) Answer No

b. Promotions for MCO (PWTD) Answer No

Promotions for MCO (PWD): 29.63% compared to 29.29% qualified applicant pool Promotions for MCO (PWTD): 7.41% 

compared to 3.14% qualified applicant pool

Section V: Plan to Ensure Advancement Opportunities for Employees with 

Disabilities

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

with disabilities. Such activities might include specialized training and mentoring programs, career development opportunities, 

awards programs, promotions, and similar programs that address advancement. In this section, agencies should identify, and provide 

data on programs designed to ensure advancement opportunities for employees with disabilities.

A. ADVANCEMENT PROGRAM PLAN

Describe the agency’s plan to ensure PWD, including PWTD, have sufficient opportunities for advancement.

FLETC encourages employee participation in an assortment of career development programs and training opportunities. In FY 

2020, FLETC offered monthly Manager and Employee Workshops opportunities to employees for self-development and 

improvement of job skills in PALMS. Opportunities included job related training, participation in the Developmental Assignment 

Program, DHS Leader Development Competency Café Series, Foundations and Milestone Programs, HR Academy’s Executive 

Speaker Series, and Federal Leadership and Professional Development Seminar Series and other formal and informal career 

development programs. General training opportunities were announced throughout the year by email and postings through 

FLETCconnect covering a variety of subjects for employees at all grade levels. FLETC continues to make available college 

academic career development opportunities to permanent employees through the Tuition Assistance Program (TAP). The TAP 
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reimburses eligible employees for mission-related college courses, helps improve job performance, and enhances needed skills for 

the future. There are several opportunities available for FLETC employees to participate in mentoring programs, as either a mentee 

or mentor. The Diversity and Inclusion Council remains available for input on career development programs that support staff 

retention and succession planning.

B. CAREER DEVELOPMENT OPPORTUNITES

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

FLETC employees have an opportunity to participate in five different mentoring programs: FLETC Mentoring Program, FLETC 8-

hour Cornerstone Mentoring Program, DHS Disability Mentoring Program, DHS Women in Law Enforcement Mentoring Program, 

and the DHS Formal Mentoring Program. The Developmental Assignment Program offers FLETC employees the opportunity to 

grow in new areas to the benefit of the employee, as well as FLETC. This program provides the workforce an opportunity to expand 

job responsibilities; develop competencies and knowledge, skills, and abilities; and learn new tools, techniques, and business 

processes to meet mission requirements. The mission of the DHS Leader Development Program is to maximize mission 

performance, strengthen the DHS leadership bench, and build leadership competencies at all levels of the DHS workforce through a 

coherent and seamless continuum of leader development opportunities across the Department. The Leader Development Program 

framework is a strategic road map designed to yield a stronger cadre of more effective and efficient leaders at every level of DHS 

leadership. The Foundations Program is one part of the strategic road map. The Foundations Program provides Team Members with 

tools to develop their current capabilities and navigate their own leadership development in order to strengthen individual abilities 

and the DHS and FLETC leadership pipeline. Whereas the Foundations Program focuses on the development of one’s own 

leadership behaviors, the Milestone Program provides Team Leads with tools to develop their current capabilities of leading others 

and navigate their own leadership development in order to strengthen management capabilities and the DHS leadership pipeline. 

Other developmental includes the FLETC New Supervisor Training Program, HR Academy’s Executive Speaker Series, Federal 

Leadership and Professional Development Seminar Series, SES Candidate Development Program, the Tuition Assistance Program, 

and Monthly Human Capital Office Employee and Management Workshops. Additionally, all employees have access to continuing 

education classes available in the DHS Performance and Learning Management System.

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

supervisory recommendation/ approval to participate.

Career Development 

Opportunities

Total Participants PWD PWTD

Applicants (#) Selectees (#)

 Applicants 

(%) Selectees (%)

 Applicants 

(%) Selectees (%)

Mentoring Programs 41 41 24.39 24.39 0 0

Internship Programs 0 0 0 0 0 0

Detail Programs 10 10 20.00 20.00 10.00 10.00

Other Career Development 

Programs

93 93 26.88 26.88 3.23 3.23

Fellowship Programs 0 0 0 0 0 0

Coaching Programs 0 0 0 0 0 0

Training Programs 0 0 0 0 0 0

3. Do triggers exist for PWD among the applicants and/or selectees for any of the career development programs? (The 

appropriate benchmarks are the relevant applicant pool for the applicants and the applicant pool for selectees.) If “yes”, 

describe the trigger(s) in the text box. Select “n/a” if the applicant data is not available for your agency, and describe your 

plan to provide the data in the text box.

a. Applicants (PWD) Answer Yes

b. Selections (PWD) Answer No
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The benchmark for PWD is 28.64%. Triggers exist for PWD in the application rate for all career development programs. No 

triggers exist for PWD in selections as all applicants were selected. FLETC will continue to market career development programs to 

all employees, including those with disabilities.

4. Do triggers exist for PWTD among the applicants and/or selectees for any of the career development programs? (The 

appropriate benchmarks are the relevant applicant pool for the applicants and the applicant pool for selectees.) If “yes”, 

describe the trigger(s) in the text box. Select “n/a” if the applicant data is not available for your agency, and describe your 

plan to provide the data in the text box.

a. Applicants (PWTD) Answer Yes

b. Selections (PWTD) Answer No

The benchmark for PWTD is 3.73%. Triggers exist for PWTD in the application rate for all career development programs. No 

triggers exist for PWTD in selections as all applicants were selected. FLETC will continue to market career development programs 

to all employees, including those with disabilities.

C. AWARDS

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

the time-off awards, bonuses, or other incentives? If “yes”, please describe the trigger(s) in the text box.

a. Awards, Bonuses, & Incentives (PWD) Answer Yes

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

Using the inclusion rate as the benchmark (Table B9-2), Time off awards were given in the first three Time off award categories on 

Table B9-2. There were no triggers in the first category of 1-10 Hours that accounted for 88.96% of time off awards. There is a 

trigger for PWD and PWTD in the 11-20 Hours category with PWD at 2.61%, PWTD at 2.50% compared to 9.68% non-PWD; and 

in the 21-30 Hours category for PWTD at 0.00% compared to .41% non-PWD. In Cash award categories, triggers exist for PWD 

received awards in the $501 - $999 category equal to 15.31% and PWTD at 7.50% compared to non-PWD rate of 28.59%. There is 

a trigger for PWTD in the $2000 - $2999 category with 0.00% compared to non-PWD of .41%.

Time-Off Awards Total (#)

Reportable 

Disability %

Without Reportable 

Disability %

Targeted Disability 

%

Without Targeted 

Disability %

Time-Off Awards 1 - 10 hours: 

Awards Given

451 47.56 39.86 52.50 46.82

Time-Off Awards 1 - 10 Hours: 

Total Hours

0 0.00 0.00 0.00 0.00

Time-Off Awards 1 - 10 Hours: 

Average Hours

0 0.00 0.00 0.00 0.00

Time-Off Awards 11 - 20 hours: 

Awards Given

51 2.61 5.68 2.50 2.62

Time-Off Awards 11 - 20 Hours: 

Total Hours

0 0.00 0.00 0.00 0.00

Time-Off Awards 11 - 20 Hours: 

Average Hours

0 0.00 0.00 0.00 0.00

Time-Off Awards 21 - 30 hours: 

Awards Given

5 0.65 0.41 0.00 0.75

Time-Off Awards 21 - 30 Hours: 

Total Hours

0 0.00 0.00 0.00 0.00

Time-Off Awards 21 - 30 Hours: 

Average Hours

0 0.00 0.00 0.00 0.00

Time-Off Awards 31 - 40 hours: 

Awards Given

0 0.00 0.00 0.00 0.00
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Time-Off Awards Total (#)

Reportable 

Disability %

Without Reportable 

Disability %

Targeted Disability 

%

Without Targeted 

Disability %

Time-Off Awards 31 - 40 Hours: 

Total Hours

0 0.00 0.00 0.00 0.00

Time-Off Awards 31 - 40 Hours: 

Average Hours

0 0.00 0.00 0.00 0.00

Time-Off Awards 41 or more 

Hours: Awards Given

0 0.00 0.00 0.00 0.00

Time-Off Awards 41 or more 

Hours: Total Hours

0 0.00 0.00 0.00 0.00

Time-Off Awards 41 or more 

Hours: Average Hours

0 0.00 0.00 0.00 0.00

Cash Awards Total (#)

Reportable 

Disability %

Without Reportable 

Disability %

Targeted Disability 

%

Without Targeted 

Disability %

Cash Awards: $501 - $999: Awards 

Given

230 15.31 24.59 7.50 16.48

Cash Awards: $501 - $999: Total 

Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $501 - $999: 

Average Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $1000 - $1999: 

Awards Given

932 80.78 89.59 95.00 78.65

Cash Awards: $1000 - $1999: Total 

Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $1000 - $1999: 

Average Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $2000 - $2999: 

Awards Given

5 0.65 0.41 0.00 0.75

Cash Awards: $2000 - $2999: Total 

Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $2000 - $2999: 

Average Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $3000 - $3999: 

Awards Given

2 0.33 0.14 0.00 0.37

Cash Awards: $3000 - $3999: Total 

Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $3000 - $3999: 

Average Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $4000 - $4999: 

Awards Given

0 0.00 0.00 0.00 0.00

Cash Awards: $4000 - $4999: Total 

Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $4000 - $4999: 

Average Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $5000 or more: 

Awards Given

0 0.00 0.00 0.00 0.00

Cash Awards: $5000 or more: Total 

Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $5000 or more: 

Average Amount

0 0.00 0.00 0.00 0.00

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

increases or performance- based pay increases? If “yes”, please describe the trigger(s) in the text box.

a. Pay Increases (PWD) Answer Yes

b. Pay Increases (PWTD) Answer Yes
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Using the Inclusion rate as the benchmark (Table B9-2), there is a trigger for both PWD at 4.89% and PWTD at 2.50% compared to 

non-PWD at 5.41% in Quality Step Increases.

Other Awards Total (#)

Reportable 

Disability %

Without Reportable 

Disability %

Targeted Disability 

%

Without Targeted 

Disability %

Total Performance Based Pay 

Increases Awarded

8 0.00 1.08 0.00 0.00

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

less than employees without disabilities? (The appropriate benchmark is the inclusion rate.) If “yes”, describe the 

employee recognition program and relevant data in the text box.

a. Other Types of Recognition (PWD) Answer N/A

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

D. PROMOTIONS

1. Does your agency have a trigger involving PWD among the qualified internal applicants and/or selectees for promotions to 

the senior grade levels? (The appropriate benchmarks are the relevant applicant pool for qualified internal applicants and 

the qualified applicant pool for selectees.) For non-GS pay plans, please use the approximate senior grade levels. If “yes”, 

describe the trigger(s) in the text box. Select “n/a” if the applicant data is not available for your agency, and describe your 

plan to provide the data in the text box.

a. SES

i. Qualified Internal Applicants (PWD) Answer No

ii. Internal Selections (PWD) Answer No

b. Grade GS-15

i. Qualified Internal Applicants (PWD) Answer Yes

ii. Internal Selections (PWD) Answer Yes

c. Grade GS-14

i. Qualified Internal Applicants (PWD) Answer Yes

ii. Internal Selections (PWD) Answer No

d. Grade GS-13

i. Qualified Internal Applicants (PWD) Answer No

ii. Internal Selections (PWD) Answer No

GS-15 Qualified internal applicants (PWD): 7.01% compared to 22.39% relevant applicant pool = trigger GS-15 Internal selections 

(PWD): 0.00% compared to 7.01% qualified internal applicants = trigger GS-14 Qualified internal applicants (PWD): 13.64% 

compared to 28.22% relevant applicant pool = trigger

2. Does your agency have a trigger involving PWTD among the qualified internal applicants and/or selectees for promotions 

to the senior grade levels? (The appropriate benchmarks are the relevant applicant pool for qualified internal applicants 

and the qualified applicant pool for selectees.) For non-GS pay plans, please use the approximate senior grade levels. If 

“yes”, describe the trigger(s) in the text box. Select “n/a” if the applicant data is not available for your agency, and 
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describe your plan to provide the data in the text box.

a. SES

i. Qualified Internal Applicants (PWTD) Answer Yes

ii. Internal Selections (PWTD) Answer No

b. Grade GS-15

i. Qualified Internal Applicants (PWTD) Answer No

ii. Internal Selections (PWTD) Answer Yes

c. Grade GS-14

i. Qualified Internal Applicants (PWTD) Answer No

ii. Internal Selections (PWTD) Answer No

d. Grade GS-13

i. Qualified Internal Applicants (PWTD) Answer No

ii. Internal Selections (PWTD) Answer No

SES Qualified applicant pool (PWTD): 0.00% compared to 1.49% relevant applicant pool = trigger GS-15 Internal selections 

(PWTD): 0.00% compared to 4.46% qualified applicant pool = trigger

3. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving PWD among the new hires 

to the senior grade levels? For non-GS pay plans, please use the approximate senior grade levels. If “yes”, describe the 

trigger(s) in the text box. Select “n/a” if the applicant data is not available for your agency, and describe your plan to 

provide the data in the text box.

a. New Hires to SES (PWD) Answer No

b. New Hires to GS-15 (PWD) Answer No

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

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

4. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving PWTD among the new 

hires to the senior grade levels? For non-GS pay plans, please use the approximate senior grade levels. If “yes”, describe 

the trigger(s) in the text box. Select “n/a” if the applicant data is not available for your agency, and describe your plan to 

provide the data in the text box.

a. New Hires to SES (PWTD) Answer No

b. New Hires to GS-15 (PWTD) Answer No

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

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

New hires to GS-14 (PWTD): 0.00% as compared to qualified applicant pool 9.38% = trigger New hires to GS-13 (PWTD): 0.00% 

as compared to qualified applicant pool 4.26% = trigger
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5. Does your agency have a trigger involving PWD among the qualified internal applicants and/or selectees for promotions to 

supervisory

positions? (The appropriate benchmarks are the relevant applicant pool for qualified internal applicants and the qualified 

applicant pool for selectees.) If “yes”, describe the trigger(s) in the text box. Select “n/a” if the applicant data is not 

available for your agency, and describe your plan to provide the data in the text box.

a. Executives

i. Qualified Internal Applicants (PWD) Answer N/A

ii. Internal Selections (PWD) Answer N/A

b. Managers

i. Qualified Internal Applicants (PWD) Answer N/A

ii. Internal Selections (PWD) Answer N/A

c. Supervisors

i. Qualified Internal Applicants (PWD) Answer N/A

ii. Internal Selections (PWD) Answer N/A

N/A. Unable to determine if triggers exist. Monster Government Solutions applicant flow data is not currently not broken down by 

Executives, Managers and Supervisors.

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

to supervisory positions? (The appropriate benchmarks are the relevant applicant pool for qualified internal applicants and 

the qualified applicant pool for selectees.) If “yes”, describe the trigger(s) in the text box. Select “n/a” if the applicant data 

is not available for your agency, and describe your plan to provide the data in the text box.

a. Executives

i. Qualified Internal Applicants (PWTD) Answer N/A

ii. Internal Selections (PWTD) Answer N/A

b. Managers

i. Qualified Internal Applicants (PWTD) Answer N/A

ii. Internal Selections (PWTD) Answer N/A

c. Supervisors

i. Qualified Internal Applicants (PWTD) Answer N/A

ii. Internal Selections (PWTD) Answer N/A

N/A. Unable to determine if triggers exist. Monster Government Solutions applicant flow data is not currently not broken down by 

Executives, Managers and Supervisors.

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

for new hires to supervisory positions? If “yes”, describe the trigger(s) in the text box. Select “n/a” if the applicant data is 

not available for your agency, and describe your plan to provide the data in the text box.

a. New Hires for Executives (PWD) Answer N/A
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b. New Hires for Managers (PWD) Answer N/A

c. New Hires for Supervisors (PWD) Answer N/A

N/A. Unable to determine if triggers exist. Monster Government Solutions applicant flow data is not currently not broken down by 

Executives, Managers and Supervisors.

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

selectees for new hires to supervisory positions? If “yes”, describe the trigger(s) in the text box. Select “n/a” if the 

applicant data is not available for your agency, and describe your plan to provide the data in the text box.

a. New Hires for Executives (PWTD) Answer N/A

b. New Hires for Managers (PWTD) Answer N/A

c. New Hires for Supervisors (PWTD) Answer N/A

N/A. Unable to determine if triggers exist. Monster Government Solutions applicant flow data is not currently not broken down by 

Executives, Managers and Supervisors.

Section VI: Plan to Improve Retention of Persons with Disabilities

To be model employer for persons with disabilities, agencies must have policies and programs in place to retain employees with 

disabilities. In this section, agencies should: (1) analyze workforce separation data to identify barriers retaining employees with 

disabilities; (2) describe efforts to ensure accessibility of technology and facilities; and (3) provide information on the reasonable 

accommodation program and workplace assistance services.

A. VOLUNTARY AND INVOLUNTARY SEPARATIONS

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

service after two years of satisfactory service (5 C.F.R. § 213.3102(u)(6)(i))? If “no”, please explain why the agency did 

not convert all eligible Schedule A employees.

Answer No

The four Schedule A conversions that were missed in FY 2020 were due to a combination of personnel changes in HCO and 

oversight of the necessary notification processes for the time-sensitive actions. In the current process, HCO pulls a bi-weekly report 

that identifies individuals who are eligible for conversion. Three months before conversion, HCO notifies the appropriate 

supervisors of the actions needed on the employee’s behalf to process their conversion. HCO will work with leadership during FY 

2021 to identify strategies to ensure conversion actions are requested and implemented within regulatory requirements.

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

exceed that of persons without disabilities? If “yes”, describe the trigger below.

a.Voluntary Separations (PWD) Answer Yes

b.Involuntary Separations (PWD) Answer No

The inclusion rate for PWD was higher in each category of voluntary separation (resignation 20.69% and retirement 51.72%) than 

people without disabilities (15.29% and 45.88% respectively.) There were no triggers identified for PWD in the category of 

involuntary separations (Table B2) with an inclusion rate of 24.14% compared to 36.14%.

Seperations Total # Reportable Disabilities %

Without Reportable 

Disabilities %

Permanent Workforce: Reduction in Force 0 0.00 0.00
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Seperations Total # Reportable Disabilities %

Without Reportable 

Disabilities %

Permanent Workforce: Removal 1 0.28 0.00

Permanent Workforce: Resignation 6 0.85 0.32

Permanent Workforce: Retirement 52 3.99 4.08

Permanent Workforce: Other Separations 15 0.57 1.39

Permanent Workforce: Total Separations 74 5.70 5.79

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

exceed that of persons without targeted disabilities? If “yes”, describe the trigger below.

a.Voluntary Separations (PWTD) Answer Yes

b.Involuntary Separations (PWTD) Answer No

Voluntary separations (PWTD): 10.00% compared to person without targeted disabilities 7.06% = trigger

Seperations Total # Targeted Disabilities %

Without Targeted Disabilities 

%

Permanent Workforce: Reduction in Force 0 0.00 0.00

Permanent Workforce: Removal 1 0.00 0.08

Permanent Workforce: Resignation 6 0.00 0.49

Permanent Workforce: Retirement 52 8.16 3.89

Permanent Workforce: Other Separations 15 0.00 1.22

Permanent Workforce: Total Separations 74 8.16 5.67

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

interview results and other data sources.

PWD involuntary separation: one, NOA: 330 Removal PWTD voluntary separations: three, NOA: 302 Retirement voluntary and 

one, NOA:301 Retirement Disability

B. ACCESSIBILITY OF TECHNOLOGY AND FACILITIES

Pursuant to 29 CFR §1614.203(d)(4), federal agencies are required to inform applicants and employees of their rights under Section 

508 of the Rehabilitation Act of 1973 (29 U.S.C. § 794(b), concerning the accessibility of agency technology, and the Architectural 

Barriers Act of 1968 (42 U.S.C. § 4151-4157), concerning the accessibility of agency facilities. In addition, agencies are required to 

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

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

rights under Section 508 of the Rehabilitation Act, including a description of how to file a complaint.

https://www.fletc.gov/accessibility-statement

2. Please provide the internet address on the agency’s public website for its notice explaining employees’ and applicants’ 

rights under the

Architectural Barriers Act, including a description of how to file a complaint.

https://www.fletc.gov/accessibility-statement

3. Describe any programs, policies, or practices that the agency has undertaken, or plans on undertaking over the next fiscal 

year, designed to improve accessibility of agency facilities and/or technology.
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The following facilities accessibility projects were completed in FY 2020: Glynco – BG0252 and BG0021; Cheltenham – BC0062, BC0642 and added public facing project at BC0003. In 2019, FLETC completed a Disability Access Plan for Public-Facing 

Programs and Activities (Non-Employment). This is a three-phase general methodology plan expected to ensure that FLETC’s 

public facing programs and activities are universally accessible to individuals with disabilities at the four training delivery points 

(Glynco, GA; Charleston, SC; Cheltenham, MD; Artesia, NM) and at FLETC’s office in Washington, D.C. For 2021, FLETC will 

continue executing the “Component Disability Access Plan for Public Facing Programs and Activities (Non-Employment)” DHS 

Directive and Instruction 065-01-001 that was completed in 2019. Additionally, any accessibility projects scheduled for FY 20 that 

were not completed have been deferred to FY 21.

C. REASONABLE ACCOMMODATION PROGRAM

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

and employees, reasonable accommodation procedures.

1. Please provide the average time frame for processing initial requests for reasonable accommodations during the reporting 

period. (Please do not include previously approved requests with repetitive accommodations, such as interpreting services.)

FLETC processed accommodation requests in an average of 16.9 days in FY 2020.

2. Describe the effectiveness of the policies, procedures, or practices to implement the agency’s reasonable accommodation 

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

accommodations, conducting training for managers and supervisors, and monitoring accommodation requests for trends.

In FY 2020, FLETC EEO Specialists briefed all new employees (supervisors and nonsupervisory) on the reasonable 

accommodation process during new employee orientation. The Disability Program Manager provided Reasonable Accommodation 

training during FLETC New Supervisor Training Program, as well as workshops for both supervisory and non-supervisory 

employees. In FY 2020, 71.5% of employee Reasonable Accommodation Requests were processed timely, with an average of 16.9 

days. A draft Reasonable Accommodation Directive is in the review process that provides detailed guidance for the processing of 

requests. The FLETC team approach to processing requests for Reasonable Accommodation has demonstrated that this approach is 

effective in the accommodations provided, the processing time average, and the knowledge sharing between the Human Capital 

Office, Office of Chief Counsel and the EEO Office. The EEO Office/ DPM established a new work group under the auspices of the 

FLETC Diversity Council. This work group is called the Student and Employee Disability and Accessibility Work Group 

(SEDAWG) and consists of representatives from various divisions and offices at FLETC whose mission includes responsibility for 

adherence to the Rehabilitation Act and the Americans with Disabilities Act. The offices include the Facilities Management 

Division, IT Business Management Division, Student Services Division, Security Management Operations, Human Capital Office, 

End-User Computing Support Branch, Evaluation and Analysis Branch, Critical Incident Stress Management Office, and the EEO 

Office. This group has been very successful in providing information to the FLETC workforce on FLETC Connect on topics such as 

Schedule A Hiring, Veterans Hiring, Agency Responsibilities under the Rehabilitation Act, Reasonable Accommodation and 

Accessibility. The network established by SEDAWG was directly instrumental in facilitating requests for accommodation, 

especially in the areas of technology and accessibility. Lastly, FLETC’s National Disability Employment Awareness Month 

Planning Committee sponsored a program and information/technology fair, which provided attendees information about reasonable 

accommodation, Computer Accommodation Program, Schedule A, braille and UbiDuo equipment, etc. The fair was well attended 

and supported by senior leaders at FLETC and other training delivery points.

D. PERSONAL ASSISTANCE SERVICES ALLOWING EMPLOYEES TO PARTICIPATE IN THE 

WORKPLACE

Pursuant to 29 CFR §1614.203(d)(5), federal agencies, as an aspect of affirmative action, are required to provide personal 

assistance services (PAS) to employees who need them because of a targeted disability, unless doing so would impose an undue 

hardship on the agency.

Describe the effectiveness of the policies, procedures, or practices to implement the PAS requirement. Some examples of 

an effective program include timely processing requests for PAS, timely providing approved services, conducting training 

for managers and supervisors, and monitoring PAS requests for trends.
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Requests from employees with targeted disabilities who require personal assistant services (PAS) will be processed under the 

FLETC reasonable accommodation policy. In FY 2020, there were no requests for personal assistant services.

Section VII: EEO Complaint and Findings Data

A. EEO COMPLAINT DATA INVOLVING HARASSMENT

1. During the last fiscal year, did a higher percentage of PWD file a formal EEO complaint alleging harassment, as compared 

to the governmentwide average?

Answer Yes

2. During the last fiscal year, did any complaints alleging harassment based on disability status result in a finding of 

discrimination or a settlement agreement?

Answer No

3. If the agency had one or more findings of discrimination alleging harassment based on disability status during the last 

fiscal year, please describe the corrective measures taken by the agency.

There were no findings of discrimination.

B. EEO COMPLAINT DATA INVOLVING REASONABLE ACCOMMODATION

1. During the last fiscal year, did a higher percentage of PWD file a formal EEO complaint alleging failure to provide a 

reasonable

accommodation, as compared to the government-wide average?

Answer Yes

2. During the last fiscal year, did any complaints alleging failure to provide reasonable accommodation result in a finding of 

discrimination or a settlement agreement?

Answer Yes

3. If the agency had one or more findings of discrimination involving the failure to provide a reasonable accommodation 

during the last fiscal year, please describe the corrective measures taken by the agency.

There were no findings of discrimination.

Section VIII: Identification and Removal of Barriers

Element D of MD-715 requires agencies to conduct a barrier analysis when a trigger suggests that a policy, procedure, or practice 

may be impeding the employment opportunities of a protected EEO group.

1. Has the agency identified any barriers (policies, procedures, and/or practices) that affect employment opportunities for 

PWD and/or PWTD?

Answer No

2. Has the agency established a plan to correct the barrier(s) involving PWD and/or PWTD?

Answer N/A

3. Identify each trigger and plan to remove the barrier(s), including the identified barrier(s), objective(s), responsible 

official(s), planned activities, and, where applicable, accomplishments
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STATEMENT OF 

CONDITION THAT WAS 

A TRIGGER FOR A 

POTENTIAL BARRIER:

Provide a brief narrative 

describing the condition at 

issue.

How was the condition 

recognized as a potential 

barrier?

Other

Workforce Data Table - B1

CAREER DEVELOPMENT OPPORTUNITIES FY 2020: The benchmark for PWD is 28.64%. 

Triggers exist for PWD in the application rate for all career development programs. No triggers 

exist for PWD in selections as all applicants were selected. The benchmark for PWTD is 3.73%. 

Triggers exist for PWTD in the application rate for all career development programs. No triggers 

exist for PWTD in selections as all applicants were selected. FLETC will continue to market career 

development programs to all employees, including those with disabilities. FY 2019: • In FY 2019, 

triggers exist for PWD among the applicants (16.67% for the Mentoring Program and 14.29% for 

the Detail Program), in comparison to 26.37% for the relevant applicant pool. • Triggers exist for 

PWTD in the Mentoring Program. There were no PWTD applicants for this program.

Y

N

STATEMENT OF 

BARRIER GROUPS:

STATEMENT OF 

IDENTIFIED BARRIER:

Provide a succinct statement 

of the agency policy, 

procedure

or practice that has been 

determined to be the barrier 

of the 

undesired condition.

Barrier Group

People with Disabilities

People with Targeted Disabilities

Source of the Trigger:

Specific Workforce Data 

Table:

Barrier Analysis Process 

Completed?:

Barrier(s) Identified?:

Barrier Name Description of Policy, Procedure, or Practice

Undetermined Continue to review policies, procedures and practices to identify any 

barriers for career development opportunities.

Objective(s) and Dates for EEO Plan

Date 

Initiated

Target Date Sufficient 

Funding / 

Staffing?

Date 

Modified

Date 

Completed

Objective Description

07/08/2020 09/30/2021 Yes To determine if barriers exist to PWD and PWTD in 

the application process for the Mentoring Program.

Responsible Official(s)

Title Name Standards Address The Plan?

EEO Officer John Weaver Yes

HCO Officer Candice Porter Yes

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

09/30/2020 Review the Mentor and Detail program policies and 

practices for barriers for PWD and PWTD.

Yes 05/11/2020

09/30/2020 Look at the marketing and announcement process for the 

Mentor and Detail programs and determine if efficient.

Yes 05/11/2020

09/30/2020 Identify other Career Development opportunities. Yes 01/17/2020
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Report of Accomplishments

Fiscal Year Accomplishment

2020 FLETC Developmental Assignment Program opportunities were announced on FLETCconnect under Career 

Development. Additionally, the announcement was emailed to staff for their awareness.

In FY 2020, training opportunities for staff included cross-training opportunities through the Developmental 

Assignment Program for 10 employees, of which five or 50.00% were from a LPG, two or 20.00% were 

Persons with Disability (PWD) and one or 10.00% was a Person with a Targeted Disability (PWTD). 

Throughout the year, the Workforce Development Branch announced opportunities to participate in mentoring 

programs on FLETCconnect, emails, staff meetings and flyers. In FY 2020, 41 FLETC employees participated 

in five different mentoring programs, (The FLETC Formal Mentoring Program, The FLETC 8-hour 

Cornerstone Mentoring, The DHS Disability Mentoring Program, The DHS Women in Law Enforcement 

Mentoring Program, and The DHS Formal Mentoring Program). Of the 41 employees, (23 mentees and 18 

mentors), ten or 24.39% were PWD and one or 2.44% was a PWTD.

Other Career Development opportunities include the FLETC Milestone and Foundations Programs. In FY 

2020, in the FLETC Milestone Program, there were 19 participants, of which five or 26.32% were PWD. In 

the FLETC Foundations Program, there were seventeen participants, of which 11.77% were PWD. 

Additionally, FLETC included five participants from its participating organizations (Treasury Inspector 

General for Tax Administration and U.S. Customs and Border Protection) in order to take a collaborative 

approach to employee development.
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STATEMENT OF 

CONDITION THAT WAS 

A TRIGGER FOR A 

POTENTIAL BARRIER:

Provide a brief narrative 

describing the condition at 

issue.

How was the condition 

recognized as a potential 

barrier?

Workforce Data (if so identify the table)

Workforce Data Table - B9

AWARDS FY 2020: Using the inclusion rate as the benchmark (Table B9-1), FLETC identified 

triggers involving the percentage of PWD (24.02%, which is -7.56% lower than Non-PWD) and 

PWTD (17.07%, which is -14.51% lower than Non-PWTD) who received Time off awards; and 

PWD (125.81%, which is -8.47% lower that Non-PWD) and PWTD (134.15%, which is -0.13% 

lower than Non-PTWD) for Cash awards. Using the inclusion rate as the benchmark (Table B9-1), 

FLETC identified triggers involving of the percentage of PWTD (2.44%, which is -2.18% lower 

than Non-PWTD) who received Quality step increases. FY 2019: Using the inclusion rate as the 

benchmark (Table B9-1), FLETC identified triggers involving the percentage of PWD (24.02%, 

which is -7.56% lower than Non-PWD) and PWTD (17.07%, which is -14.51% lower than NonPWTD) who received Time off awards; and PWD (125.81%, which is -8.47% lower that NonPWD) and PWTD (134.15%, which is -0.13% lower than Non-PTWD) for Cash awards. Using the 

inclusion rate as the benchmark (Table B9-1), FLETC identified triggers involving of the 

percentage of PWTD (2.44%, which is -2.18% lower than Non-PWTD) who received Quality step 

increases.

Y

N

STATEMENT OF 

BARRIER GROUPS:

STATEMENT OF 

IDENTIFIED BARRIER:

Provide a succinct statement 

of the agency policy, 

procedure

or practice that has been 

determined to be the barrier 

of the 

undesired condition.

Barrier Group

People with Disabilities

People with Targeted Disabilities

Source of the Trigger:

Specific Workforce Data 

Table:

Barrier Analysis Process 

Completed?:

Barrier(s) Identified?:

Barrier Name Description of Policy, Procedure, or Practice

Undetermined Continue to review policies, procedures and practices to identify 

any barriers for awards.

Objective(s) and Dates for EEO Plan

Date 

Initiated

Target Date Sufficient 

Funding / 

Staffing?

Date 

Modified

Date 

Completed

Objective Description

11/04/2019 11/04/2022 Yes The EEO Office and HR will work in concert to 

ensure detailed workforce data is available to EEO for 

in-depth barrier analysis.

Responsible Official(s)

Title Name Standards Address The Plan?

EEO Officer John Weaver Yes

HCO Officer Candice Porter Yes

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

06/30/2020 Request HCO provide quarterly detail data for award and 

recognitions, or provide training to EEO staff.

Yes 09/15/2020
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Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

09/30/2020 Perform trend analysis of detail PWD workforce data. Yes 09/30/2021

09/30/2020 Breakout trend analysis for awards and recognitions by 

Directorate and share with Senior Managers for 

awareness.

Yes 01/31/2021

Report of Accomplishments

Fiscal Year Accomplishment

2020 Request HCO provide quarterly detail data for award and recognitions, or provide training to EEO staff. 

Update: The EEO Specialist was given access to detail data for awards and recognitions through NFC 

Reporting Center. 

Perform trend analysis of detail PWD workforce data. Update: Detail data for awards and recognitions have 

been pulled for FY 2016 through FY 2019. PWD and PWTD inclusion rate in all level of awards falls below 

their comparator from 2017 through 2019. FY 2020 data tables depict that trend did not continue in cash award 

categories $500-under, $2000-2999 and $3000-3999. Time off Awards also saw a change in participation in the 

1-10 Hours and 21-30 Hours. The upward swing is worth noting and will be included in the Departmental 

summaries. In FY 2021, FLETC will continue to evaluate the FY 2020 data against baselines that were 

established for FY 2019. Analysis of all awards given in FY 2019 showed that 99.91% of employees received 

at least one award. That number breaks down to 14.38% awards were to people with disabilities and 85.61% to 

those identifying no disability. Additional findings will be identified in the FY 2021 action planning. 

Breakout trend analysis for awards and recognitions by Directorate and share with Senior Managers for 

awareness. Update: FLETC has pulled the awards and recognitions detail data, is currently sorting it by 

organization, and will distribute to senior management for their awareness during FY 2021.
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STATEMENT OF 

CONDITION THAT WAS 

A TRIGGER FOR A 

POTENTIAL BARRIER:

Provide a brief narrative 

describing the condition at 

issue.

How was the condition 

recognized as a potential 

barrier?

Workforce Data (if so identify the table)

Workforce Data Table - B7

PROMOTIONS FY 2020: The percentage of PWD among the selectees for promotion at grades 

GS-13 (0.00%) and GS-14 (0.00%) fell below their benchmark. The percentage of PWTD among 

the selectees for promotion for grades GS-13 (0.00%) and GS-14 (0.00%) fell below their 

benchmarks. The percentage of PWD among the new hires at grades GS-13 (6.90%), GS-14 

(0.00%) and GS-15 (0.00%) fell below their benchmarks. The percentage of PWTD among the new 

hires at grades GS 13 (3.45%), GS-14 (0.00%) and GS-15 (0.00%) fell below their benchmarks. FY 

2019: The percentage of PWD among the selectees for promotion at grades GS-13 (0.00%) and 

GS-14 (0.00%) fell below their benchmark. The percentage of PWTD among the selectees for 

promotion for grades GS-13 (0.00%) and GS-14 (0.00%) fell below their benchmarks. The 

percentage of PWD among the new hires at grades GS-13 (6.90%), GS-14 (0.00%) and GS-15 

(0.00%) fell below their benchmarks. The percentage of PWTD among the new hires at grades GS 

13 (3.45%), GS-14 (0.00%) and GS-15 (0.00%) fell below their benchmarks.

Y

N

STATEMENT OF 

BARRIER GROUPS:

STATEMENT OF 

IDENTIFIED BARRIER:

Provide a succinct statement 

of the agency policy, 

procedure

or practice that has been 

determined to be the barrier 

of the 

undesired condition.

Barrier Group

People with Disabilities

People with Targeted Disabilities

Source of the Trigger:

Specific Workforce Data 

Table:

Barrier Analysis Process 

Completed?:

Barrier(s) Identified?:

Barrier Name Description of Policy, Procedure, or Practice

Unidentifed Continue review of policies, procedures and practices for 

promotions.

Objective(s) and Dates for EEO Plan

Date 

Initiated

Target Date Sufficient 

Funding / 

Staffing?

Date 

Modified

Date 

Completed

Objective Description

11/04/2019 11/04/2022 Yes EEO and HR will work toward identifying possible 

barriers to the external hiring and internal promotions 

of PWD and PWTD. Analysis of detailed hiring and 

promotion data will be the initial focus.

Responsible Official(s)

Title Name Standards Address The Plan?

HCO Officer Candice Porter Yes

EEO Officer John Weaver Yes

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

06/30/2020 Work with HR to gain access and receive training for 

pulling detailed work force data.

Yes 04/10/2020
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Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

06/30/2020 Work with HR to determine appropriate recruitment data 

and development of metrics.

Yes 09/30/2021

09/30/2020 Perform data analysis to determine where hiring is 

occurring, series, grade, etc.

Yes 09/30/2021

Report of Accomplishments

Fiscal Year Accomplishment

2020 Work with HR to gain access and receive training for pulling detailed work force data. The EEO Specialist was 

given access to detail data through NFC Reporting Center. 

Work with HR to determine appropriate recruitment data and development of metrics. Update: Although due 

to the pandemic most of the targeted events were cancelled, for external new hires, FLETC was able to pursue 

diverse recruitment initiatives by sending vacancy announcements to targeted professional law enforcement, 

cultural and veterans organizations through the Diversity Initiative Notification in Monster Government 

Solutions. Additionally, we were able to participate virtually in the Navy Tri-Base Career Fair, DHS is Hiring 

Law Enforcement Virtual webinar, and Warriors to the Workforce Veteran’s Summit. FLETC DPM met with 

Ft. Stewart Wounded Warrior Program officials and briefed them on Schedule A Hiring Authority, usajobs.gov 

website, and reasonable accommodation. A FLETC Training Division representative participated in U.S. Army 

Garrison Fort Stewart Wounded Warrior Program Town Hall in November 2019 at which time he spoke of 

career opportunities at FLETC and shared his experience as an individual with a targeted disability working as 

an GS-1801 Law Enforcement Instructor at FLETC. 

Perform data analysis to determine where hiring is occurring, series, grade, etc. Update: Detail data for PWD/

PWTD new hires have been pulled for FY 2015 through FY 2020. In FY 2021, FLETC will continue to work 

to provide a baseline for trend analysis.
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STATEMENT OF 

CONDITION THAT WAS 

A TRIGGER FOR A 

POTENTIAL BARRIER:

Provide a brief narrative 

describing the condition at 

issue.

How was the condition 

recognized as a potential 

barrier?

Workforce Data (if so identify the table)

Workforce Data Table - B1

SEPARATIONS FY 2020: Using the inclusion rate, triggers exist for PWD (3.23%) who 

involuntarily separated from the agency, as compared to the rate of persons without disabilities 

(1.80%). FY 2019: Using the inclusion rate, triggers exist for PWD (3.23%) who involuntarily 

separated from the agency, as compared to the rate of persons without disabilities (1.80%).

Y

N

STATEMENT OF 

BARRIER GROUPS:

STATEMENT OF 

IDENTIFIED BARRIER:

Provide a succinct statement 

of the agency policy, 

procedure

or practice that has been 

determined to be the barrier 

of the 

undesired condition.

Barrier Group

People with Disabilities

Source of the Trigger:

Specific Workforce Data 

Table:

Barrier Analysis Process 

Completed?:

Barrier(s) Identified?:

Barrier Name Description of Policy, Procedure, or Practice

Objective(s) and Dates for EEO Plan

Date 

Initiated

Target Date Sufficient 

Funding / 

Staffing?

Date 

Modified

Date 

Completed

Objective Description

11/04/2019 11/04/2020 Yes 09/30/2021 To perform a trend analysis to identify if any barriers 

exist in the separation rate of PWD.

Responsible Official(s)

Title Name Standards Address The Plan?

EEO Officer John Weaver Yes

HCO Officer Candice Porter Yes

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

06/30/2020 Conduct further analysis on nature of action codes for 

other separations.

Yes 04/16/2020

09/30/2020 Identify any trends and/or barriers. Yes 09/30/2021
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Report of Accomplishments

Fiscal Year Accomplishment

2020 An EEO Specialist has access to systems that contain employee data in singular caches. The data for each 

analysis point is pulled separately and then compiled by hand to provide the basis for substantive analysis. 

FLETC continues to gather Separations data for prior years to complete the trend analysis and make a 

determination if barriers exist regarding the separation rate of PWD and PWTD.
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STATEMENT OF 

CONDITION THAT WAS 

A TRIGGER FOR A 

POTENTIAL BARRIER:

Provide a brief narrative 

describing the condition at 

issue.

How was the condition 

recognized as a potential 

barrier?

Workforce Data (if so identify the table)

Workforce Data Table - B6

PROGRESSION TOWARDS GOALS (RECRUITMENT AND HIRING) FY 2020: In comparison 

to the qualified applicant benchmark (9.04%), a trigger does exist for PWD (8.51%) among the 

qualified external applicants for the GS-1801 series. In comparison to the benchmark for PWD 

(27.47%), a trigger does exist for PWD (12.00%) among the qualified internal applicants for the 

GS-1801 series. FY 2019: Table B6-1, although the GS-1801 permanent workforce, PWD (27.47%) 

and PWTD (3.65%) exceed their 12% and 2% goal, new hires fall below in comparison to applicant 

benchmarks.

Y

N

STATEMENT OF 

BARRIER GROUPS:

STATEMENT OF 

IDENTIFIED BARRIER:

Provide a succinct statement 

of the agency policy, 

procedure

or practice that has been 

determined to be the barrier 

of the 

undesired condition.

Barrier Group

People with Disabilities

Source of the Trigger:

Specific Workforce Data 

Table:

Barrier Analysis Process 

Completed?:

Barrier(s) Identified?:

Barrier Name Description of Policy, Procedure, or Practice

Unidentified Continue to review policies, procedures and practices for current 

triggers to ensure there are no barriers.

Objective(s) and Dates for EEO Plan

Date 

Initiated

Target Date Sufficient 

Funding / 

Staffing?

Date 

Modified

Date 

Completed

Objective Description

10/01/2019 09/30/2022 Yes To identify if barriers exist in the recruitment and 

hiring process for the 1801 series.

Responsible Official(s)

Title Name Standards Address The Plan?

Branch Chief, Strategic Recruitment 

Diversity Inclusion and Development

Brenda M. Lloyd Yes

Human Capital Officer Candice Porter Yes

EEO Officer John C. Weaver Yes

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

06/30/2020 Initiate analysis of recruitment processes for 1801 series. Yes 08/31/2020

09/30/2020 Work with HR to initiate an internal metric collection 

tool to better track the hiring process from advertisement 

to hire.

Yes 09/30/2021
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Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

09/30/2020 Examine physical requirements for GS-1801 positions. Yes 01/29/2021

09/30/2020 Work with FLETC’s new Data Driven Management 

office statistician to request detailed data on exit surveys 

to include ERI and gender information to analyze for any 

indicators of why Hispanic or Latino males, White males 

and females separation rates exceed their participation 

rates.

Yes 01/27/2020

Report of Accomplishments

Fiscal Year Accomplishment

2020 Initiate analysis of recruitment processes for 1801 series. Update: Although due to the pandemic most of the 

targeted events were cancelled, FLETC was able to pursue recruitment initiatives for the GS-1801 series by 

sending vacancy announcements to targeted professional law enforcement, cultural and veterans organizations 

through the Diversity Initiative Notification in Monster Government Solutions. Additionally, we were able to 

participate virtually in the Navy Tri-Base Career Fair, DHS is Hiring Law Enforcement Virtual webinar, and 

Warriors to the Workforce Veterans Summit. FLETC DPM met with Ft. Stewart Wounded Warrior Program 

officials and briefed them on Schedule A Hiring Authority and usajobs.gov website and reasonable 

accommodation. A FLETC Training Division representative participated in U.S. Army Garrison Fort Stewart 

Wounded Warrior Program Town Hall in November 2019 at which time he spoke of career opportunities at 

FLETC and shared his experience as an individual with a targeted disability working as an GS-1801 Law 

Enforcement Instructor at FLETC.

Work with HR to initiate an internal metric collection tool to better track the hiring process from advertisement 

to hire. Update: In FY 2020, Monster Government Solutions worked to implement updates on applicant flow 

data. Pending this implementation, FLETC amended this planned activity for the EEO Specialist to work an 

overall five year GS-1801 trend analysis on ERI and gender participation, New Hires (internal and external), 

and Separation rates. The EEO Specialist will continue the trend analysis in FY 2021 to examine GS-1801 

individuals with disabilities. 

Examine physical requirements for GS-1801 positions. Update: Physical requirements for each of the GS-1801 

instructor positions is defined by the hiring manager when the position description is being created. The PDs 

are reviewed every time they are submitted and now that we are using Monster, PDs have a review cycle of 3 

years.

4. Please explain the factor(s) that prevented the agency from timely completing any of the planned activities.

PROGRESSION TOWARDS GOALS (RECRUITMENT AND HIRING) Planned Activity: Work with HR to initiate an internal 

metric collection tool to better track the hiring process from advertisement to hire. Factors: In FY 2020, FLETC was notified that 

Monster Government Solutions was in the process of implementing an update to their systems that will improve the reporting 

capabilities of applicant flow data. The EEO Specialist took that time to conduct trend analysis on the GS-1801 series to further 

identify applicant trends. Once the updated reporting features are finalized, the EEO Specialist will work along with the newly 

formed FLETC Diversity Office and the Human Capital Office to identify any areas of the hiring process for GS-1801’s that are not 

identified in the new reporting feature in Monster Government Solutions.

5. For the planned activities that were completed, please describe the actual impact of those activities toward eliminating the 

barrier(s).

PROGRESSION TOWARDS GOALS (RECRUITMENT AND HIRING) Although no barriers have been identified thus far, the 

EEO Specialist, and the newly formed FLETC Strategic Recruitment, Diversity, Inclusion, and Development Office will assess 
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FY 2020

Page 29

GS-1801 applicant trend analysis against the identified recruitment processes for recommendations of future targeted recruitment 

efforts for women and members of minority racial or ethnic groups to include individuals with disabilities. AWARDS Impacts will 

be measured starting in FY 2021 during ongoing trend analysis.

6. If the planned activities did not correct the trigger(s) and/or barrier(s), please describe how the agency intends to improve 

the plan for the next fiscal year.

N/A