MANAGEMENT

DIRECTIVE 715

ANNUAL EEO PROGRAM

STATUS REPORT

U.S. Department of Transportation

Federal Highway Administration

Fiscal Year 2021
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FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 1 of 103 

Table of Contents

Parts A – E. Identification, General Employment Totals, and Executive Summary ...................... 2

Part F. Certification of Establishment of Continuing EEO Programs ......................................... 26

Part G. Agency Self-Assessment Checklist Measuring Essential Elements................................ 27

Part H. EEO Plan to Attain the Essential Elements of a Model EEO Program ........................... 59

Part I. EEO Plan to Eliminate Identified Barriers ........................................................................ 70

Part J. Special Program Plan for the Recruitment, Hiring, Advancement, and Retention of 

Persons with Disabilities ............................................................................................................... 78
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MD-715

Parts A Through E 

Part A – Department or Agency Identifying Information 

Agency Second Level 

Component Address City State Zip Code Agency FIPS Code

U.S. 

Department of 

Transportation

Federal 

Highway 

Administration

1200 

New 

Jersey 

Avenue, 

SE

Washington DC 20590 TD04

1100

1000

01

Part B – Total Employment 

Total Employment Permanent 

Workforce

Temporary 

Workforce

Total 

Workforce

Number of 

Employees 2722 4 2726 

Part C.1 – Head of Agency and Head of Agency Designee 

Agency Leadership Name Title

Head of Agency Stephanie Pollack Acting Administrator

Head of Agency Designee Stephanie Pollack Deputy Administrator 

Part C.2 – Agency Official(s) Responsible for Oversight of EEO Program(s) 

EEO Program 

Staff Name Title Occupational Series

Pay 

Plan 

and 

Grade

Phone 

Number

Email 

Address

Principal EEO 

Director/ 

Official

Irene Rico

Associate 

Administrator 

for Civil 

Rights

0340 SES

202-

366-

0693

Irene.Ri

co@dot.

gov

Affirmative 

Employment 

Program 

Manager

Nikisha M. 

Bennett

Internal EEO 

and Special 

Emphasis 

Program 

Manager

0360 GS-14 

202-

366-

3894 

Nikisha.

Bennett

@dot.go

v
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FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

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EEO Program 

Staff Name Title Occupational Series

Pay 

Plan 

and 

Grade

Phone 

Number

Email 

Address

Complaint 

Processing 

Program 

Manager

Nikisha M. 

Bennett

Internal EEO 

and Special 

Emphasis 

Program 

Manager

0360 GS -

14 

202-

366-

3894 

Nikisha.

Bennett

@dot.go

v

Diversity & 

Inclusion 

Officer

Shakira 

Crandol 

Chief DEI 

Officer 0340 GS15 

202-

366-

6731 

Shakira.

Crandol

@dot.go

v

Hispanic 

Program 

Manager 

(SEPM)

Nikisha M. 

Bennett

Internal EEO 

and Special 

Emphasis 

Program 

Manager

0360 GS-14 

202-

366-

3894 

Nikisha.

Bennett

@dot.go

v

Women's 

Program 

Manager 

(SEPM)

Nikisha M. 

Bennett

Internal EEO 

and Special 

Emphasis 

Program 

Manager

0360 GS-14 

202-

366-

3894 

Nikisha.

Bennett

@dot.go

v

Disability 

Program 

Manager 

(SEPM)

Kirsten 

Poston 

Disability 

Policy 

Analyst 

0301 GS-13 

202-

559-

5116 

Kirsten.

Poston

@dot.go

v

Special 

Placement 

Program 

Coordinator 

(Individuals 

with 

Disabilities)

Allen 

Milham

Program 

Analyst 0343 GS-11 

202-

493-

5238 

Allen.M

ilham@

dot.gov

Reasonable 

Accommodation 

Program 

Manager

Kirsten 

Poston 

Disability 

Policy 

Analyst 

0301 GS-13 

202-

559-

5116 

Kirsten.

Poston

@dot.go

v

AntiHarassment 

Program 

Manager

Pamela 

McCormick

AntiHarassment 

Coordinator 

0301 GS-13 

202-

366-

0693 

Pamela.

McCor

mick@d

ot.gov
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EEO Program 

Staff Name Title Occupational Series

Pay 

Plan 

and 

Grade

Phone 

Number

Email 

Address

ADR Program 

Manager

Nikisha M. 

Bennett

Internal EEO 

and Special 

Emphasis 

Program 

Manager

0360 GS-14 

202-

366-

3894 

Nikisha.

Bennett

@dot.go

v

Compliance 

Manager

Nikisha M. 

Bennett

Internal EEO 

and Special 

Emphasis 

Program 

Manager

0360 GS-14 

202-

366-

3894 

Nikisha.

Bennett

@dot.go

v

Part D.1 – List of Subordinate Components Covered in this Report

 If the agency does not have any subordinate components, please check the box. 

Subordinate Component 

Division Office – The FHWA has a 

Division office in each of the 50 states, the 

District of Columbia and Puerto Rico.

City State Agency 

Code

FIPS

Code

Alabama Division Office Montgomery AL TD04 12130101 

Alaska Division Office Juneau AK TD04 21130110 

Arizona Division Office Phoenix AZ TD04 40370013 

Arkansas Division Office Little Rock AR TD04 52320119 

California Division Office Sacramento CA TD04 63150067 

Colorado Division Office Lakewood CO TD04 81435059 

Connecticut Division Office Hartford CT TD04 90255003 

Delaware Division Office Dover DE TD04 100130001 

District of Columbia Division Office Washington DC TD04 110010001 

Florida Division Office Tallahassee FL TD04 122940073 

Georgia Division Office Atlanta GA TD04 130280089 

Hawaii Division Office Honolulu HI TD04 152400003 

Idaho Division Office Boise ID TD04 160160001 

Illinois Division Office Springfield IL TD04 178220167 

Indiana Division Office Indianapolis IN TD04 182210097 

Iowa Division Office Ames IA TD04 190230169 

Kansas Division Office Topeka KS TD04 205400177 

Kentucky Division Office Frankfort KY TD04 211220073 

Louisiana Division Office Baton Rouge LA TD04 220150033 

Maine Division Office Augusta ME TD04 230160011 

Maryland Division Office Baltimore MD TD04 240050510 

Massachusetts Division Office Cambridge MA TD04 250170017 

Michigan Division Office Lansing MI TD04 262700037 

Minnesota Division Office St. Paul MN TD04 276330123 
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Subordinate Component 

Division Office – The FHWA has a 

Division office in each of the 50 states, the 

District of Columbia and Puerto Rico.

City State Agency 

Code

FIPS

Code

Mississippi Division Office Jackson MS TD04 281220049 

Missouri Division Office Jefferson City MO TD04 294040027 

Montana Division Office Helena MT TD04 300590049 

Nebraska Division Office Lincoln NE TD04 312830109 

Nevada Division Office Carson City NV TD04 320050510 

New Hampshire Division Office Concord NH TD04 330070013 

New Jersey Division Office West Trenton NJ TD04 343380021 

New Mexico Division Office Santa Fe NM TD04 350710049 

New York Division Office Albany NY TD04 360050001 

North Carolina Division Office Raleigh NC TD04 373750183 

North Dakota Division Office Bismarck ND TD04 380370015 

Ohio Division Office Columbus OH TD04 391800049 

Oklahoma Division Office Oklahoma 

City OK TD04 403550017 

Oregon Division Office Salem OR TD04 411810047 

Pennsylvania Division Office Harrisburg PA TD04 423500043 

Puerto Rico Division Office San Juan PR TD04 72-127 

Rhode Island Division Office Providence RI TD04 440190007 

South Carolina Division Office Columbia SC TD04 450520063 

South Dakota Division Office Pierre SD TD04 462160065 

Tennessee Division Office Nashville TN TD04 471760037 

Texas Division Office Austin TX TD04 480330453 

Utah Division Office Salt Lake City UT TD04 491700035 

Vermont Division Office Montpelier VT TD04 500380023 

Virginia Division Office Richmond VA TD04 512060760 

Washington Division Office Olympia WA TD04 531590067 

West Virginia Division Office Charleston WV TD04 540480039 

Wisconsin Division Office Madison WI TD04 552780025 

Wyoming Division Office Cheyenne WY TD04 560100021 

Federal Lands Highway Division Offices TD04 110010001 

Part D.2 – Mandatory and Optional Documents for this Report

In the table below, the agency must submit these documents with its MD-715 report.

Did the agency submit the 

following mandatory 

documents?

Please 

respond 

Yes or No

Comments

Organizational Chart YES

EEO Policy Statement YES
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Did the agency submit the 

following mandatory 

documents?

Please 

respond 

Yes or No

Comments

Strategic Plan YES

Anti-Harassment Policy and 

Procedures YES

Reasonable Accommodation 

Procedures YES

The Departmental Office of Civil Rights 

submits this document on behalf of the 

Department.

Personal Assistance Services 

Procedures YES

The Departmental Office of Civil Rights 

submits this document on behalf of the 

Department.

Alternative Dispute Resolution 

Procedures YES

The Departmental Office of Civil Rights 

submits this document on behalf of the 

Department.

In the table below, the agency may decide whether to submit these documents with its MD-715 

report.

Did the agency submit the 

following optional documents?

Please 

respond 

Yes or No

Comments

Federal Equal Opportunity 

Recruitment Program (FEORP) 

Report 

YES

Disabled Veterans Affirmative 

Action Program (DVAAP) Report YES

Operational Plan for Increasing 

Employment of Individuals with 

Disabilities under Executive Order 

13548 

YES The Departmental Office of Civil Rights 

will provide this plan. 

Diversity and Inclusion Plan under 

Executive Order 13583 YES

Diversity Policy Statement YES

Human Capital Strategic Plan YES

The Departmental Office of Human 

Resource Management will provide this 

plan. 
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Did the agency submit the 

following optional documents?

Please 

respond 

Yes or No

Comments

EEO Strategic Plan NO

Results from most recent Federal 

Employee Viewpoint Survey or 

Annual Employee Survey 

YES

FHWA conducts an All-Employee 

Survey every 2 years in addition to 

OPM’s Federal Employee Viewpoint 

Survey (FEVS).

Part E – Executive Summary

All agencies must complete Part E.1; however, only agencies with 199 or fewer employees in 

permanent FT/PT appointments are required to complete Part E.2 to E.5. Agencies with 200 or 

more employees in permanent FT/PT appointments have the option to complete Part E.2 to E.5. 

Part E.1 – Executive Summary: Mission

The Federal Highway Administration (FHWA) submission of the annual Equal Employment 

Opportunity Program Status Report for Fiscal Year 2021 (FY 21) Management Directive 715 

report and plan was prepared in accordance with the U.S. Equal Employment Opportunity 

Commission laws and authority governed under Section 717 of the Civil Rights Act of 1964, as 

amended; and Section 501 of the Rehabilitation Act of 1973, as amended. This report highlights 

FHWA’s accomplishments in establishing and maintaining a model Equal Employment 

Opportunity (EEO) Program for FY 21. 

The FHWA is an Operating Administration within the U.S. Department of Transportation (DOT) 

that supports State and local governments in the design, construction, and maintenance of the 

Nation’s highway system (Federal-aid highway program) and various Federal and Tribal owned 

lands (Federal Lands Highway Program). Through financial and technical assistance to State 

departments of transportation, local governments, Federal agencies, and Tribal governments, 

FHWA is responsible for ensuring that America’s roads and highways continue to be among the 

safest, most technologically sound, and equitable in the world. 

The top-level official of FHWA is the Administrator, who reports directly to the Secretary of 

DOT. The FHWA organizational structure includes a Washington D.C. Headquarters with 14 

program offices, 3 Federal Lands Highway Division Offices, and 52 Federal-aid Division Offices 

(one in every state, the District of Columbia, and Puerto Rico). 

The FHWA’s mission is to “enable and empower the strengthening of a world-class highway 

system that promotes safety, mobility, and economic growth, while enhancing the quality of life 

of all Americans.”

Part E.2 – Executive Summary: Essential Element A – E 

Element A – Demonstrated Commitment from Agency Leadership

The FHWA continues to commit to the principles of EEO and maintaining a successful EEO 

Program. This commitment continues to be demonstrated throughout the Agency’s hierarchy 
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from senior executives, managers, and supervisors to all employees. Efforts to demonstrate this 

commitment include the following:

• Status of the Agency’s MD-715 is provided to senior leadership on an annual and 

ongoing basis. 

• Senior leaders support, encourage, and participate in monthly observances and events 

• Senior leadership participates in annual training sessions such as Anti-Harassment 

Training. 

The annual Administrator’s Awards Program has an award category, “Diversity and Inclusion 

Award” dedicated to giving recognition to individuals and/or teams for their significant 

contributions to EEO, Civil Rights, and Diversity and Inclusion while advancing the 

Administrator’s commitment to maintaining a high performing organization. 

On February 24, 2021, Stephanie Pollack was named Acting Administrator of FHWA. In this 

role, Ms. Pollack provides executive leadership and strategic direction within FHWA to advance 

goals and priorities of the Department, provides direction to a 2,700-person Agency, and 

oversees an annual budget over $70 billion. 

The selection of FHWA’s Executive Director Tom Everett was announced on October 22, 

2018. As Executive Director, Mr. Everett manages the Agency’s daily operations and its 

personnel, and advises the Administrator, Deputy Administrator, and senior officials throughout 

DOT. 

Senior Leadership demonstrates their commitment to advancing a model EEO Program through 

their participation in FHWA’s Diversity Management Committee Women’s Forum series, 

engaging with Employee Resource Groups, participating at the Agency’s EEO Virtual 

Awareness Symposium, setting expectations for the Anti-Harassment Program, supporting 

Special Emphasis programs, supporting equity based initiatives through the Department, and 

establishing the Diversity, Equity, Inclusion Officer position within the Agency. 

All Employee Survey Updates

Since the early 1990’s, FHWA has been conducting the “FHWA All Employee Survey 

(AES).” The FHWA AES originally was conducted on an annual basis, and when the Office of 

Personnel Management (OPM) began conducting the Federal Employee View Point Survey 

(FEVS) on an annual basis the FHWA AES started to be conducted only in the odd years. 

The FHWA AES in FY 21 had 2,153 employees who shared their thoughts and provided 

feedback. FHWA Headquarters led the way with a 97% response rate overall; 36 division 

offices had a response rate of 90% or above, and 23 of those offices reported at 100%. The 

number of respondents and participation rates from primary groups in the Agency are shown 

below.

FHWA Headquarters 627/648 97%

Office of Transportation Workforce Development and 

Technology 

123/145 85% 
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Federal-aid Division Offices 896/963 93% 

Federal Lands Highway 486/683 71% 

Based on the results of the survey, the Human Resources Management Committee (HRMC) will 

create an action plan to address lower scoring items. The action plan will include objectives that 

address the needs across the Agency in different offices. Each objective will have a champion. 

The HRMC compiles a status of the actions twice a year to present to Agency leadership. The 

HRMC action plan is released to Agency staff. The HRMC offers listening sessions to increase 

input on employee concerns. 

Element B – Integration of EEO in the Agency’s Strategic Mission

The FY 19-22 FHWA Strategic Plan outlines the preceding Administration’s goals and 

objectives for FHWA and superseded the previous FHWA Performance Year 2018/19 Strategic 

Implementation Plan. The FY 19-22 FHWA Strategic Plan was developed to align FHWA 

efforts with the FY 18-22 DOT Strategic Plan and reflects the priorities of Agency leadership. In 

the FY 18-22 DOT Strategic Plan, one of the goals was Accountability, which had been adopted 

from the DOT Strategic Plan: 

Under Accountability: Management Objective 2- Mission Efficiency and Support. Strategies 

“Workforce: Attract, develop, and retain employees who have the capabilities and competencies 

to help the Department achieve its goals.” 

The Agency has determined enterprise activities each year and equity serves as a critical 

enterprise activity for the Agency. Each unit within the Agency is tasked to develop and 

implement activities that are centered around incorporating equity into workforce, program 

delivery, and project management efforts. The FHWA will revamp its Strategic Plan to continue 

to address equity, diversity, and inclusion. The Agency is expected to publish the FY 22-26 

FHWA Strategic Plan in FY 22. 

To improve the efficiency and effectiveness of the organization, FHWA/DOT continues to 

recruit, hire, and retain employees from all segments of American society with the right skills 

and provide the training and professional development opportunities they need to help DOT 

successfully achieve its goals and to consider equity in workforce activities. 

The Agency conducted a wide variety of programs and activities as outlined in the Unit 

Performance Plans during the reporting period that reflect leadership commitment: 

• The Associate Administrator for the Office of Civil Rights has the authority and 

resources to effectively deliver a successful EEO Program and leads the day-to-day 

FHWA Civil Rights operations and reports to the Agency’s Executive Director. The 

FHWA Office of Civil Rights provides technical guidance in the implementation of EEO 

programs at the national level including the development of action plans as required by 

MD-715 and EEOC guidance. 

• In our effort to gather disability data, FHWA continued its efforts to resurvey the 

workforce resulting in an increased number of employees completing the revised SelfIdentification of the Workforce Standard Form (SF-256 form). All employees were 
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encouraged to self-identify or update their information using descriptions from OPM’s 

Self-Identification of Disability through their Employee Express system account. All 

disability codes have been updated in the HR information system, therefore, increasing 

the Agency’s PWD and PWTD population. 

• FHWA continued to implement FHWA’s Anti-Harassment Process.

• FHWA Office of Civil Rights developed a Roadmap in FY 21 and created the FY 22 – 26 

Roadmap, a strategic and budgetary plan, to reflect upon the activities to support 

diversity, equity, inclusion, and accessibility initiatives. 

• FHWA promoted programs that engage employee participation in committees that 

support efforts to improve FHWA as an organization. 

• Employees are encouraged in their technical field/discipline to enhance knowledge 

management throughout the Agency and support closing competency gaps through 

discipline learning and development. 

• TFHWA continues to promote a culture that recognizes employee contributions using 

informal and formal recognition programs at the local and national level. 

• Diverse pipeline recruitment initiatives included the Professional Development Program, 

Rotational Developmental Assignment Clearinghouse, and expanded Career 

Development Programs. 

Element C – Management and Program Accountability 

The FHWA’s employees received updated training on EEO, Prevention of Harassment, and 

Reasonable Accommodations through the FHWA Office of Civil Rights. The FHWA’s Office 

of Civil Rights Website includes details related to Anti-Harassment, EEO, and Prevention of 

Harassment. It provides an overview of each section, laws, points of contact, and other 

resources. https://www.fhwa.dot.gov/civilrights/. 

The Office of Human Resources sponsored a Webinar on Federal Hiring Authorities including 

providing information on Schedule A hiring authorities on January 13, 2021, for its corporate 

recruiters.

The Human Resources Employee Relations staff and staff of the Office of Chief Counsel 

continued to work closely with both the FHWA Civil Rights Disability Program Manager, to 

support the reasonable accommodations program throughout our workforce, and the AntiHarassment Coordinator, to respond to complaints of harassment. 

Reasonable Accommodations and Disability Program 

The FHWA’s Disability Program Manager continues to work collaboratively with the 

Departmental Disability Resource Center to timely process and track reasonable accommodation 

requests and, additionally, to provide technical assistance and training to managers, supervisors, 

and team leaders on the Reasonable Accommodation Process. 

Several virtual technical assistance sessions were held with FHWA managers and employees 

during the fiscal year to ensure managers were familiar with the policies and procedures. In 

February 2021, a memo was distributed to all employees informing them of a guidance 

document for accessible virtual events for individuals with disabilities
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In recognition of DOT’s FY 21 National Disability Employment Awareness Month, FHWA 

sponsored webinars on Assistive Technology and Section 508. More than 60 

Managers/Supervisors participated in the Webinar.

Religious Accommodations 

The Office of Civil Rights worked with the Departmental Office of Civil Rights to develop 

policy documents and training on religious accommodations. This effort continues in FY 22. 

Accessibility and 508 Compliance 

The Agency held several training sessions in July 2021 with the disability community to 

establish a long term contract for relay conference captioning. The FHWA conducted a market 

research and identified entities who were qualified to provide the service. Final contract details 

were worked out in FY 22. 

The Agency held over 42 sessions for employees and managers in the area of 508 compliance 

from June to November 2021. 

Special Emphasis Programs 

The FHWA Office of Civil Rights continues to utilize Special Emphasis Programs and engages 

with Employee Resource Groups to increase employees’ awareness of the importance of 

diversity and to demonstrate the Agency’s commitment as a model EEO workplace. The 

Agency has continued to host a series of Webinars that were intended to educate the workforce 

about the different Employee Resource Groups within the Agency. 

In FY 21, FHWA leadership championed, and the FHWA Office of Civil Rights disseminated, 

positive messaging recognizing and honoring monthly observances and virtually hosted, with the 

support of Employee Resource Groups, the following DOT Special Emphasis Program Events: 

• African American History Month: On February 25, 2021, an outreach session was held 

for college students and FHWA employees on Driving Power Connection with a New 

Generation. 

• Women’s History Month: In honor of 2021 Women’s History Month, a dynamic Women 

in Transportation panel discussion on Experiences & Challenges of Women in the 

Workplace was held and a presentation was provided on Women Representation in the 

FHWA Workforce: 80’s and Beyond on March 18, 2021. Additionally, the Office of 

Civil Rights held focus group discussion throughout March and April 2021 to initiate 

conversations with women employees within the FHWA to provide an opportunity for 

women to voice their concerns with challenges and deficiencies within our organization 

as well as to recommend strategies to improve recruitment, hiring, training/development, 

promotions, and separation disparities as they relate to women. 

• Asian American and Pacific Islander Heritage Month: On May 26, 2021, the FHWA 

Office of Civil Rights invited FHWA employees to participate in the 2021 virtual DOT, 

2020 Asian American and Pacific Islander Heritage Month panel discussion with 

employees within FHWA, Federal Transit Administration as well as the Chair from 

DOT’s Asian Pacific Employees Council ERG on celebration Advancing Leaders 

Through Purpose-Driven Service. 
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• Lesbian, Gay, Bisexual, Transgender and Queer+ Pride Month: Pride month event “You 

Are Included” was held on June 29, 2021. We also had Mahri Monson, a Federal 

LGBTQ+ employee resource group leader who also works in OPM’s Office of Diversity, 

Equity, Inclusion and Accessibility deliver a presentation on gender inclusivity. The 

workshop provided background on why employees should care about being inclusive of 

our gender non-binary and transgender colleagues. Research shows we learn best by 

doing, so the workshop included several opportunities for practicing their new skills in a 

small group setting. Participants walked away with greater understanding of gender 

inclusivity, an enhanced vocabulary, and concrete steps to take right away to contribute 

to increased inclusion in our organization. 

• Hispanic Heritage Month: On September 30, 2021, the FHWA employee resource group 

named the Assist, Motivate, Integrate, Guide and Orient (A.M.I.G.O.) Workgroup and 

the Office of Civil Rights hosted a Networking Event titled “Esperanza: A Celebration 

of Hispanic Heritage and Hope.” The event highlighted the AMIGO workgroup, 

Agency Hispanic initiatives, introduced Agency leadership with Hispanic backgrounds, 

and celebrated Hispanic culture through trivia, sharing stories, and recipes. 

• National American Indian Heritage Month: On November 23, 2021, an event titled 

“Together Towards Tomorrow” was arranged by the FHWA’s Office of Tribal 

Transportation on the Tribal Transportation Program and the importance of this office 

when it comes to partnering with Tribal Nations. In addition, we had a guest speaker, 

Maiya Rainer from California State Parks, share historical information on the Yurok 

people in North Coast, California as well as share her lived experiences. 

Prevention of Harassment Program (Anti-Harassment)

The Agency held four all employee sessions on Respectful Workplace and four sessions on 

Leading for Respect (managers only). These sessions were part of the 2021 annual Prevention of 

Harassment training and both trainings were offered through Microsoft Teams to allow for 

virtual participation.

Targeted Recruitment and Outreach Efforts 

In FY 21, the FHWA has continued to build upon the revamped Corporate Recruitment efforts to 

address the low representation of women, Hispanic women, and individuals with disabilities in 

the FHWA workforce. The FHWA attended recruitment and outreach events designed to 

provide access to targeted audiences from these populations and other groups with low 

participation rates. The events included the following: 

• 118 virtual career fairs with universities and organizations

• 16 virtual career fairs hosted by Historically Black Colleges and Universities (HBCU) 

• 18 virtual career fairs hosted by Hispanic Serving Institutions (HSI) 

• 9 virtual career fairs targeting female professionals

• 7 virtual career fairs targeting persons with disabilities

• 5 virtual career fairs targeting military and veterans

The FHWA utilized a variety of recruitment resources, including online services; job postings; 

social media; the Workforce Recruitment Program Database; OPM Shared List of People with 

Disabilities Database; state and local vocational rehabilitation agencies and employment offices; 

educational institutions, colleges, and universities; USAJOBS; and the USAJobs Agency Talent 
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Portal to attract people with disabilities to FHWA job opportunities. The FHWA’s Office of 

Human Resources also partnered with groups and employees throughout the Agency to deliver 

virtual employment workshops to the public to educate them about the Agency and attract 

prospective candidates to apply to open announcements. The FHWA vacancy announcements 

continue to be marketed on free recruitment sites to increase the visibility in those specific 

communities. 

Education/Outreach on Schedule A

The FHWA’s Office of Human Resources hosted several one-on-one consultative sessions with 

hiring managers to discuss various staffing and recruitment initiatives which included different 

hiring authorities. Staffing specialists continue to educate hiring managers on special hiring 

authorities while developing recruitment packages. 

The Office of Civil Rights offered employee webinars on Schedule A hiring authorities and other 

topics such as the Reasonable Accommodation process that increased the awareness of actions 

Federal hiring managers could take to increase and maintain a diverse workforce within the 

Agency. 

Addressing Generational Diversity

The FHWA continues to employ an advisory group called the Innovation Exchange (iExchange), 

a multi-generational forum focused on exchanging ideas and inspiring innovation. While 

promoting and facilitating generational diversity, the iExchange creates an environment that 

welcomes members and encourages the overall diversity of the Agency. Sponsored by the 

Knowledge Management (KM) unit, the iExchange expanded its membership to over 250 

employees. Over the course of FY 21, the advisory group held a virtual speed networking event 

and continued to work with FHWA offices, committees, and councils to provide ideas and a 

fresh perspective.

Element D – Proactive Prevention of Unlawful Discrimination 

Throughout FY 21, the Office of Civil Rights’ Anti-Harassment, EEO, and Reasonable 

Accommodations Program Managers coordinated and conducted a series of virtual AntiHarassment, EEO, and Reasonable Accommodations training sessions to FHWA offices. 

The training sessions’ aim was to ensure employees were familiar with the anti-harassment, 

EEO, and Reasonable Accommodation processes within FHWA. The virtual training sessions 

were well received and future plans to expand the sessions to cover all FHWA offices is 

currently in the works for FY 22. 

Since the December 18, 2019 rollout of the final FHWA Anti-Harassment Process to comply 

with the DOT Policy Framework, the Agency continues to perform regular outreach to 

employees and managers on the Anti-Harassment Process. On March 12, 2021, information on 

the Anti-Harassment Process was part of the civil rights session that the Office of Civil Rights 

hosted for all field leaders. This training was geared towards Division Administrators and 

Deputy Division Administrators so that they understand the process. FHWA has revamped the 

Agency’s website and updated the current process 

https://www.fhwa.dot.gov/civilrights/programs/AntiHarassment/resources.cfm. 
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In February 23 – 25, 2021, the Agency hosted its first annual EEO symposium. During this 

symposium, there were two sessions on Prevention of Harassment topics for all employees. 

These sessions were as follows:

• Which Lane Are You In? Panel - Session providing an overview of the Anti-Harassment, 

EEO, Reasonable Accommodation, Grievance, and ADR paths that an employee may 

take to address workplace concerns. 

• Fearless Communication - How Psychological Safety Improves Conversations. 

On May 13, 2021, the Agency hosted a training called “What Happens Next after an AntiHarassment Complaint in a Workplace?”. This session was held for managers only and the 

presenters were from the Departmental Office of Civil Rights. 

 

The Office of Civil Rights and the Office of Human Resources partnered to provide training on 

the Alternate Dispute Resolution, Anti-harassment, EEO, and Employee Relations processes 

during the February 2021 EEO Virtual Awareness Symposium. 

Diversity Management Committee 

The FHWA continued to utilize its 19-member Diversity Management Committee (DMC or 

committee) to cultivate and advance several initiatives designed to improve organizational 

culture and raise awareness on the importance of having a diverse and inclusive organization. 

Furthermore, the committee collaborated with HR to develop a Diversity Hiring Guide for Hiring 

Managers. The Diversity Hiring Guide for Hiring Managers offers consolidated tactics and 

strategies that can work to reduce the effects of bias throughout the planning, recruitment, 

evaluation, and selection process. 

The DMC also continued its Women’s Forum Webinar series which is designed to foster greater 

interaction among female employees at all levels of the Agency. The committee conducted two 

webinars with the aim of providing a safe and engaging discussion platform for all employees to 

network with each other and address issues of common interest, such as career growth, 

mentoring, professional development, and identifying challenges in the workplace especially 

those impacting women. 

With the Agency’s diversity education goals in mind, the DMC also identified several training 

modules available in DOT Learns that teach the principles of diversity and inclusion. The 

committee was able to identify two modules that address diversity and the benefits of inclusion, 

while providing a better understanding of how unconscious bias can undermine our efforts to be 

inclusive. The FHWA added the courses to all employees’ DOT Learns learning plans and 

encouraged them to take the courses. Nearly a third of our workforce have taken one or more of 

the training modules. 

In an effort to improve cultural awareness, the DMC also created a monthly Diversity Awareness 

newsletter which highlights a wide range of observances and traditions that acknowledge unique 

segments of our population. Furthermore, the DMC decided to build from last year’s effort to 
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capture all of the Departmental Employee Resource Groups within a distribution list and added 

the listing to the New Employee Orientation Program. 

The DMC also continued its role in conducting diversity presentations at a large number of 

requesting program offices. In a year marked by one of the greatest social justice movements in 

history, the DMC and its Diversity Program Manager conducted 14 conversations centered 

around race. Three of the sessions were Agency-wide corporate sessions that garnered attendee 

counts ranging from 250 to 300 employees. 

Element E – Efficiency

In FY 21, FHWA timely submitted to the EEOC the Annual Federal EEO Statistical Report of 

Discrimination Complaints (EEOC Form 462) and the Annual Notification and Federal 

Employee Anti-discrimination and Retaliation Act of 2002 (No FEAR Act) report. Furthermore, 

FHWA submitted its annual FEEORP to OPM in December 2021. 

The FHWA continues to ensure that all EEO policies were prominently posted in all personnel 

offices, employee bulletin boards, and on the FHWA Civil Rights Website. All policies related 

to anti-discrimination laws, Civil Rights, the EEO complaint process, Departmental Reasonable 

Accommodations policies and ADR have been posted on the FHWA Website. 

Element F – Responsiveness and Legal Compliance

The FHWA continues to maintain the goal of full compliance with all EEO statutes, regulations, 

policy guidance, and other written instructions. All Agency personnel are held accountable for 

timely compliance with orders issued by the EEOC. Plans for addressing newly identified gaps 

from prior fiscal years are further discussed in Part H of this report.

Part E.3 – Executive Summary: Workforce Analyses

As of September 30, 2021, FHWA onboard strength showed a total of 2,726 employees, of 

whom 2,722 were permanent employees and 4 were temporary employees. 

The FHWA is starting to see improvements in targeted areas. In FY 21, FHWA exceeded its 

goal of 12% of hires of PWD and its 2% goal of PWTD onboard. In FY21, approximately 

17.28% of all new hires were PWD, and 3.09% were PWTD. Overall, PWTD comprise 2.93% 

of the total FHWA workforce, which was slightly higher than the 2.75% reported for FY 20 

(This number includes hires from other DOT modes, and therefore is not demonstrated by the 

workforce tables).

Veterans with 30% or more disability represent 6.8% of all hires and make up 3.85% of the total 

workforce. 

The FHWA reports out the following regarding the overall diversity of its workforce between FY 

10 and FY 21: 

(1) Hispanics in FHWA’s permanent workforce had a slight increase from 8.95% to 9.55% this 

included 3.38% Hispanic females and 6.17% Hispanic males 
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(2) Black or African Americans in the permanent workforce had a slight increase from 15.06% to 

15.69%; this included 8.82% Black or African American females and 6.87% African American 

males

(3) PWD had a slight increase from 10.78% to 11.57% of the FHWA permanent workforce. 

(4) PWTD had a slight decrease from 3.06% to 2.90% of the FHWA permanent workforce. 

* This number is inclusive of hires from other DOT modes and is not accounted for in the 

workforce tables.

Although FHWA continues to be successful in its efforts to diversify its workforce, the 

representation of persons with disabilities and female populations remains areas where FHWA is 

continuing to focus its efforts. In addition, FHWA will look to dive deeper into the workforce 

analysis in relation to hiring rate and separation rates of FHWA employees based upon race, 

gender, ethnicity, and disability demographics. These areas of improvement have been included 

in Part H and I of this report. 

Workforce Analysis Trends:

RNO FY 18 FY 19 FY 20 FY 21 2010 CLF 2014-2018 CLF 

Male 62.88% (1684) 62.58% 

(1679) 

62.78% 

(1737) 

62.29% 

(1698) 51.84% 51.79% 

Female 37.12% (994) 37.42% 

(1004) 

37.22% 

(1030) 

37.71% 

(1028) 48.16% 48.21% 

In reviewing the FY 21 workforce tables Table B4P analyzing whether FHWA met 

EEOC’s 2% and 12% goal onboarding Persons with Disabilities and Persons with 

Targeted Disabilities at the GS-1-10 and GS11-SES levels the following information was 

captured:

Grade Level Person with Disabilities

(12%) Person with Targeted Disabilities (2%)

GS 1-10 18.45% 6.64% 

GS 11-SES 10.81% 2.49% 

The FHWA’s FY 21 Ethnicity as it compares to the Civilian Labor Force:
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FY 21 FHWA Total Workforce - Distribution by Race/Ethnicity and Sex (Table A1)

FHWA Total Workforce - Distribution by Disability (Table B1) The following groups have 

participation rates that are above or equal to the 2010 CLF: The Hispanic Males CLF has 

increased from 2010 CLF to 2014-2018 CLF. It is noted that there is less than 1% difference 

between the benchmark (2014-2018 CLF) and FY 21 participation rates for Hispanic Males 

(6.16%), Two or More Races Males (0.40%), and Two or More Races Females (0.59%).

RNO/Disability FY 18 FY 19 FY 20 FY 21 2010 

CLF

2014- 

2018 

CLF

White Males 45.37% 44.63% 44.24% 42.88% 38.33% 35.65% 

Hispanic Males 5.23% 5.50% 5.75% 6.16% 5.17% 6.82% 

Black or African American 

Males 6.20% 6.28% 6.76% 6.86% 5.49% 5.70% 

Black or African American 

Females 8.81% 8.74% 8.78% 8.80% 6.53% 6.61% 

Asian Males 5.19% 5.32% 5.17% 5.39% 1.97% 2.19% 

Asian Females 2.50% 2.68% 2.86% 2.97% 1.93% 2.18% 

Native Hawaiian or Other 

Pacific Islander Males 0.15% 0.11% 0.11% 0.11% 0.07% 0.08% 

Two or More Races Males 0.15% 0.19% 0.25% 0.40% 0.26% 1.05% 

Two or More Races Females 0.37% 0.52% 0.51% 0.59% 0.28% 1.05% 

American

Indian or

Alaska

Native

Asian

Native

Hawaiian or

Other Pacific

Islander

Black or

African

American

Hispanic or

Latino

Two or

More Races White NonSpecified

FHWA 0.99% 8.36% 0.15% 15.66% 9.54% 0.55% 64.31% 0.30%

CLF 1.08% 3.90% 0.14% 12.02% 9.96% 0.54% 72.36%

0.99%

8.36%

0.15%

15.66%

9.54%

0.55%

64.31%

1.08% 0.30%

3.90%

0.14%

12.02% 9.96%

0.54%

72.36%

0%

10%

20%

30%

40%

50%

60%

70%

80%

FHWA Workforce: Ethnicity Compared to Civilian Labor Force

FY 21

FHWA CLF
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RNO/Disability FY 18 FY 19 FY 20 FY 21 2010 

CLF

2014- 

2018 

CLF

Persons with Targeted 

Disabilities* 2.88% 3.05% 2.75% 2.93% 2.00% (501 Goal) 

*Note: For Persons with Targeted Disabilities utilize the 501 Goal and not the CLF as the 

benchmark. 

FHWA Total Workforce - Distribution by Race/Ethnicity and Sex (Table A1)

FHWA Total Workforce - Distribution by Disability (Table B1) The following groups have 

a lower participation rate than the expected 2010 CLF: The White Females gap is 12.61% 

from the 2010 CLF making White Females the largest gap followed by Hispanic Females (1.42% 

from the 2010 CLF) and PWD (0.37% from the 2010 CLF). 

RNO/Disability FY 18 FY 19 FY 20 FY 21 2010 CLF 2014 - 

2018 CLF 

White Females 21.66% 21.53% 21.03% 21.42% 34.03% 31.82% 

Hispanic Females 3.25% 3.42% 3.54% 3.37% 4.79% 6.16% 

Native Hawaiian or 

Pacific Islander Female 0.04% 0.04% 0.00% 0.04% 0.07% 0.08% 

American Indian or 

Alaska Native Females 0.41% 0.52% 0.51% 0.51% 0.53% 0.31% 

American Indian or 

Alaska Native Males 0.52% 0.52% 0.51% 0.48% 0.55% 0.31% 

Persons with 

Disabilities* 9.97% 10.78% 10.84% 11.63% 12.00% (501 Goal) 

*Note: For Persons with Targeted Disabilities utilize the 501 Goal and not the CLF as the 

benchmark. 

FHWA Total Workforce: Women Overall and Hispanic Women: Hiring and Separation. 

The hiring rate of Hispanic females is trending down. Also, in FY 21 the separation rate of 

Hispanic women is higher than both the hiring rate and the total workforce of Hispanic women 

within FY 21. 

Workforce Indicators

Females Hispanic Females

FY 19 FY 20 FY 21 FY 19 FY 20 FY 21

Total Workforce (A1) 37.45% 37.22% 37.71% 3.42% 3.54% 3.37% 

2014- 2018 Civilian Labor Force 

(A1) 48.21% 6.16% 

Hiring Rate

(A1) 43.91% 36.79% 42.59% 4.78% 4.01% 0.62% 

Separation Rate 

(A1) 41.82% 38.81% 34.30% 1.82% 2.28% 3.38% 

Barrier Analysis Tables (FHWA Leadership Pipeline Analysis: GS 13 – SES) - See Part I 

for results.
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Barrier Analysis Tables (Awards) – The tables below demonstrate the analysis that was 

performed comparing the FHWA Workforce to the benchmarks. 

White

Females

GS-13

PWD

GS-13

PWTD

GS-13

Black Females

GS-14

Hispanic

Females

GS-14

Hispanic

Males

GS-14

PWD

GS-14

FHWA 19.14% 10.34% 1.15% 6.37% 2.32% 3.86% 7.92%

CLF 21.42% 12.00% 2.00% 8.82% 3.38% 6.17% 12.00%

19.14%

10.34%

1.15%

6.37%

2.32%

3.86%

7.92%

21.42%

12.00%

2.00%

8.82%

3.38%

6.17%

12.00%

0%

5%

10%

15%

20%

25%

Leadership Pipeline: GS 13 - GS 14 

(Groups Below Benchmark)

FHWA CLF

Asian

Males

GS-15

Black

Females

GS-15

Hispanic

Males

GS-15

PWD

GS-15

Asian

Females

SES

Asian

Males

SES

Hispanic

Males

SES

PWD

SES

PWTD

SES

FHWA 3.13% 6.25% 4.02% 9.38% 0.00% 2.00% 0.00% 0.00% 0.00%

CLF 5.40% 8.82% 6.17% 12.00% 2.94% 5.40% 6.17% 12.00% 2.00%

3.13%

6.25%

4.02%

9.38%

0.00%

2.00%

0.00% 0.00% 0.00%

5.40%

8.82%

6.17%

12.00%

2.94%

5.40% 6.17%

12.00%

2.00%

0%

2%

4%

6%

8%

10%

12%

14%

Leadership Pipeline: GS 15 - SES 

(Groups Below Benchmark)

FHWA CLF
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FHWA EEO Complaints Trends:

Over the past five years, from FY 17 to FY 21, the informal/pre-complaint and formal complaint 

filings ebbed and flowed. 

FY Informal Formal 

2017 15 5 

2018 11 11 

2019 12 8 

2020 15 14 

2021 11 8 

Top Five Issues Complaint Trends: 

Top Five Issues FY 17 FY 18 FY 19 FY 20 FY 21 

Harassment

3 

(NonSexual)

10 

(NonSexual)

7 

(NonSexual)

10 

(NonSexual)

6 

(5-Non-Sexual, 

1-Sexual)

Reasonable 

Accommodation 3 5 2 4 

Black 

Males

≤ $500

Asian 

Males

≤ $500

Hispan

ic

Males

$501 -

$999

Asian

Males

$501 -

$999

Black

Males

$1000

-

$1999

Black

Femal

es

$4000

-

$4999

Black

Males

$4000

-

$4999

Hispan

ic

Males

$4000

-

$4999

Asian

Males

$4000

-

$4999

Black 

Males

≥ 

$5000

Hispan

ic 

Males 

≥ 

$5000

Asian 

Males 

≥ 

$5000

Black

Males

QSI

Black

Femal

es

QSI

FHWA 5.12% 3.86% 3.80% 3.25% 4.66% 7.34% 4.89% 3.98% 3.36% 5.26% 3.68% 3.68% 5.26% 2.63%

Benchmark 6.87% 5.40% 6.17% 5.40% 6.87% 8.82% 6.87% 6.17% 5.40% 6.87% 6.17% 5.40% 6.87% 8.82%

5.12%

3.86% 3.80%

3.25%

4.66%

7.34%

4.89%

3.98%

3.36%

5.26%

3.68% 3.68%

5.26%

2.63%

6.87%

5.40%

6.17%

5.40%

6.87%

8.82%

6.87%

6.17%

5.40%

6.87%

6.17%

5.40%

6.87%

8.82%

0%

1%

2%

3%

4%

5%

6%

7%

8%

9%

10%

Cash Awards (including QSI))

(Groups Below Benchmark)

FHWA Benchmark
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Top Five Issues FY 17 FY 18 FY 19 FY 20 FY 21 

Disciplinary Action 2 5 5 

3 

(1-reprimand, 1-

suspension, 

1-discipline 

warning) 

Assignment of Duties 3 2 

Pay (Including overtime) 3 

Promotion/Non-Selection 2 5 2 

Performance 

Appraisal/Evaluation 2 2 5 3 

Time and Attendance 2 2 

Training 2 

*For FY 21, assignment of duties, promotion/non-selection, and time and attendance have the 

same number of complaints identifying these employment issues. 

Anti-Harassment Trends:

Anti-Harassment cases identified from FY18 to FY21. 

Fiscal Year Number of Anti-Harassment Cases

2018 2 

2019 3 

2020 10 

2021 12 

*Note: The Agency transitioned out of the pilot to a permanent process in FY 20: therefore, this 

may explain the increase in FY 20 and FY 21. 

Part E.4 – Executive Summary: Accomplishments

The FHWA makes EEO principles a fundamental part of its culture. Below is a summary of 

FHWA’s FY 21 accomplishments under the six essential elements 1) demonstrated commitment 

to EEO, 2) integration of EEO into DOT’s strategic mission,3) management and program 

accountability, 4) proactive prevention of unlawful discrimination, 5) efficiency and 

responsiveness, and 6) legal compliance:

• In FY 21, FHWA revamped its Organizational Manual to reflect the Administration’s 

priorities in relation to diversity, equity, inclusion, and accessibility. 

• In FY 21, Office of Civil Rights had 10 ancillary duty staff serving as Fact Finders within 

the Anti-Harassment Process. All new and experienced Anti-Harassment Fact Finders 

received the 32-hour Workplace Investigator’s training in FY 21. The training was 

attended by Fact Finders, Employee Relations staff, and the Office of Chief Counsel 

staff. 

• In FY 21, FHWA was recognized as a 2021 Top Supporter of HBCU’s by US Black 

Engineer & Information Technology Magazine. 

• In FY 21, FHWA hired 3.14% of people with targeted disabilities for the permanent 

workforce which was an increase from its FY 20 record of 2.72% hires. 
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• In FY 21, FHWA had three Schedule A Hires for Persons with Disabilities.

• In FY 21, FHWA had one Schedule A Hire for Persons with Targeted Disabilities.

• In FY 21, FHWA initiated the Emerging Leaders Externship Program. This pilot

program is geared towards HBCU college students and provides 6-week professional

development training in the area of mentoring, resume, and career outreach.

• In July 2021, FHWA drafted Reasonable Accommodations procedures to comply with

the DOT Order 1101.1B. The procedures outline roles and responsibilities of Agency

supervisors, Disability Program Manager, and established the Designated Disability

Advisory Team.

• In FY 21, FHWA developed an Accessibility Memo to outline roles and responsibilities

of event organizers in the reasonable accommodation process. Training was provided to

the Office of Safety, Office of Operations, and Office of Policy to provide insight on the

memo.

• In FY 21, FHWA hosted an online virtual series of Prevention of Harassment training

sessions with the topic centered around Respect in the Workplace. A total of eight

sessions were held with approximately 300 FHWA employees participating in the

sessions.

• FHWA had no findings of discrimination by the Equal Employment Opportunity

Commission, the Merit Systems Protection Board, or the District Court in FY 21.

• Agency employees are educated and encouraged to participate in one or more of the 25

DOT Employee Resource Groups (ERGs).

• For ERGS where FHWA employees serve in a leadership capacity, the following

activities have been highlighted:

African American Leaders in Transportation (AALT)

o African American Leaders in Transportation (AALT) completed their charter that

provides a basic overview of AALT’s goals, mission, and structure. AALT’s

membership grew to over 130 members.

o AALT met with Secretary Pete Buttigieg and the OST Office of Civil Rights to

provide an introduction on FHWA’s AALT and its mission.

o AALT reorganized the AALT structure, merging/creating the following

committees: Recruitment, Professional Development/Mentoring, Succession

Planning and Communications.

o AALT completed a White Paper titled “Enhancing Competition for Leadership

Rotational Assignments”

o AALT held three Webinars:

 Driving a Power Connection to the next Generation. Recruitment

event to assist college students with their transition to the professional

world.

 Trailblazing your own path in FHWA. This Webinar provided

information on how to prepare for your next role in FHWA.

 Political Savvy Workshop. This Webinar provided techniques for

successful communications as a leader and as a peer.

o AALT participated in the Office of Civil Rights EEO Symposium. During that

event AALT provided an overview of the organization for staff and coordinated a

special session for college students.
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Hispanic Engagement Initiative/AMIGO Affinity Group

o Operations: Updated the Hispanic Outreach Roster (list of Amigo Volunteers, 

Amigo Recruiters list, Amigo Mentors list, etc.) and established the FHWA 

AMIGO Networking Outlook Email Distribution List and the AMIGO Teams 

Channel. 

o Networking subcommittee: Hosted two networking events (May 5 – Cinco de 

Mayo and September 30 – National Hispanic Heritage Month – focus was on 

mentoring and learning from FHWA Hispanic leaders). The Cinco de Mayo 

event had over 50 participants. The Hispanic Heritage event had several hundred 

as this was open to all USDOT. 

o Mentoring subcommittee: Developed a preliminary list of Hispanic leaders in 

the Agency that could serve as mentors. The next step will be to reach out to 

these individuals and see if they are interested in serving as mentors. Once the list 

is refined, the names will be shared with the AMIGO community. The group 

committee ask the community if anyone else is interested in becoming a mentor 

or a mentee and begin to make connections. The committee will also be 

developing strategies for mentoring activities once the connections are made. 

o Recruitment Subcommittee: Continuous coordination with HQ recruitment to 

participate in recruitment efforts, including virtual career fairs, and university 

presentations. 

 Attended 14 virtual career fairs to assist with recruitment in FY 21

 Virtual Presentation for the University of Texas at El Paso Engineering 

Student Leadership Council. 

 Attended the Florida International University Federal Government 

conference in July 2021. The committee were part of the 46 Federal 

agencies and 1,300 students and alumni that were in attendance. 

 Met with Hispanic Association of Colleagues and Universities (HACU) 

representatives to find engagement opportunities. Activities are currently 

being coordinated with FHWA HR. 

 As requested by Division DAs and DDAs who want to increase Hispanic 

representation in their offices, internal FHWA vacancies announcements 

are shared through the AMIGO Teams channel and with USDOT’s 

Hispanics in Transportation (HIT). 

 Developed a one-page FHWA talking points document with links to our 

application sites that can be used during virtual career fairs. 

Part E.5 – Executive Summary: Planned Activities

The following list identifies emphasis areas, activities and/or planned initiatives to address 

and/or correct program deficiencies in Parts H, I and J.

Strategic Planning & Agency Initiatives

• FHWA is developing a new Strategic Plan for FY 22-26. The new Strategic Plan 

includes equity, which elevates diversity, equity, inclusion, and accessibility, and will 

also incorporate measures and strategic objectives.
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• FHWA will continue to roll out joint technical assistance and training on EEO,

Reasonable Accommodations, Anti- Harassment, and Diversity & Inclusion to program

and field offices. As well as support the Department’s DEIA Strategic Plan.

• FHWA will continue to partner within DOT to recognize and identify monthly

observances and host various events to educate employees on cultural differences,

accomplishments, and contributions.

• FHWA’s goal is to have a Diversity Champion for each work unit, and the DMC will

continue in its recruitment of new members as existing members rotate off. As new

Champions and Committee members are added the DMC will sponsor an onboarding

training.

• In response to and in consideration of Executive Order 14035, FHWA has hired a new

Chief DEI Officer. Starting in FY 22, the Chief DEI Officer will work with interagency

leadership and partners to develop strategies to ensure that diversity, equity, and inclusion

are integrated into and contribute to the FHWA’s overall mission and strategic goals.

• In FY 22, FHWA enhanced its workforce analysis on participation rates for permanent

workforce (i.e., senior grade level, compensation and awards, management positions)

through utilizing the FY 21 Barrier Analysis team.

Recruitment, Hiring, & Outreach Efforts

• FHWA plans to continue to focus its recruitment efforts to support targeted outreach to

increase the number of women and Hispanic women. As well as persons with targeted

disabilities at all grade levels. By continuing efforts through career fairs and outreach

events as well as targeted email campaigns and social media groups.

• FHWA will continue to create an inclusive organizational environment by performing

outreach and remaining in close contact in working with our recruitment partners from

various associations and organizations that target or serve underrepresented groups, and

schools with targeted populations to tap into a diversified applicant pool for all job

vacancies while working with these organizations to ensure the success of our

recruitment program.

• FHWA will aim to continue its partnership with universities with a large disability

population to provide mock interview experiences for students who may be seeking

employment opportunities within FHWA’s pipeline programs.

• FHWA will continue to examine and review its recruitment and hiring practices to further

identify if there are barriers to underrepresented groups, particularly within the seven

mission critical occupations.

• FHWA will continue to be proactive in its efforts to market the Summer Transportation

Internship Program for Diverse Groups (STIPDG), Pathways Program, Dwight D.

Eisenhower Fellowship Program as well as the Professional Development Program (PDP)

amongst colleges and universities.

Training & Program Awareness Efforts

• FHWA Virtual EEO Awareness Symposium planned for FY 22. The symposium’s

purpose is to educate FHWA Management and Staff with a focus on EEO, Conflict

Resolution, Prevention of Harassment, and Effective Communication. The first annual

symposium was held over a 3-day time span from February 22-25, 2021.
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• FHWA will continue to identify new resources and programs for hiring managers that

highlight how to find diverse pools of talent for FHWA vacancy announcements as well

as how to communicate vacancy announcements to those diverse talent pools.

• FHWA developed and distributed a “Diversity Hiring Guide” for hiring managers. This

guide provides recommendations that aim to mitigate bias and offers resources that help

broaden applicant pools for job vacancies. The guide also makes diverse resume review

panels and interview panels a standard practice. In FY 22, the Agency will have a

session at the EEO Virtual Awareness Symposium that is centered around the Diversity

Hiring Guide. The FHWA Strategic Plan for FY 22-26 will include opportunities for

DEIA training for Agency staff.

• In partnership with the DOT Disability Resource Center, FHWA will offer education and

training about the DOT Disability Resource Center and how its services benefit FHWA’s

workforce.

• The Office of Administration will offer Unconscious Bias training for all managers and

supervisors. This 2.5-hour instructor-led online course is designed to give

Managers/Supervisors an introductory overview of Unconscious Bias including:

Identifying Bias, Learning the impacts of bias on performance and Discovering

techniques for cultivation connection.

• The FHWA Office of Civil Rights will develop a deliverable spreadsheet to modify the

approach to training for all managers and supervisors in the areas of EEO, ADR,

Prevention of Harassment Training, and Reasonable Accommodations.

Policy & Procedure Updates 

FHWA developed a draft Reasonable Accommodations Procedures and developed a draft 

Handbook that will be a tool for Managers to understand their role and responsibilities. The 

FHWA Office of Civil Rights also drafted checklists, sample letters, and one-page summaries for 

managers and employees. These resources were reevaluated based upon the new Departmental 

DOT Reasonable Accommodation Order. The plan is to issue the final version in FY 22. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

C FORM U.S. Equal Employment Opportunity Commission

715-01 FEDERAL AGENCY ANNUAL

PART F EEO PROGRAM STATUS REPORT

CERTIFICATION of ESTABLISHMENT of CONTINUING

EQUAL EMPLOYMENT OPPORTUNITY PROGRAMS

I, Irene Rico, Associate Administrator for Civil Rights am the

(Insert name above) (Insert official

title/series/grade above)

Principal EEO Director/Official for Federal Highway Administration

(Insert Agency/Component Name above)

The Agency has conducted an annual self-assessment of Section 717 and Section 501 programs against the essential elements

as prescribed by EEO MD-715. If an essential element was not fully compliant with the standards of EEO MD-715, a further

evaluation was conducted and, as appropriate, EEO Plans for Attaining the Essential Elements of a Model EEO Program, are 

included with this Federal Agency Annual EEO Program Status Report.

The Agency has also analyzed its work force profiles and conducted barrier analyses aimed at detecting whether any

management or personnel policy, procedure or practice is operating to disadvantage any group based on race, national origin,

gender or disability. EEO Plans to Eliminate Identified Barriers, as appropriate, are included with this Federal Agency Annual

EEO Program Status Report.

I certify that proper documentation of this assessment is in place and is being maintained for EEOC review upon request.

8/18/2022

Signature of Principal EEO Director/Official Date

Certifies that this Federal Agency Annual EEO Program Status Report is in compliance with EEO MD715.

August 30, 2022

Signature of Agency Head or Agency Head Designee Date

Page 26 of 103
Page 27 of 103 

MD-715 - PART G

Agency Self-Assessment Checklist

Essential Element A: Demonstrated Commitment from Agency Leadership

This element requires the agency head to communicate a commitment to equal employment opportunity and a discriminationfree workplace.

Measures

Compliance Indicator

A.1 - The agency issues an effective, up-to-date

EEO policy statement.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

A.1.a

Does the agency annually issue a signed and dated 

EEO policy statement on agency letterhead that 

clearly communicates the agency's commitment to 

EEO for all employees and applicants? If "yes", 

please provide the annual issuance date in the 

comments column. [see MD-715, II(A)]

YES

The Departmental Office of 

Civil Rights issued the annual 

DOT EEO Policy statements 

dated March 29, 2021 on behalf 

of the Department.

A.1.a.2

A.1.b

Does the EEO policy statement address all protected 

bases (age, color, disability, sex (including 

pregnancy, sexual orientation and gender identity), 

genetic information, national origin, race, religion, 

and reprisal) contained in the laws EEOC enforces? 

[see 29 CFR § 1614.101(a)]

YES New

Measures

Compliance Indicator

A.2 - The agency has communicated EEO policies

and procedures to all employees.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

A.2.a Does the agency disseminate the following policies 

and procedures to all employees:

A.2.a.1 Anti-harassment policy? [see MD 715, II(A)] YES

All existing employees have 

been provided a copy of the AH 

policy and an initiative is 

underway to provide additional 

tools to ensure new employees 

receive FHWA’s specific 

policies and procedures.

New
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Measures

Compliance Indicator

A.2 - The agency has communicated EEO policies

and procedures to all employees.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

A.2.a.2 Reasonable accommodation procedures? [see 29 

C.F.R § 1614.203(d)(3)] YES

FHWA uses the Department’s 

Reasonable Accommodation 

Policy

New

A.2.b

Does the agency prominently post the following 

information throughout the workplace and on its 

public website: 

A.2.b.1

The business contact information for its EEO 

Counselors, EEO Officers, Special Emphasis 

Program Managers, and EEO Director? [see 29 C.F.R 

§ 1614.102(b)(7)]

YES https://www.fhwa.dot.gov/civilr

ights/programs/eeo/ New

A.2.b.2

Written materials concerning the EEO program, laws, 

policy statements, and the operation of the EEO 

complaint process? [see 29 C.F.R § 1614.102(b)(5)] 

YES https://www.fhwa.dot.gov/civilr

ights/programs/eeo/ A.2.c

A.2.b.3

Reasonable accommodation procedures? [see 29 

C.F.R. § 1614.203(d)(3)(i)] If so, please provide the

internet address in the comments column.

YES

https://fhwa.dot.gov/civilrights/

programs/disability/resources.cf

m

A.3.c

A.2.c Does the agency inform its employees about the 

following topics: 

A.2.c.1

EEO complaint process? [see 29 CFR §§ 

1614.102(a)(12) and 1614.102(b)(5)] If "yes", please 

provide how often. 

YES Annually A.2.a

A.2.c.2 ADR process? [see MD-110, Ch. 3(II)(C)] If "yes", 

please provide how often. YES Annually New

A.2.c.3

Reasonable accommodation program? [see 29 CFR § 

1614.203(d)(7)(ii)(C)] If "yes", please provide how 

often. 

YES Annually New

A.2.c.4

Anti-harassment program? [see EEOC Enforcement 

Guidance on Vicarious Employer Liability for 

Unlawful Harassment by Supervisors (1999), § 

V.C.1] If "yes", please provide how often.

YES Annually New
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Measures

Compliance Indicator

A.2 - The agency has communicated EEO policies 

and procedures to all employees.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

A.2.c.5 

Behaviors that are inappropriate in the workplace and 

could result in disciplinary action? [5 CFR § 

2635.101(b)] If "yes", please provide how often. 

YES Annually A.3.b 

Measures

Compliance Indicator

A.3 - The agency assesses and ensures EEO 

principles are part of its culture.

Measure 

Met?

(Yes/No/NA)

Comments

New Compliance Indicator

Current 

Part G 

Questions

A.3.a

Does the agency provide recognition to employees, 

supervisors, managers, and units demonstrating 

superior accomplishment in equal employment 

opportunity? [see 29 CFR § 1614.102(a) (9)] If "yes", 

provide one or two examples in the comments section.

YES

The Agency has a Superior 

Achievement Award to honor 

employees that have made 

significant achievements in 

support of the EEO program. 

The Agency established a 

Diversity & Inclusion award in 

2017, and it is part of the 

Administrator’s Awards 

Program. The Department also 

has a Secretary’s Awards 

Program. 

There is a Secretary’s Award 

for Meritorious Achievement 

and the EEO/Affirmative 

Action Award which recognizes 

employees for contributions to 

the DOT’s Equal Employment 

Opportunity (EEO) Program of 

an outstanding and distinctive 

nature. FHWA employees have 

consistently been nominated for 

those honors.

New
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Measures

Compliance Indicator

A.3 - The agency assesses and ensures EEO 

principles are part of its culture.

Measure 

Met?

(Yes/No/NA)

Comments

New Compliance Indicator

Current 

Part G 

Questions

A.3.b 

Does the agency utilize the Federal Employee 

Viewpoint Survey or other climate assessment tools to 

monitor the perception of EEO principles within the 

workforce? [see 5 CFR Part 250] 

YES

Annually for FEVS and every 

two years for FHWA’s All 

Employee Survey 

New

Essential Element B: Integration of EEO into the agency's Strategic Mission 

This element requires that the agency's EEO programs are structured to maintain a workplace that is free from 

discrimination and support the agency's strategic mission.

Measures

Compliance Indicator

B.1 - The reporting structure for the EEO 

program provides the principal EEO official with 

appropriate authority and resources to effectively 

carry out a successful EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

B.1.a

Is the agency head the immediate supervisor of the 

person ("EEO Director") who has day-to-day control 

over the EEO office? [see 29 CFR §1614.102(b)(4)]

NO

The Associate Administrator 

for Civil Rights Reports to the 

Agency Executive Director who 

is the Agency’s top career 

employee.

B.1.a

B.1.a.1 

If the EEO Director does not report to the agency 

head, does the EEO Director report to the same 

agency head designee as the mission-related 

programmatic offices? If "yes," please provide the 

title of the agency head designee in the comments.

YES

The Associate Administrator 

for Civil Rights reports to the 

Executive Director. All 

Associate Administrators for all 

program offices in FHWA 

report to the Executive 

Director. The Executive 

Director is responsible for all 

workforce matters in the 

Agency. 

New
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Measures

Compliance Indicator

B.1 - The reporting structure for the EEO 

program provides the principal EEO official with 

appropriate authority and resources to effectively 

carry out a successful EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

B.1.a.2 

Does the agency's organizational chart clearly define 

the reporting structure for the EEO office? [see 29 

CFR §1614.102(b)(4)] 

YES B.1.d 

B.1.b 

Does the EEO Director have a regular and effective 

means of advising the agency head and other senior 

management officials of the effectiveness, efficiency, 

and legal compliance of the agency's EEO program? 

[see 29 CFR §1614.102(c)(1); MD-715 Instructions, 

Sec. I]

YES

The Associate Administrator 

for Civil Rights participates in 

monthly Leadership Meetings 

that provide briefings to the 

head of the agency. In addition, 

the Associate Administrator of 

Civil Rights provides regular 

briefings to the head of the 

agency on all areas of Civil 

Rights. 

B.2.a 

B.1.c 

During this reporting period, did the EEO Director 

present to the head of the agency, and other senior 

management officials, the "State of the agency" 

briefing covering the six essential elements of the 

model EEO program and the status of the barrier 

analysis process? [see MD-715 Instructions, Sec. I)] If 

"yes", please provide the date of the briefing in the 

comments column. 

YES

The Associate Administrator 

for Civil Rights and the MD 

715 preparer presented to the 

agency leadership the “State of 

the Agency” report on May 21, 

2021. 

B.2.b 

B.1.d 

Does the EEO Director regularly participate in seniorlevel staff meetings concerning personnel, budget, 

technology, and other workforce issues? [see MD715, II(B)]

YES New
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Measures

Compliance Indicator

B.2 - The EEO Director controls all aspects of the 

EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

New Compliance Indicator

Current 

Part G 

Questions

B.2.a

Is the EEO Director responsible for the 

implementation of a continuing affirmative 

employment program to promote EEO and to identify 

and eliminate discriminatory policies, procedures, 

and practices? [see MD-110, Ch. 1(III)(A); 29 CFR 

§1614.102(c)]

YES B.3.a

B.2.b 

Is the EEO Director responsible for overseeing the 

completion of EEO counseling [see 29 CFR 

§1614.102(c)(4)]

YES New

B.2.c 

Is the EEO Director responsible for overseeing the 

fair and thorough investigation of EEO complaints? 

[see 29 CFR §1614.102(c)(5)] [This question may 

not be applicable for certain subordinate level 

components.] 

N/A

FHWA is a sub-reporting unit 

and is not responsible for 

investigations. Investigations 

are handled by the 

Departmental Office of Civil 

Rights.

New

B.2.d 

Is the EEO Director responsible for overseeing the 

timely issuing final agency decisions? [see 29 CFR 

§1614.102(c)(5)] [This question may not be 

applicable for certain subordinate level components.] 

N/A

FHWA is a sub-reporting Unit 

and is not responsible for 

investigations. The 

Departmental Office of Civil 

Rights issues final agency 

decisions.

New

B.2.e 

Is the EEO Director responsible for ensuring 

compliance with EEOC orders? [see 29 CFR §§ 

1614.102(e); 1614.502]

YES

The Director ensures that 

reporting is done as requested 

by those orders.

F.3.b 

B.2.f 

Is the EEO Director responsible for periodically 

evaluating the entire EEO program and providing 

recommendations for improvement to the agency 

head? [see 29 CFR §1614.102(c)(2)]

YES New
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Measures

Compliance Indicator

B.2 - The EEO Director controls all aspects of the 

EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

New Compliance Indicator

Current 

Part G 

Questions

B.2.g 

If the agency has subordinate level components, does 

the EEO Director provide effective guidance and 

coordination for the components? [see 29 CFR §§ 

1614.102(c)(2) and (c)(3)] 

N/A

This function is handled by the 

Departmental Office of Civil 

Rights. 

New

Measures

Compliance Indicator

B.3 - The EEO Director and other EEO 

professional staff are involved in, and consulted 

on, management/personnel actions.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

B.3.a

Do EEO program officials participate in agency 

meetings regarding workforce changes that might 

impact EEO issues, including strategic planning, 

recruitment strategies, vacancy projections, 

succession planning, and selections for training/career 

development opportunities? [see MD-715, II(B)]

YES B.2.c & 

B.2.d

B.3.b 

Does the agency's current strategic plan reference 

EEO / diversity and inclusion principles? [see MD715, II(B)] If "yes", please identify the EEO 

principles in the strategic plan in the comments 

column. 

YES

FHWA strategic and 

performance planning efforts 

are aligned to the DOT 

Strategic Plan. In addition, 

FHWA has provided a list of 

objectives that include 

EEO/diversity and inclusion 

principles through the INPUT 

performance tracking system. 

(This information is provided as 

supplemental documentation to 

this report).

New
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Measures

Compliance Indicator

B.4 - The agency has sufficient budget and staffing 

to support the success of its EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

B.4.a

Pursuant to 29 CFR §1614.102(a)(1), has the agency 

allocated sufficient funding and qualified staffing to 

successfully implement the EEO program, for the 

following areas:

B.4.a.1 to conduct a self-assessment of the agency for 

possible program deficiencies? [see MD-715, II(D)] YES B.3.b

B.4.a.2 to enable the agency to conduct a thorough barrier 

analysis of its workforce? [see MD-715, II(B)] YES B.4.a 

B.4.a.3 

to timely, thoroughly, and fairly process EEO 

complaints, including EEO counseling, 

investigations, final agency decisions, and legal 

sufficiency reviews? [see 29 CFR § 1614.102(c)(5) & 

1614.105(b) - (f); MD-110, Ch. 1(IV)(D) & 5(IV); 

MD-715, II(E)]

YES E.5.b 

B.4.a.4 

to provide all supervisors and employees with 

training on the EEO program, including but not 

limited to retaliation, harassment, religious 

accommodations, disability accommodations, the 

EEO complaint process, and ADR? [see MD-715, 

II(B) and III(C)] If not, please identify the type(s) of 

training with insufficient funding in the comments 

column.

YES B.4.f & 

B.4.g 

B.4.a.5 

to conduct thorough, accurate, and effective field 

audits of the EEO programs in components and the 

field offices, if applicable? [see 29 CFR 

§1614.102(c)(2)]

YES E.1.c 

B.4.a.6 

to publish and distribute EEO materials (e.g., 

harassment policies, EEO posters, reasonable 

accommodations procedures)? [see MD-715, II(B)]

YES B.4.c 
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Measures

Compliance Indicator

B.4 - The agency has sufficient budget and staffing 

to support the success of its EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

B.4.a.7 

to maintain accurate data collection and tracking 

systems for the following types of data: complaint 

tracking, workforce demographics, and applicant 

flow data? [see MD-715, II(E)]. If not, please identify 

the systems with insufficient funding in the 

comments section.

YES New

B.4.a.8 

to effectively administer its special emphasis 

programs (such as, Federal Women's Program, 

Hispanic Employment Program, and People with 

Disabilities Program Manager)? [5 USC § 7201; 38 

USC § 4214; 5 CFR § 720.204; 5 CFR § 213.3102(t) 

and (u); 5 CFR § 315.709] 

YES

B.3.c, 

B.3.c.1, 

B.3.c.2, & 

B.3.c.3 

B.4.a.9 

to effectively manage its anti-harassment program? 

[see MD-715 Instructions, Sec. I); EEOC 

Enforcement Guidance on Vicarious Employer 

Liability for Unlawful Harassment by Supervisors 

(1999), § V.C.1] 

YES New

B.4.a.10 to effectively manage its reasonable accommodation 

program? [see 29 CFR § 1614.203(d)(4)(ii)] YES B.4.d 

B.4.a.11 to ensure timely and complete compliance with 

EEOC orders? [see MD-715, II(E)] YES New

B.4.b 

Does the EEO office have a budget that is separate 

from other offices within the agency? [see 29 CFR § 

1614.102(a)(1)] 

YES New

B.4.c 

Are the duties and responsibilities of EEO officials 

clearly defined? [see MD-110, Ch. 1(III)(A), 2(III), 

& 6(III)]

YES B.1.b 
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Measures

Compliance Indicator

B.4 - The agency has sufficient budget and staffing 

to support the success of its EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

B.4.d 

Does the agency ensure that all new counselors and 

investigators, including contractors and collateral 

duty employees, receive the required 32 hours of 

training, pursuant to Ch. 2(II)(A) of MD-110? 

YES Investigators are overseen at the 

Departmental level. E.2.d 

B.4.e 

Does the agency ensure that all experienced 

counselors and investigators, including contractors 

and collateral duty employees, receive the required 8 

hours of annual refresher training, pursuant to Ch. 

2(II)(C) of MD-110? 

YES Investigators are overseen at the 

Departmental level. E.2.e 

Measures

Compliance Indicator

B.5 - The agency recruits, hires, develops, and 

retains supervisors and managers who have 

effective managerial, communications, and 

interpersonal skills.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

B.5.a

Pursuant to 29 CFR § 1614.102(a)(5), have all 

managers and supervisors received training on 

their responsibilities under the following areas 

under the agency EEO program:

B.5.a.1 EEO Complaint Process? [see MD-715(II)(B)] YES

New managers and supervisors 

receive EEO training through 

Launchpoint. Follow up 

training is offered and made 

available to all managers and 

supervisors through Virtual 

EEO Awareness Symposium 

and annual site visits.

New
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Measures

Compliance Indicator

B.5 - The agency recruits, hires, develops, and 

retains supervisors and managers who have 

effective managerial, communications, and 

interpersonal skills.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

B.5.a.2 Reasonable Accommodation Procedures? [see 29 

C.F.R. § 1614.102(d)(3)] YES

Managers and supervisors are 

made aware of the 

accommodation process 

through annual site visits, as 

well as through training as part 

of the Manager and Supervisor 

Forum. 

A.3.d 

B.5.a.3 Anti-Harassment Policy? [see MD-715(II)(B)] YES New

B.5.a.4 

Supervisory, managerial, communication, and 

interpersonal skills in order to supervise most 

effectively in a workplace with diverse employees 

and avoid disputes arising from ineffective 

communications? [see MD-715, II(B)]

YES New

B.5.a.5 

ADR, with emphasis on the federal government's 

interest in encouraging mutual resolution of 

disputes and the benefits associated with utilizing 

ADR? [see MD-715(II)(E)]

YES

Training is offered and made 

available to all managers and 

supervisors through EEO 

Virtual EEO Awareness 

Symposium. 

E.4.b 

Measures

Compliance Indicator

B.6 - The agency involves managers in the 

implementation of its EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

B.6.a

Are senior managers involved in the 

implementation of Special Emphasis Programs? 

[see MD-715 Instructions, Sec. I]

YES New

B.6.b 

Do senior managers participate in the barrier 

analysis process? [see MD-715 Instructions, Sec. 

I]

YES D.1.a 
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Measures

Compliance Indicator

B.6 - The agency involves managers in the 

implementation of its EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

B.6.c 

When barriers are identified, do senior managers 

assist in developing agency EEO action plans 

(Part I, Part J, or the Executive Summary)? [see 

MD-715 Instructions, Sec. I]

YES D.1.b 

B.6.d 

Do senior managers successfully implement EEO 

Action Plans and incorporate the EEO Action 

Plan Objectives into agency strategic plans? [29 

CFR § 1614.102(a)(5)] 

YES D.1.c 

Essential Element C: Management and Program Accountability 

This element requires the agency head to hold all managers, supervisors, and EEO officials responsible for the effective 

implementation of the agency's EEO Program and Plan.

Measures

Compliance Indicator

C.1 - The agency conducts regular internal 

audits of its component and field offices.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

C.1.a

Does the agency regularly assess its component and 

field offices for possible EEO program 

deficiencies? [see 29 CFR §1614.102(c)(2)] If 

"yes", please provide the schedule for conducting 

audits in the comments section.

YES

FHWA annually assesses its 

field offices for possible EEO 

deficiencies.

New

C.1.b 

Does the agency regularly assess its component and 

field offices on their efforts to remove barriers from 

the workplace? [see 29 CFR §1614.102(c)(2)] If 

"yes", please provide the schedule for conducting 

audits in the comments section.

YES

FHWA annually conducts 

assessments on the agency’s 

efforts to remove barriers from 

the workplace. 

New

C.1.c 

Do the component and field offices make 

reasonable efforts to comply with the 

recommendations of the field audit? [see MD-715, 

II(C)]

YES New
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Measures

Compliance Indicator

C.2 - The agency has established procedures to 

prevent all forms of EEO discrimination.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

C.2.a

Has the agency established comprehensive antiharassment policy and procedures that comply with 

EEOC's enforcement guidance? [see MD-715, II(C); 

Enforcement Guidance on Vicarious Employer 

Liability for Unlawful Harassment by Supervisors 

(Enforcement Guidance), EEOC No. 915.002, § 

V.C.1 (June 18, 1999)]

YES

FHWA has drafted an update to 

our Anti-Harassment 

procedures and they comply 

with EEOC’s enforcement 

guidance and they are currently 

under Departmental internal 

review.

New

C.2.a.1

Does the anti-harassment policy require corrective 

action to prevent or eliminate conduct before it rises 

to the level of unlawful harassment? [see EEOC 

Enforcement Guidance on Vicarious Employer 

Liability for Unlawful Harassment by Supervisors 

(1999), § V.C.1]

YES New

C.2.a.2

Has the agency established a firewall between the 

Anti-Harassment Coordinator and the EEO 

Director? [see EEOC Report, Model EEO Program 

Must Have an Effective Anti-Harassment Program 

(2006]

YES New

C.2.a.3

Does the agency have a separate procedure (outside 

the EEO complaint process) to address harassment 

allegations? [see Enforcement Guidance on 

Vicarious Employer Liability for Unlawful 

Harassment by Supervisors (Enforcement 

Guidance), EEOC No. 915.002, § V.C.1 (June 18, 

1999)]

YES New

C.2.a.4

Does the agency ensure that the EEO office informs 

the anti-harassment program of all EEO counseling 

activity alleging harassment? [see Enforcement 

Guidance, V.C.]

YES New
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Measures

Compliance Indicator

C.2 - The agency has established procedures to 

prevent all forms of EEO discrimination.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

C.2.a.5

Does the agency conduct a prompt inquiry 

(beginning within 10 days of notification) of all 

harassment allegations, including those initially 

raised in the EEO complaint process? 

[see Complainant v. Dep't of Veterans Affairs, 

EEOC Appeal No. 0120123232 (May 21, 2015); 

Complainant v. Dep't of Defense (Defense 

Commissary Agency), EEOC Appeal No. 

0120130331 (May 29, 2015)] If "no", please provide 

the percentage of timely-processed inquiries in the 

comments column.

YES New

C.2.a.6

Do the agency's training materials on its antiharassment policy include examples of disabilitybased harassment? [see 29 CFR 1614.203(d)(2)]

YES New

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)]

YES

FHWA has drafted its own 

procedures and they are under 

internal review. Pending 

approval, FHWA is following 

the Department’s DOT Order 

1101.1B, which complies with 

EEOC’s regulations and 

guidance.

New

C.2.b.1

Is there a designated agency official or other 

mechanism in place to coordinate or assist with 

processing requests for disability accommodations 

throughout the agency? [see 29 CFR 

1614.203(d)(3)(D)]

YES E.1.d

C.2.b.2 

Has the agency established a firewall between the 

Reasonable Accommodation Program Manager and 

the EEO Director? [see MD-110, Ch. 1(IV)(A)] 

YES New
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Measures

Compliance Indicator

C.2 - The agency has established procedures to 

prevent all forms of EEO discrimination.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

C.2.b.3 

Does the agency ensure that job applicants can 

request and receive reasonable accommodations 

during the application and placement processes? [see 

29 CFR 1614.203(d)(1)(ii)(B)] 

YES New

C.2.b.4 

Do the reasonable accommodation procedures 

clearly state that the agency should process the 

request within a maximum amount of time (e.g., 20 

business days), as established by the agency in its 

affirmative action plan? [see 29 CFR 

1614.203(d)(3)(i)(M)] 

YES New

C.2.b.5 

Does the agency process all accommodation 

requests within the time frame set forth in its 

reasonable accommodation procedures? [see MD715, II(C)] If "no", please provide the percentage of 

timely-processed requests in the comments column. 

NO

The DOT order indicates a 25 

day timeframe unless there are 

extenuating circumstances. 44% 

of accommodations within 

RAMs in FY 21 met the 25 day 

timeframe.

E.1.e 

C.2.c 

Has the agency established procedures for 

processing requests for personal assistance services 

that comply with EEOC's regulations, enforcement 

guidance, and other applicable executive orders, 

guidance, and standards? [see 29 CFR 

1614.203(d)(6)]

YES FHWA currently follows the 

Department’s procedures. New

C.2.c.1 

Does the agency post its procedures for processing 

requests for Personal Assistance Services on its 

public website? [see 29 CFR § 1614.203(d)(5)(v)] If 

"yes", please provide the internet address in the 

comments column. 

YES

https://www.transportation.gov/

drc/personal-assistance-asreasonable-accommodationNew
EEOC FORM 

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FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 42 of 103 

Measures

Compliance Indicator

C.3 - The agency evaluates managers and 

supervisors on their efforts to ensure equal 

employment opportunity.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

C.3.a

Pursuant to 29 CFR §1614.102(a)(5), do all managers 

and supervisors have an element in their performance 

appraisal that evaluates their commitment to agency 

EEO policies and principles and their participation in 

the EEO program?

YES New

C.3.b 

Does the agency require rating officials to evaluate 

the performance of managers and supervisors based 

on the following activities:

C.3.b.1 

Resolve EEO problems/disagreements/conflicts, 

including the participation in ADR proceedings? [see 

MD-110, Ch. 3.I]

YES A.3.a.1 

C.3.b.2 

Ensure full cooperation of employees under his/her 

supervision with EEO officials, such as counselors 

and investigators? [see 29 CFR §1614.102(b)(6)]

YES A.3.a.4 

C.3.b.3 

Ensure a workplace that is free from all forms of 

discrimination, including harassment and retaliation? 

[see MD-715, II(C)]

YES A.3.a.5 

C.3.b.4 

Ensure that subordinate supervisors have effective 

managerial, communication, and interpersonal skills 

to supervise in a workplace with diverse employees? 

[see MD-715 Instructions, Sec. I]

YES A.3.a.6 

C.3.b.5 

Provide religious accommodations when such 

accommodations do not cause an undue hardship? 

[see 29 CFR §1614.102(a)(7)]

YES A.3.a.7 

C.3.b.6 

Provide disability accommodations when such 

accommodations do not cause an undue hardship? [ 

see 29 CFR §1614.102(a)(8)]

YES A.3.a.8 
EEOC FORM 

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Measures

Compliance Indicator

C.3 - The agency evaluates managers and 

supervisors on their efforts to ensure equal 

employment opportunity.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

C.3.b.7 

Support the EEO program in identifying and 

removing barriers to equal opportunity. [see MD-715, 

II(C)]

YES New

C.3.b.8 

Support the anti-harassment program in investigating 

and correcting harassing conduct. [see Enforcement 

Guidance, V.C.2] 

YES A.3.a.2 

C.3.b.9 

Comply with settlement agreements and orders issued 

by the agency, EEOC, and EEO-related cases from 

the Merit Systems Protection Board, labor arbitrators, 

and the Federal Labor Relations Authority? [see MD715, II(C)]

YES New

C.3.c 

Does the EEO Director recommend to the agency 

head improvements or corrections, including remedial 

or disciplinary actions, for managers and supervisors 

who have failed in their EEO responsibilities? [see 29 

CFR §1614.102(c)(2)] 

YES New

C.3.d 

When the EEO Director recommends remedial or 

disciplinary actions, are the recommendations 

regularly implemented by the agency? [see 29 CFR 

§1614.102(c)(2)] 

N/A There were no findings for 

FY21. New 
EEOC FORM 

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Measures

Compliance Indicator

C.4 - The agency ensures effective 

coordination between its EEO programs and 

Human Resources (HR) program.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

C.4.a

Do the HR Director and the EEO Director meet 

regularly to assess whether personnel programs, 

policies, and procedures conform to EEOC laws, 

instructions, and management directives? [see 29 

CFR §1614.102(a)(2)]

YES New

C.4.b 

Has the agency established timetables/schedules 

to review at regular intervals its merit promotion 

program, employee recognition awards program, 

employee development/training programs, and 

management/personnel policies, procedures, and 

practices for systemic barriers that may be 

impeding full participation in the program by all 

EEO groups? [see MD-715 Instructions, Sec. I]

YES C.2.a, C.2.b, 

& C.2.c 

C.4.c 

Does the EEO office have timely access to 

accurate and complete data (e.g., demographic 

data for workforce, applicants, training programs, 

etc.) required to prepare the MD-715 workforce 

data tables? [see 29 CFR §1614.601(a)]

YES New

C.4.d 

Does the HR office timely provide the EEO 

office have timely access to other data (e.g., exit 

interview data, climate assessment surveys, and 

grievance data), upon request? [see MD-715, 

II(C)]

YES New

C.4.e Pursuant to Section II(C) of MD-715, does the 

EEO office collaborate with the HR office to:

C.4.e.1 

Implement the Affirmative Action Plan for 

Individuals with Disabilities? [see 29 CFR 

§1614.203(d); MD-715, II(C)]

YES New
EEOC FORM 

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FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 45 of 103 

Measures

Compliance Indicator

C.4 - The agency ensures effective 

coordination between its EEO programs and 

Human Resources (HR) program.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

C.4.e.2 Develop and/or conduct outreach and recruiting 

initiatives? [see MD-715, II(C)] YES New

C.4.e.3 Develop and/or provide training for managers 

and employees? [see MD-715, II(C)] YES New

C.4.e.4 Identify and remove barriers to equal opportunity 

in the workplace? [see MD-715, II(C)] YES New

C.4.e.5 Assist in preparing the MD-715 report? [see MD715, II(C)] YES New

Measures

Compliance Indicator

C.5 - Following a finding of discrimination, the 

agency explores whether it should take a 

disciplinary action.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

C.5.a

Does the agency have a disciplinary policy and/or 

table of penalties that covers discriminatory 

conduct? 29 CFR § 1614.102(a)(6); see 

also Douglas v. Veterans Administration, 5 

MSPR 280 (1981)

YES

http://staffnet.fhwa.dot.gov/hr/r

egulations/handbook/appendix_

a.htm

C.3.a.

C.5.b 

When appropriate, does the agency discipline or 

sanction managers and employees for 

discriminatory conduct? [see 29 CFR 

§1614.102(a)(6)] If "yes", please state the number 

of disciplined/sanctioned individuals during this 

reporting period in the comments. 

YES

Although the Agency takes 

appropriate action, there were 

no findings of discrimination 

for this reporting period. 

C.3.c 
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Measures

Compliance Indicator

C.5 - Following a finding of discrimination, the 

agency explores whether it should take a 

disciplinary action.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

C.5.c 

If the agency has a finding of discrimination (or 

settles cases in which a finding was likely), does 

the agency inform managers and supervisors 

about the discriminatory conduct? [see MD-715, 

II(C)]

YES

The Agency takes appropriate 

action; however, there have 

been, no findings of 

discrimination or settlements 

due to a likely finding during 

this reporting period. 

New

Measures

Compliance Indicator

C.6 - The EEO office advises 

managers/supervisors on EEO matters.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

C.6.a

Does the EEO office provide 

management/supervisory officials with regular 

EEO updates on at least an annual basis, 

including EEO complaints, workforce 

demographics and data summaries, legal updates, 

barrier analysis plans, and special emphasis 

updates? [see MD-715 Instructions, Sec. I] If 

"yes", please identify the frequency of the EEO 

updates in the comment’s column.

YES

This is discussed annually 

within FHWA and the 

information is posted on our 

website.

C.1.a

C.6.b 

Are EEO officials readily available to answer 

managers' and supervisors' questions or concerns? 

[see MD-715 Instructions, Sec. I]

YES New

Essential Element D: Proactive Prevention

This element requires that the agency head make early efforts to prevent discrimination and to identify and eliminate barriers 

to equal employment opportunity.
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Measures

Compliance Indicator

D.1 - The agency conducts a reasonable 

assessment to monitor progress towards 

achieving equal employment opportunity 

throughout the year.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

D.1.a

Does the agency have a process for identifying 

triggers in the workplace? [see MD-715 

Instructions, Sec. I]

YES New

D.1.b 

Does the agency regularly use the following 

sources of information for trigger identification: 

workforce data; complaint/grievance data; exit 

surveys; employee climate surveys; focus groups; 

affinity groups; union; program evaluations; 

special emphasis programs; reasonable 

accommodation program; anti-harassment 

program; and/or external special interest groups? 

[see MD-715 Instructions, Sec. I]

YES New

D.1.c 

Does the agency conduct exit interviews or 

surveys that include questions on how the agency 

could improve the recruitment, hiring, inclusion, 

retention and advancement of individuals with 

disabilities? [see 29 CFR 1614.203(d)(1)(iii)(C)] 

YES

The Department of 

Transportation has a DOT-wide 

exit survey and starting in fiscal 

year 2022 FHWA will have 

access to the survey data. 

FHWA does not require exit 

interviews, but managers can 

perform the interviews at their 

discretion.

New
EEOC FORM 

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Measures

Compliance Indicator

D.2 - The agency identifies areas where 

barriers may exclude EEO groups (reasonable 

basis to act.)

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

D.2.a

Does the agency have a process for analyzing the 

identified triggers to find possible barriers? [see 

MD-715, (II)(B)]

YES New

D.2.b 

Does the agency regularly examine the impact of 

management/personnel policies, procedures, and 

practices by race, national origin, sex, and 

disability? [see 29 CFR §1614.102(a)(3)] 

YES B.2.c.2 

D.2.c 

Does the agency consider whether any group of 

employees or applicants might be negatively 

impacted prior to making human resource 

decisions, such as re-organizations and 

realignments? [see 29 CFR §1614.102(a)(3)] 

YES B.2.c.1 

D.2.d 

Does the agency regularly review the following 

sources of information to find barriers: 

complaint/grievance data, exit surveys, employee 

climate surveys, focus groups, affinity groups, 

union, program evaluations, anti-harassment 

program, special emphasis programs, reasonable 

accommodation program; anti-harassment 

program; and/or external special interest groups? 

[see MD-715 Instructions, Sec. I] If "yes", please 

identify the data sources in the comments column. 

YES

Complaint/grievance data, 

employee climate surveys, focus 

groups, affinity groups, antiharassment program, special 

emphasis programs, and the 

reasonable accommodation 

program. Note: FHWA does 

not have unions.

New

Measures

Compliance Indicator

D.3 - The agency establishes appropriate 

action plans to remove identified barriers.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

D.3.a. Does the agency effectively tailor action plans to 

address the identified barriers, in particular YES New
EEOC FORM 

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Page 49 of 103 

Measures

Compliance Indicator

D.3 - The agency establishes appropriate 

action plans to remove identified barriers.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

policies, procedures, or practices? [see 29 CFR 

§1614.102(a)(3)]

D.3.b 

If the agency identified one or more barriers 

during the reporting period, did the agency 

implement a plan in Part I, including meeting the 

target dates for the planned activities? [see MD715, II(D)] 

YES New

D.3.c Does the agency periodically review the 

effectiveness of the plans? [see MD-715, II(D)] YES New

Measures

Compliance Indicator

D.4 - The agency has an affirmative action 

plan for people with disabilities, including 

those with targeted disabilities

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

D.4.a

Does the agency post its affirmative action plan 

on its public website? [see 29 CFR 

1614.203(d)(4)] Please provide the internet 

address in the comments.

YES

www.fhwa.dot.gov/civilrights/

Note: The Agency website also 

links to the Department and the 

Department is updating their 

website.

New

D.4.b 

Does the agency take specific steps to ensure 

qualified people with disabilities are aware of and 

encouraged to apply for job vacancies? [see 29 

CFR 1614.203(d)(1)(i)] 

YES New

D.4.c 

Does the agency ensure that disability-related 

questions from members of the public are 

answered promptly and correctly? [see 29 CFR 

1614.203(d)(1)(ii)(A)] 

YES New
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Measures

Compliance Indicator

D.4 - The agency has an affirmative action 

plan for people with disabilities, including 

those with targeted disabilities

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

D.4.d 

Has the agency taken specific steps that are 

reasonably designed to increase the number of 

persons with disabilities or targeted disabilities 

employed at the agency until it meets the goals? 

[see 29 CFR 1614.203(d)(7)(ii)] 

YES New

Essential Element E: Efficiency

This element requires the agency head to ensure that there are effective systems for evaluating the impact and effectiveness of 

the agency's EEO programs and an efficient and fair dispute resolution process.

Measures

Compliance Indicator

E.1 - The agency maintains an efficient, fair, 

and impartial complaint resolution process.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

E.1.a Does the agency timely provide EEO counseling, 

pursuant to 29 CFR §1614.105? YES E.3.a.1

E.1.b 

Does the agency provide written notification of 

rights and responsibilities in the EEO process 

during the initial counseling session, pursuant to 

29 CFR §1614.105(b)(1)? 

YES E.3.a.2 

E.1.c 

Does the agency issue acknowledgment letters 

immediately upon receipt of a formal complaint, 

pursuant to MD-110, Ch. 5(I)? 

N/A 

This function is handled by 

the Departmental Office of 

Civil Rights.

New

E.1.d 

Does the agency issue acceptance letters/dismissal 

decisions within a reasonable time (e.g., 60 days) 

after receipt of the written EEO Counselor report, 

pursuant to MD-110, Ch. 5(I)? If so, please 

provide the average processing time in the 

comments.

N/A

This function is handled by 

the Departmental Office of 

Civil Rights.

New
EEOC FORM 

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Measures

Compliance Indicator

E.1 - The agency maintains an efficient, fair, 

and impartial complaint resolution process.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

E.1.e 

Does the agency ensure all employees fully 

cooperate with EEO counselors and EEO 

personnel in the EEO process, including granting 

routine access to personnel records related to an 

investigation, pursuant to 29 CFR 

§1614.102(b)(6)? 

YES New

E.1.f Does the agency timely complete investigations, 

pursuant to 29 CFR §1614.108? N/A

This function is handled by 

the Departmental Office of 

Civil Rights.

E.3.a.3 

E.1.g 

If the agency does not timely complete 

investigations, does the agency notify 

complainants of the date by which the 

investigation will be completed and of their right 

to request a hearing or file a lawsuit, pursuant to 

29 CFR §1614.108(g)? 

N/A

This function is handled by 

the Departmental Office of 

Civil Rights.

New

E.1.h 

When the complainant does not request a hearing, 

does the agency timely issue the final agency 

decision, pursuant to 29 CFR §1614.110(b)? 

N/A

This function is handled by 

the Departmental Office of 

Civil Rights.

E.3.a.4 

E.1.i 

Does the agency timely issue final actions 

following receipt of the hearing file and the 

administrative judge's decision, pursuant to 29 

CFR §1614.110(a)? 

N/A

This function is handled by 

the Departmental Office of 

Civil Rights.

E.3.a.7 

E.1.j 

If the agency uses contractors to implement any 

stage of the EEO complaint process, does the 

agency hold them accountable for poor work 

product and/or delays? [See MD-110, Ch. 

5(V)(A)] If "yes", please describe how in the 

comments column. 

N/A

FHWA does not use 

contractors for its stages of 

the EEO process. To the 

extent contractors are used 

for other stages, this is 

handled by the Departmental 

Office of Civil Rights.

E.2.c 
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Measures

Compliance Indicator

E.1 - The agency maintains an efficient, fair, 

and impartial complaint resolution process.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

E.1.k 

If the agency uses employees to implement any 

stage of the EEO complaint process, does the 

agency hold them accountable for poor work 

product and/or delays during performance 

review? [See MD-110, Ch. 5(V)(A)] 

YES New

E.1.l 

Does the agency submit complaint files and other 

documents in the proper format to EEOC through 

the Federal Sector EEO Portal (FedSEP)? [See 29 

CFR § 1614.403(g)] 

N/A

This function is handled by 

the Departmental Office of 

Civil Rights.

New

Measures Compliance Indicator

E.2 - The agency has a neutral EEO process.

Measure Met?

(Yes/No/NA)

Comments

Revised Indicator

Current 

Part G 

Questions

E.2.a 

Has the agency established a clear separation 

between its EEO complaint program and its 

defensive function? [see MD-110, Ch. 1(IV)(D)]

YES

Legal sufficiency reviews 

are handled at the 

Departmental level.

New

E.2.b 

When seeking legal sufficiency reviews, does the 

EEO office have access to sufficient legal 

resources separate from the agency 

representative? [see MD-110, Ch. 1(IV)(D)] If 

"yes", please identify the source/location of the 

attorney who conducts the legal sufficiency 

review in the comments column. 

N/A

Legal sufficiency reviews 

are handled at the 

Departmental level.

E.6.a 

E.2.c 

If the EEO office relies on the agency's defensive 

function to conduct the legal sufficiency review, 

is there a firewall between the reviewing attorney 

and the agency representative? [see MD-110, Ch. 

1(IV)(D)]

N/A

Legal sufficiency reviews 

are handled at the 

Departmental level.

New
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Measures Compliance Indicator

E.2 - The agency has a neutral EEO process.

Measure Met?

(Yes/No/NA)

Comments

Revised Indicator

Current 

Part G 

Questions

E.2.d 

Does the agency ensure that its agency 

representative does not intrude upon EEO 

counseling, investigations, and final agency 

decisions? [see MD-110, Ch. 1(IV)(D)] 

YES E.6.b 

E.2.e 

If applicable, are processing time frames 

incorporated for the legal counsel's sufficiency 

review for timely processing of complaints? 

EEOC Report, Attaining a Model Agency 

Program: Efficiency (Dec. 1, 2004) 

N/A

Legal sufficiency reviews 

are handled at the 

Departmental level. 

E.6.c 

Measures

Compliance Indicator

E.3 - The agency has established and 

encouraged the widespread use of a fair 

alternative dispute resolution (ADR) program.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

E.3.a 

Has the agency established an ADR program for 

use during both the pre-complaint and formal 

complaint stages of the EEO process? [see 29 

CFR §1614.102(b)(2)]

YES E.4.a

E.3.b 

Does the agency require managers and 

supervisors to participate in ADR once it has been 

offered? [see MD-715, II(A)(1)]

YES E.4.c 

E.3.c 

Does the agency encourage all employees to use 

ADR, where ADR is appropriate? [see MD-110, 

Ch. 3(IV)(C)]

YES D.2.a 

E.3.d 

Does the agency ensure a management official 

with settlement authority is accessible during the 

dispute resolution process? [see MD-110, Ch. 

3(III)(A)(9)]

YES New
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Measures

Compliance Indicator

E.3 - The agency has established and 

encouraged the widespread use of a fair 

alternative dispute resolution (ADR) program.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

E.3.e 

Does the agency prohibit the responsible 

management official named in the dispute from 

having settlement authority? [see MD-110, Ch. 

3(I)]

YES E.4.d 

E.3.f 

Does the agency annually evaluate the 

effectiveness of its ADR program? [see MD-110, 

Ch. 3(II)(D)]

NO

The Department evaluates 

the effectiveness of its ADR 

program annually. FHWA 

will implement its own 

evaluation process in FY22 

to evaluate FHWA’s use of 

the Departmental ADR 

program.

New

Measures

Compliance Indicator

E.4 - The agency has effective and accurate 

data collection systems in place to evaluate its 

EEO program.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

E.4.a 

Does the agency have systems in place to 

accurately collect, monitor, and analyze the 

following data:

E.4.a.1 

Complaint activity, including the issues and bases 

of the complaints, the aggrieved 

individuals/complainants, and the involved 

management official? [see MD-715, II(E)]

YES E.5.a

E.4.a.2 The race, national origin, sex, and disability status 

of agency employees? [see 29 CFR §1614.601(a)] YES E.5.c 

E.4.a.3 Recruitment activities? [see MD-715, II(E)] YES E.5.f 
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Measures

Compliance Indicator

E.4 - The agency has effective and accurate 

data collection systems in place to evaluate its 

EEO program.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

E.4.a.4 

External and internal applicant flow data 

concerning the applicants' race, national origin, 

sex, and disability status? [see MD-715, II(E)]

YES New

E.4.a.5 The processing of requests for reasonable 

accommodation? [29 CFR § 1614.203(d)(4)] YES New

E.4.a.6 

The processing of complaints for the antiharassment program? [see EEOC Enforcement 

Guidance on Vicarious Employer Liability for 

Unlawful Harassment by Supervisors (1999), § 

V.C.2] 

YES New

E.4.b 

Does the agency have a system in place to resurvey the workforce on a regular basis? [MD715 Instructions, Sec. I] 

YES New

Measures

Compliance Indicator

E.5 - The agency identifies and disseminates 

significant trends and best practices in its EEO 

program.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

E.5.a 

Does the agency monitor trends in its EEO 

program to determine whether the agency is 

meeting its obligations under the statutes EEOC 

enforces? [see MD-715, II(E)] If "yes", provide 

an example in the comments.

YES

Reviews Annual Federal 

Equal Employment 

Opportunity Statistical 

Report of Discrimination 

Complaints (EEOC Form 

462) to develop and provide 

training in EEO areas and 

track trends.

E.5.e
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Measures

Compliance Indicator

E.5 - The agency identifies and disseminates 

significant trends and best practices in its EEO 

program.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

E.5.b 

Does the agency review other agencies' best 

practices and adopt them, where appropriate, to 

improve the effectiveness of its EEO program? 

[see MD-715, II(E)] If "yes", provide an example 

in the comments.

YES

Adopted a best practice 

from GSA: EEO counselors 

now provide the initial 

contact form to Aggrieved 

Persons for them to review 

for accuracy of EEO 

allegations.

E.5.g 

E.5.c 

Does the agency compare its performance in the 

EEO process to other federal agencies of similar 

size? [see MD-715, II(E)]

YES E.3.a 

Essential Element F: Responsiveness and Legal Compliance

This element requires federal agencies to comply with EEO statutes and EEOC regulations, policy guidance, and other written 

instructions.

Measures

Compliance Indicator

F.1 - The agency has processes in place to 

ensure timely and full compliance with EEOC 

Orders and settlement agreements.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

F.1.a 

Does the agency have a system of management 

controls to ensure that its officials timely comply 

with EEOC orders/directives and final agency 

actions? [see 29 CFR §1614.102(e); MD-715, 

II(F)]

YES F.1.a

F.1.b 

Does the agency have a system of management 

controls to ensure the timely, accurate, and 

complete compliance with resolutions/settlement 

agreements? [see MD-715, II(F)]

YES E.3.a.6 
EEOC FORM 

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Measures

Compliance Indicator

F.1 - The agency has processes in place to 

ensure timely and full compliance with EEOC 

Orders and settlement agreements.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

F.1.c 

Are there procedures in place to ensure the timely 

and predictable processing of ordered monetary 

relief? [see MD-715, II(F)]

YES F.2.a.1 

F.1.d Are procedures in place to process other forms of 

ordered relief promptly? [see MD-715, II(F)] YES F.2.a.2 

F.1.e 

When EEOC issues an order requiring 

compliance by the agency, does the agency hold 

its compliance officer(s) accountable for poor 

work product and/or delays during performance 

review? [see MD-110, Ch. 9(IX)(H)] 

N/A Compliance Officer is at the 

Departmental Level. F.3.a. 

Measures

Compliance Indicator

F.2 - The agency complies with the law, 

including EEOC regulations, management 

directives, orders, and other written 

instructions.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

F.2.a 

Does the agency timely respond and fully comply 

with EEOC orders? [see 29 CFR §1614.502; MD715, II(E)]YES C.3.d

F.2.a.1 

When a complainant requests a hearing, does the 

agency timely forward the investigative file to the 

appropriate EEOC hearing office? [see 29 CFR 

§1614.108(g)] 

N/A

This function is handled by 

the Departmental Office of 

Civil Rights.

E.3.a.5 

F.2.a.2 

When there is a finding of discrimination that is 

not the subject of an appeal by the agency, does 

the agency ensure timely compliance with the 

orders of relief? [see 29 CFR §1614.501] 

YES E.3.a.7 
EEOC FORM 

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Page 58 of 103 

Measures

Compliance Indicator

F.2 - The agency complies with the law, 

including EEOC regulations, management 

directives, orders, and other written 

instructions.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

F.2.a.3 

When a complainant files an appeal, does the 

agency timely forward the investigative file to 

EEOC's Office of Federal Operations? [see 29 

CFR §1614.403(e)] 

N/A

This function is handled by 

the Departmental Office of 

Civil Rights.

New

F.2.a.4 

Pursuant to 29 CFR §1614.502, does the agency 

promptly provide EEOC with the required 

documentation for completing compliance? 

YES F.3.d (1 to 

9) 

Measures

Compliance Indicator

F.3 - The agency reports to EEOC its program 

efforts and accomplishments.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

F.3.a 

Does the agency timely submit to EEOC an 

accurate and complete No FEAR Act report? 

[Public Law 107-174 (May 15, 2002), §203(a)]

YES

This function is handled by 

the Departmental Office of 

Civil Rights.

New

F.3.b 

Does the agency timely post on its public 

webpage its quarterly No FEAR Act data? [see 29 

CFR §1614.703(d)]

YES New
Page 59 of 104

MD-715 – Part H

Part H1 

Agency EEO Plan to Attain the Essential Elements of a Model EEO Program 

Please describe the status of each plan that the agency has implemented to correct deficiencies in 

the EEO program.

 If the agency did not address any deficiencies during the reporting period, please check the 

box.

Statement of Model Program Essential Element Deficiency 

Type of Program 

Deficiency Brief Description of Program Deficiency

Agency does not 

conduct trend analysis 

on workforce data

The FHWA has not completed a 3-year trend analyses for the 

workforce compensation and reward system by race, national origin, 

sex, and disability. 

Objective(s) and Dates for EEO Plan 

Date Initiated 

(mm/dd/yyyy) Objective Target Date (mm/dd/yyyy) 

Modified Date 

(mm/dd/yyyy) 

Date 

Completed 

(mm/dd/yyyy) 

12/15/2005 

To conduct trend 

analyses for workforce 

compensation and 

reward system by race, 

national origin, sex, and 

disability.

09/30/2017 09/30/2021 

9/30/2023 Ongoing 

Responsible Official(s) 

Title Name Performance Standards 

Address the Plan? (Yes or No)

Director, Office of Human 

Resources David Lewis YES

Operations Team Leader, Office of 

Civil Rights Tanya Emam YES

Planned Activities Toward Completion of Objective 
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Page 60 of 103 

Target Date 

(mm/dd/yyyy) Planned Activities

Sufficient 

Funding & 

Staffing?

(Yes or No)

Modified Date 

(mm/dd/yyyy) 

Completion 

Date 

(mm/dd/yyyy) 

09/30/2017 

Office of Civil Rights 

(HCR) in continued 

partnership with HR will 

conduct annual barrier 

analyses by race, national 

origin and sex on 

workforce compensation 

and awards for the last 3 to 

5 years. 

YES

09/30/2017 

09/30/2021 

9/30/2022 

5/30/2022 

Complete

09/30/2017 

HCR in continued 

partnership with HR will 

conduct annual trend 

analyses by disability on 

workforce compensation 

and awards for the last 3 to 

5 years. 

YES 9/30/2020 9/30/2020 

Complete

Report of Accomplishments 

Fiscal Year Accomplishments

2018 

The FHWA “At-A-Glance” workforce analysis report for FY 18 was completed 

and presented to the Agency in February 2019. On an annual basis, this 

workforce analysis is presented as a snapshot of the FHWA’s workforce by 

Gender, Ethnicity, Disability, Grade Dispersion, Awards and Recognition. 

FHWA continues to monitor and conduct an annual trend analysis by race, 

national origin and sex on workforce compensation and awards.
EEOC FORM 

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FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 61 of 103 

Fiscal Year Accomplishments

2019 

The FHWA examined and reviewed its recruitment trends in an effort to bolster 

the Agency’s corporate recruitment plan. It utilizes the Data Visualization 

Center to continue to identify new ways to improve its recruitment and 

onboarding efforts. As part of this new plan a focus was put on increasing 

outreach and diversity in FHWA’s workforce with a particular focus on 

women. A 30+ page recruitment plan was developed that created 5 year 

benchmarks of FHWA’s applicant pool, aligned with previous workforce plans, 

identified underrepresented populations, and hiring targets for each as well as 

predictions for mission critical turnover. Hiring fairs and outreach events were 

identified to align with the data to create a strategic approach to organizational 

outreach and recruitment. FHWA worked with FHWA leadership to develop a 

designated team for recruitment and outreach. The result was the creation of 

the Recruitment Outreach and Diversity (ROAD) Team. The ROAD team 

created new promotional materials including brochures and a banner for display 

and distribution. In addition, FHWA recognized a need to understand how to 

advertise its careers in urban areas. FHWA conducted market research on 

brand awareness and specifically looked at the effectiveness of transit 

advertising in multiple metropolitan areas. The information was later used to 

identify a vendor and advertising package to pursue billboard advertising to 

promote the Agency’s very own career fair in Q2 of FY 20. To further support 

the ROAD team and the Agency’s recruitment efforts, FHWA enhanced its 

Ambassador’s program, which is an initiative to select and train Division Office 

recruiters all over the Agency. The ROAD team updated the list of 

approximately 100 recruiters and grew the list with support from senior 

leadership to approximately 180 ambassadors. New recruiters were selected 

with an emphasis on creating as much diversity as possible. A 1-day training 

was created for Ambassadors to teach them how to be effective recruiters, or 

Ambassadors, for FHWA. Two separate 1-day trainings were offered in FY 

19. Post-course feedback was very positive with the course receiving 

overwhelmingly positive reviews. FHWA now has a larger pool of diverse 

recruiters nationwide to attend hiring fairs, professional conferences, and career 

info sessions while visiting colleges and universities. A list of universities as 

well as points of contact was compiled. Each university was contacted via 

email or phone to ensure that FHWA’s contact list was up to date. Utilizing 

Handshake, US News and World Report’s annual list of top engineering 

schools, and lists of Minority Serving Institutions, Historically Black Colleges 

and Universities, all female universities, Hispanic Serving Institutes and Asian 

Serving Institutes as well as large universities with diverse student bodies, 

FHWA now has a list of 239 universities with specific points of contact that its 

recruiters have access to. Many have already used the list to begin outreach 

efforts and conduct presentations at universities.
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

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Page 62 of 103 

Fiscal Year Accomplishments

2020 

The FHWA “At-A-Glance” workforce analysis report for FY 20 was completed 

and presented to the Agency on April 8, 2021. On an annual basis, this 

workforce analysis is presented as a snapshot of the FHWA’s workforce by 

Gender, Ethnicity, Disability, Grade Dispersion, Awards and Recognition. 

FHWA continues to monitor and conduct an annual trend analysis by race, 

national origin and sex on workforce compensation and awards. 

FHWA has analyzed the RNO and gender data over a 3-year trend in relation to 

compensation and awards. FHWA plans to utilize a Barrier Analysis Team to 

identify triggers, determine if there are barriers, and develop an action plan. 

2021 

The Agency conducted Barrier Analysis in compensation and awards. The 

process identified triggers highlighted in Part I of this report. A team approach 

was used to review workforce tables and the appropriate benchmarks were 

identified. A 3 to 5-year trend was established to outline rates above and/or 

above the EEOC benchmark. Policies and procedures were reviewed and 

interviews with Office of Human Resources, Office of Civil Rights, Employee 

Resource Groups, and the Diversity Equity Inclusion Officer were held. See 

Part I for specifics. 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 63 of 103 

MD-715 – Part H

Part H2 

Agency EEO Plan to Attain the Essential Elements of a Model EEO Program 

Please describe the status of each plan that the agency has implemented to correct deficiencies in 

the EEO program.

 If the agency did not address any deficiencies during the reporting period, please check the 

box.

Statement of Model Program Essential Element Deficiency 

Type of Program 

Deficiency Brief Description of Program Deficiency

Tracking recruitment 

efforts and using this 

data to identify 

potential barriers in 

accordance with MD715 standards. 

The FHWA does not track the effectiveness of our targeted outreach 

recruitment efforts and analyze resulting data to identify potential 

barriers in accordance with MD-715 standards. 

Objective(s) and Dates for EEO Plan 

Date Initiated 

(mm/dd/yyyy) Objective Target Date (mm/dd/yyyy) 

Modified 

Date 

(mm/dd/yyyy) 

Date 

Completed 

(mm/dd/yyyy) 

12/15/2011

To track and analyze the 

effectiveness of our 

targeted recruitment and 

outreach efforts by 

collecting data for virtual 

and in-person event 

attendance to measure 

turnout. Subsequently, 

track job announcement 

application data.

09/30/2017

Target date 

extended: 

09/30/2019 

09/30/2020 

9/30/2023

Ongoing

Responsible Official(s)

Title Name Performance Standards Address the 

Plan? (Yes or No)

Director, Office of Human 

Resources David Lewis YES
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Planned Activities Toward Completion of Objective 

Target Date 

(mm/dd/yyyy) Planned Activities

Sufficient 

Funding & 

Staffing?

(Yes or No)

Modified 

Date 

(mm/dd/yyyy) 

Completion 

Date 

(mm/dd/yyyy) 

09/30/2017 

FHWA will work to identify 

the best approach to 

gathering and tracking data 

on recruitment resources. 

YES 09/30/2020 

09/30/2017 

Complete

9/30/2020 

09/30/2017 Analyze Data. YES 09/30/2020 

09/30/2017 

Complete

9/30/2020 

Report of Accomplishments 

Fiscal Year Accomplishments

2018 

In FY 18 recruitment efforts were not as expected due to additional processes 

built into the vetting approval process of new positions by FHWA. The 

Department approves all vacancies. This adds an additional layer to the 

process. A modified plan is still in developmental stages with the target date of 

09/30/2020 so that multiple year trend analyses can be performed. Recruitment 

activities will continue to be monitored for hiring trends for FY 19/20. 

2019 

The FHWA continues to examine and review its recruitment trends. It utilizes

the Data Visualization Center to continue to identify ways to improve its 

recruitment and onboarding efforts. This will be an ongoing effort for FY 20. 

Additional accomplishments are listed in Section H.2 for 2019. 

2020 

FHWA consistently participated in recruitment events also making it a priority 

to attend virtual events as well. In addition, FHWA participates in recruitment 

outreach for Persons with Disabilities, veterans, women, African American, 

Asian, Hispanic, Native American, and other minority groups. FHWA then 

assesses the success of the events using event evaluation forms for attendees. 

This routine will continue going forward. 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 65 of 103 

Fiscal Year Accomplishments

2021 

FHWA continued to participate in a variety of recruitment events including 

virtual and in-person activities. The target audience was diverse and included 

minority serving institutions, veterans, persons with disabilities, and 

professionals across multiple levels (i.e., current students, recent graduates, and 

mid-career). Participation rates from recruitment events were generally noted to 

identify schools/organizations that had the most interest in FHWA. 

The agency utilized direct emailing to reach large candidate bases to market 

available job announcements. This method was found to be most effective in 

reaching out to the public. 

Virtual information sessions were piloted as a cost effective and efficient way 

to attract interested candidates to learn about our agency and market our job 

opportunities. 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 66 of 103 

MD-715 – Part H

Part H3 

Agency EEO Plan to Attain the Essential Elements of a Model EEO Program 

Please describe the status of each plan that the agency has implemented to correct deficiencies in 

the EEO program. 

 If the agency did not address any deficiencies during the reporting period, please check the 

box. 

Statement of Model Program Essential Element Deficiency 

Type of Program 

Deficiency Brief Description of Program Deficiency

Evaluating the effectiveness 

of the Agency’s ADR 

program in alignment with 

OST and in accordance with 

Management Directive 

(MD)-110, Ch. 3(II)(D). 

FHWA does not annually evaluate the effectiveness of its ADR 

program. 

Objective(s) and Dates for EEO Plan

Date Initiated 

(mm/dd/yyyy) Objective Target Date (mm/dd/yyyy) 

Modified 

Date 

(mm/dd/yyyy) 

Date 

Completed 

(mm/dd/yyyy) 

08/23/2021 

To evaluate the 

effectiveness of FHWA’s 

ADR Program

9/30/2023 

Responsible Official(s) 

Title Name

Performance Standards 

Address the Plan?

(Yes or No)

EEO and Special Emphasis Program 

Manager, Office of Civil Rights Nikisha Bennett YES

Operations Team Leader, Office of 

Civil Rights Tanya Emam YES

Planned Activities Toward Completion of Objective 
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Page 67 of 103 

Target Date 

(mm/dd/yyyy) Planned Activities

Sufficient 

Funding & 

Staffing?

(Yes or No)

Modified 

Date 

(mm/dd/yyyy) 

Completion 

Date 

(mm/dd/yyyy) 

03/01/2022 

Develop a survey to be 

disseminated to FHWA 

employees who participate 

in the EEO Complaint 

Process.

YES

9/30/2023 Analyze survey data on an 

annual basis. YES

Report of Accomplishments 

Fiscal Year Accomplishments

New Deficiency
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 68 of 103 

MD-715 – Part H

Part H4 

Agency EEO Plan to Attain the Essential Elements of a Model EEO Program 

Please describe the status of each plan that the agency has implemented to correct deficiencies in 

the EEO program. 

 If the agency did not address any deficiencies during the reporting period, please check the 

box. 

Statement of Model Program Essential Element Deficiency 

Type of Program Deficiency Brief Description of Program Deficiency

Improve efficiency of the 

Reasonable Accommodations 

process to meet expanded 

demands as a result of the 

new hybrid work 

environment. 

Increase in tools and resources needed within the reasonable 

accommodations process to ensure timely processing of 

requests. 

Objective(s) and Dates for EEO Plan 

Date Initiated 

(mm/dd/yyyy) Objective Target Date (mm/dd/yyyy) 

Modified Date 

(mm/dd/yyyy) 

Date 

Completed 

(mm/dd/yyyy) 

4/28/2022 

To develop a more 

efficient case 

management system to 

monitor and deliver 

timely processing of 

reasonable 

accommodation requests

9/30/2023 

Responsible Official(s) 

Title Name

Performance Standards 

Address the Plan?

(Yes or No)

Operations Team Leader, 

Office of Civil Rights Tanya Emam YES

Disability Policy Analyst, 

Office of Civil Rights Kirsten Poston YES
EEOC FORM 

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Page 69 of 103 

Planned Activities Toward Completion of Objective 

Target Date 

(mm/dd/yyyy) Planned Activities

Sufficient 

Funding & 

Staffing?

(Yes or No)

Modified 

Date 

(mm/dd/yyyy) 

Completion 

Date 

(mm/dd/yyyy) 

9/30/2022 

Finalize the Agency RA 

case tracking system for 

Managers/Employees 

YES

9/30/2022 

Distribute FHWA 

Reasonable Accommodation 

Procedures.

YES

6/30/2023 

Develop supporting 

Reasonable Accommodation 

Processing Toolkit for 

Managers

YES

Report of Accomplishments 

Fiscal Year Accomplishments

New Deficiency
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 70 of 103 

MD-715 – Part I

Part I1

Agency EEO Plan to Eliminate Identified Barrier

Please describe the status of each plan that the agency implemented to identify possible barriers 

in policies, procedures, or practices for employees and applicants by race, ethnicity, and gender. 

 If the agency did not conduct barrier analysis during the reporting period, please check the 

box. 

Statement of Condition That Was a Trigger for a Potential Barrier: 

Source of 

the Trigger

Specific Workforce 

Data Table Narrative Description of Trigger

Workforce 

Data Tables A/1, B/1

Groups with lower than expected participation rates

when comparing workforce indicators such as total

representation, the CLF, hiring, and/or separation rates.

EEO Group(s) Affected by Trigger 

EEO Group Affected by Trigger (Yes/No)

All Men NO

All Women YES

Hispanic or Latino Males NO

Hispanic or Latino Females YES

White Males NO

White Females YES

Black or African American Males NO

Black or African American Females NO

Asian Males NO

Asian Females NO

Native Hawaiian or Other Pacific Islander Males NO

Native Hawaiian or Other Pacific Islander Females YES

American Indian or Alaska Native Males YES

American Indian or Alaska Native Females YES
EEOC FORM 

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Page 71 of 103 

EEO Group Affected by Trigger (Yes/No)

Two or More Races Males NO

Two or More Races Females NO

Barrier Analysis Process 

Sources of Data

Source 

Reviewed?

(Yes or No)

Identify Information Collected

Workforce Data Tables YES

A1/B1 data tables, Annual Federal EEO 

Statistical Report of Discrimination (EEOC Form 

462), No FEAR Act Annual Report, Federal 

Employee View Point Survey (FEVS) and 

FHWA's All Employee Survey. 

Complaint Data (Trends) YES EEO and Anti-Harassment trends

Grievance Data (Trends) NO 

Findings from Decisions 

(e.g., EEO, Grievance, 

MSPB, Anti-Harassment 

Processes)

YES OST annual data calls, 462 report 

Climate Assessment 

Survey (e.g., FEVS) YES Federal Employee Viewpoint Survey 

Exit Interview Data NO

Focus Groups YES Women’s Focus Group and Barrier Analysis 

Team

Interviews YES

Key staff from Office of Civil Rights, Office of 

Administration, and select Employee Resource 

Groups 

Reports (e.g., Congress, 

EEOC, MSPB, GAO, 

OPM)

YES

US DOT Equity Initiatives to support EO 13985 

& 13988; Equity Actions | US Department of 

Transportation

Other (Please Describe) YES Agency Recruitment Plan; Diversity Hiring 

Guide; & Merit Promotion Plan

Status of Barrier Analysis Process
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Page 72 of 103 

Barrier Analysis Process Completed?

(Yes or No)

Barrier(s) Identified?

(Yes or No)

YES YES

Statement of Identified Barrier(s)

Description of Policy, Procedure, or Practice

The Agency is in the process of conducting a barrier analysis of recruitment and hiring 

practices, and the separation factors. The DOT has not identified the causes of the condition at 

the time of reporting. 

Objective(s) and Dates for EEO Plan 

Date Initiated 

(mm/dd/yyyy) Objective

Target 

Date 

(mm/dd/

yyyy) 

Modified 

Date 

(mm/dd/

yyyy) 

Date 

Completed 

(mm/dd/

yyyy) 

03/30/2018 

FHWA will continue to implement its 

focus outreach efforts to recruit 

qualified female applicants and 

applicants from groups with lowerthan-expected participation rates. 

FHWA will leverage its resources to 

increase recruitment efforts, through the 

2019-2022 Strategic Plan.

09/30/ 

2022 

04/30/2021 

FHWA will continue to implement and 

perform workforce analysis on a 

biennial basis as it relates to hiring rate 

and separation rates over a 3-year trend. 

As well as further analysis at the 

higher-grade levels.

Once analysis is complete, FHWA will 

look to perform: 1) Focus Groups; 2) 

Exit Interviews; and 3) Target Group 

Surveys on any identified triggers to 

further analyze barriers if necessary. 

9/30/2023 

Responsible Official(s) 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

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Page 73 of 103 

Title Name

Performance Standards 

Address the Plan?

(Yes or No)

Operations Team Leader, 

Office of Civil Rights Tanya Emam YES

Director, Office of Human 

Resources David Lewis YES

Report of Accomplishments

2020 

FY 20 Accomplishments for recruiting women:110 or 36.8% of the permanent hires 

were women – an 11% increase from the 99 women hired in FY 19. With the 

improvements in hiring, women still separated. It is noted that in FY 20 the separation 

rate of women is higher than the participant rate of women in the total workforce. 

FHWA excelled in improving the number of women in the applicant pools of the 

following two occupational series: 0810 (Civil Engineering) which is a hard to fill 

occupation where the talent pool is overwhelmingly male and 0020 (Community 

Planning) which saw the largest spike in the number of female applicants. 

0810 Civil Engineering saw an increase from 245 in 2019 to 286 female applicants in 

2020, a 114% increase in the number of female applicants. 

0020 Community Planning saw an increase from 68 in 2019 to 114 female applicants 

in 2020, a 141% increase in the number of female applicants 

2021 

The Agency conducted a Women’s Focus Group in 2021. The group included a 

representative sampling of women to include administrative, professional, and 

management representatives across the Agency. The focus group was a mixture of 

open dialog and facilitated discussions in a question and answer format. The group 

was held virtually with an emphasis on hiring, promotions, career development, gender 

inclusivity, and separations.

The Agency at this time does not require exit interviews. This is managed within the 

Department of Transportation. Also, the Agency is looking to revamp efforts away 

from a targeted survey to more of a listening session with select employee resource 

groups. Both of these activities will be revisited in FY 22/23. 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 74 of 103 

MD-715 – Part I

Part I2 

Agency EEO Plan to Eliminate Identified Barrier

Please describe the status of each plan that the agency implemented to identify possible barriers 

in policies, procedures, or practices for employees and applicants by race, ethnicity, and gender. 

 If the agency did not conduct barrier analysis during the reporting period, please check the 

box. 

Statement of Condition That Was a Trigger for a Potential Barrier: 

Source of 

the 

Trigger

Specific 

Workforce Data 

Table 

Narrative Description of Trigger

Workforce 

Data 

Tables

A4P Groups with lower than permanent workforce at Grades 13 

through SES. 

EEO Group(s) Affected by Trigger 

EEO Group Affected by Trigger (Yes/No)

All Men YES (note: Only @ SES level) 

All Women YES (note: Only @ GS 13 & 14 

levels)

Hispanic or Latino Males YES

Hispanic or Latino Females YES

White Males NO

White Females YES

Black or African American Males NO

Black or African American Females YES

Asian Males YES

Asian Females YES

Native Hawaiian or Other Pacific Islander Males NO

Native Hawaiian or Other Pacific Islander Females NO
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 75 of 103 

EEO Group Affected by Trigger (Yes/No)

American Indian or Alaska Native Males NO

American Indian or Alaska Native Females NO

Two or More Races Males NO

Two or More Races Females NO

Barrier Analysis Process 

Sources of Data

Source 

Reviewed?

(Yes or 

No)

Identify Information Collected

Workforce Data Tables YES

A1/B1 data tables, Annual Federal EEO Statistical 

Report of Discrimination (EEOC Form 462), No 

FEAR Act Annual Report, Federal Employee View 

Point Survey (FEVS) and FHWA's All Employee 

Survey. 

Complaint Data (Trends) YES EEO and Anti-Harassment trends

Grievance Data (Trends) NO

Findings from Decisions 

(e.g., EEO, Grievance, 

MSPB, Anti-Harassment 

Processes)

YES OST annual data calls, 462 report 

Climate Assessment 

Survey (e.g., FEVS) YES Federal Employee Viewpoint Survey 

Exit Interview Data NO

Focus Groups YES Women’s Focus Group and Barrier Analysis Team 

Interviews YES

Key staff from Office of Civil Rights, Office of 

Administration, and select Employee Resource 

Groups 

Reports (e.g., Congress, 

EEOC, MSPB, GAO, 

OPM)

YES

US DOT Equity Initiatives to support EO 13985 & 

13988; Equity Actions | US Department of 

Transportation
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 76 of 103 

Sources of Data

Source 

Reviewed?

(Yes or 

No)

Identify Information Collected

Other (Please Describe) YES Agency Recruitment Plan; Diversity Hiring Guide; 

& Merit Promotion Plan

Status of Barrier Analysis Process

Barrier Analysis Process Completed?

(Yes or No)

Barrier(s) Identified?

(Yes or No)

YES YES

Statement of Identified Barrier(s)

Description of Policy, Procedure, or Practice

The Agency will explore potential blocked pipelines in grade. The DOT has not identified the 

causes of the condition at the time of reporting. 

Objective(s) and Dates for EEO Plan 

Date Initiated 

(mm/dd/yyyy) Objective

Target 

Date 

(mm/dd/

yyyy) 

Modified 

Date 

(mm/dd/

yyyy) 

Date 

Completed 

(mm/dd/

yyyy) 

7/30/2022 

FHWA will continue to implement and 

perform workforce analysis on a biennial 

basis as it relates to hiring rate and 

separation rates over a 3-year trend. As 

well as further analysis at the highergrade levels.

Once analysis is complete, FHWA will 

look to perform: 1) Perform Focus 

Groups; 2) Garner support and develop 

process to perform Agency exit 

interviews; and 3) ERG Group Briefings 

on any identified triggers to further 

analyze barriers if necessary. 

9/30/ 

2024 
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Date Initiated 

(mm/dd/yyyy) Objective

Target 

Date 

(mm/dd/

yyyy) 

Modified 

Date 

(mm/dd/

yyyy) 

Date 

Completed 

(mm/dd/

yyyy) 

7/30/2022 

FHWA will continue to implement and 

explore leadership pipeline efforts within 

internal promotion practices (i.e. 

interviewing, locational qualification 

considerations, performance 

reviews/awards, etc).

9/30/ 

2024 

7/30/2022 

FHWA will explore and benchmark 

successes within succession planning to 

share throughout the Agency. 

9/30/ 

2024 

Responsible Official(s) 

Title Name

Performance Standards 

Address the Plan?

(Yes or No)

Operations Team Leader, 

Office of Civil Rights Tanya Emam YES

Director, Office of Human 

Resources David Lewis YES
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MD-715 – Part J

Special Program 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 plan will improve the recruitment, hiring, advancement, 

and retention of applicants and employees with disabilities. All agencies, regardless of size, 

must complete this Part of the MD-715 report. 

Section I: Efforts to Reach Regulatory Goals

EEOC regulations (29 C.F.R. § 1614.203(d)(7)) require agencies to establish specific numerical 

goals for increasing the participation of persons with reportable and targeted disabilities in the 

federal government. 

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

PWD by grade level cluster in the permanent workforce? If “yes”, describe the trigger(s) 

in the text box. 

a. Cluster GS-1 to GS-10 (PWD) Yes 0 No X

b. Cluster GS-11 to SES (PWD) Yes X No 0

Source: Table B4P: In FY 21, PWD in GS 1-10 Cluster of the permanent workforce 

participate at 18.45%, a higher rate than the expected 12% benchmark, indicating no 

trigger. 

PWD in the GS 11 to SES Cluster participate at 10.69%, a lower rate than the 

expected 12% benchmark, indicating a trigger. (Source: Table B4P) 

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) Yes 0 No X

b. Cluster GS-11 to SES (PWTD) Yes 0 No X

Source Table B4P: In FY 21, PWTD in GS 1-10 Cluster of the permanent 

workforce participate at 6.64%, a higher rate than the expected 2% benchmark, 

indicating no trigger. 

PWTD in the GS 11 to SES Cluster participate at 2.49%, a rate slightly greater than 

the expected 2% benchmark, indicating no trigger. (Table B4P) 

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

and/or recruiters.

Through FY 21, the Agency’s numerical goals for hiring person with disabilities were 

shared via the Agency’s quarterly Leadership Team Dashboard. This was specifically 
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targeted toward managers and supervisors and is posted on the Agency’s internal Website 

to provide access to all employees. In addition, the annual FHWA At-A-Glance report 

and All Employee Webinar briefing are used to share information on the Agency’s 

workforce including the status of persons with disabilities. Also, all senior leadership 

members receive the Office Profile for their organization biannually which includes 

information on the numerical representation of persons with disabilities and persons with 

targeted disabilities in their organizations. The Agency’s annual Workforce Plan 

includes a section on “Employment of Persons with Disabilities” that identifies the 

numerical goals and how the Agency did in meeting those goals. 

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. 

Yes X No 0

Not applicable. 

2. Identify all staff responsible for implementing the agency’s disability employment 

program by the office, staff employment status, and responsible official. 

Disability Program Task 

# of FTE Staff by 

Employment Status Responsible Official

(Name, Title, Office, 

Email) Full 

Time

Part 

Time

Collateral 

Duty

Processing applications from 

PWD and PWTD 1 Allen Milham, Program Analyst 

Answering questions from the 

public about hiring authorities 

that take disability into account 

1 Allen Milham, Program 

Analyst 

Processing reasonable 

accommodation requests from 

applicants and employees 

1 Kirsten Poston, Disability 

Program Manager

Section 508 Compliance 1 Michelle Cribbs, Section 

508 Program Manager 

Architectural Barriers Act 

Compliance 1 

Jeffrey Baxter, Associate 

Director of Facilities, 

Office of the Secretary 

(OST)
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Disability Program Task 

# of FTE Staff by 

Employment Status Responsible Official

(Name, Title, Office, 

Email) Full 

Time

Part 

Time

Collateral 

Duty

Special Emphasis Program for 

PWD and PWTD 1 Kirsten Poston, Disability Program Manager

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 planned for the upcoming 

year.

Yes X No 0

The Disability Program Manager has attended a number of training sessions in fiscal year 

2021. The training includes the Federal Dispute Resolution conference, the EXCEL 

conference through EEOC, the Disability Program Manager training through EEOC, and 

the MD 715 Basics course. 

B. Plan to Ensure Sufficient Funding for the Disability Program

1. 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.

Yes X No 0

Not applicable.

Section III: Plan to Recruit and Hire Individuals with Disabilities

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

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

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

A. PLAN TO IDENTIFY JOB APPLICANTS WITH DISABILITIES

1. Describe the programs and resources the agency uses to identify job applicants with 

disabilities, including individuals with targeted disabilities. 

The FHWA has a multipronged approach to identify potential applicants with 

disabilities. This includes: 

• Participating in recruitment and outreach events that focus on the employment of 

persons with disabilities. In FY 21, FHWA participated in 118 recruitment events 

throughout the nation. Of those, 10 events were related to disability hiring. 

• Developing and maintaining relationships with disability organizations and colleges 

with disability offices. This allows FHWA to share information related to job 

opportunities which can be shared with their community. In some instances, these 

organizations have helped FHWA to post job announcements on their recruitment 
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sites to be more visible. FHWA is using Handshake and Simplicity to raise 

awareness of their job opportunities. 

• The FHWA continues to implement a Recruitment, Outreach and Diversity plan that 

focuses on increasing the number of applicants with disabilities in FHWA's applicant 

pool. To achieve this outcome the Agency intends to increase its outreach to talent 

pools that consist of people with disabilities. This outreach will consist of attending 

hiring fairs, classroom outreach at academic institutions, and through affinity groups 

whose membership is made up of people with disabilities. 

• The DOT Executive Agent has a standard list of professional organizations, and 

academic institutions that automatically receive a copy of all job announcements 

posted via USAJobs. More specifically, FHWA has used the following recruitment 

sources as part of its outreach to have persons with disabilities apply for vacancies: 

• OPM’s Shared List of People with Disabilities; the Workforce Recruitment Program 

(WRP) database; State and local vocational rehabilitation agencies and employment 

offices; the Department of Veterans Affairs, Wounded Warrior Office, and Vets 2 

Feds; Military installations and transition offices.

This list is not all encompassing but provides a broad view of the Agency’s ongoing 

efforts.

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. 

The FHWA utilizes appointing authorities to include Schedule A, Excepted Service, 

Veterans Recruitment Appointment (VRA), and 30% or More Disabled Veterans. 

The HR specialists provide information on these hiring flexibilities when contacted by 

hiring managers to fill a vacancy. The HR Specialist identifies which authority may meet 

the needs of the office and provides information on how to use the authorities if deemed 

appropriate. 

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. 

At FHWA, the HR Specialists work directly with hiring managers to use the noncompetitive excepted service hiring authorities, including Schedule A. If a manager 

determines that a hiring authority that takes disability into account may be used, the HR 

Specialists provides specific information related to how applications are received and 

reviewed. This may include requesting resumes from the Agency’s Selection Placement 

Coordinator assigned to collect and share this information. In addition, Agency recruiters 

from around the country may be asked for points of contacts for Veteran organizations to 

facilitate resume collection. 
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The FHWA receives and reviews resumes and determines whether the applicants are 

qualified for the position and whether the applicants submitted the necessary 

supplemental documents including Schedule A letters. Resumes and supplemental 

documents are then forwarded to the hiring manager. After the hiring manager completes 

interviewing of qualified candidates, he/she decides if the applicant can perform the job 

duties. The applicant must meet the qualification requirements, including specialized 

experience, for the position. 

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. 

Yes X No 0 N/A 0

The FHWA Office of Human Resources conducted Webinars on hiring veterans, disabled 

veterans, and persons with disabilities for the HR staffing personnel as well as for the 

hiring managers. 

As positions become vacant, HR Specialists discusses hiring flexibilities and options with 

hiring managers to reinforce the Agency's commitment for employing a diverse 

workforce. The DVAAP Program Coordinator utilizes the HR bi-weekly meetings, 

comprised of Agency-wide staffing and classification teams, to provide briefings, 

updates, and reminders related to disability hiring goals and hiring flexibilities. 

In FY 21, FHWA Human Resource Specialists conducted training sessions for hiring 

managers on recruitment options such as Veterans Hiring Flexibilities, including hiring 

and retaining disabled veterans and people with disabilities. Training was provided via 

classroom based training, office presentations and division office site visits. Civil Rights 

Specialists also provided Webinar training on hiring authorities to all employees 

including hiring managers. For the first time, FHWA collaborated with the Federal 

Aviation Administration to implement a hiring fair that promoted FHWA careers directly 

to veterans, disabled veterans, veterans with 30% or more disability, veteran transition 

counselors, representatives from the VA, and people with disabilities.

B. Plan to Establish Contacts with Disability Employment Organizations 

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

assist PWD, including PWTD, in securing and maintaining employment. 

The FHWA continues to implement a Recruitment, Outreach and Diversity (ROAD) plan 

to conduct a review of organizations, colleges and universities, and other organizations 

that serve persons with disabilities and veterans. The organizations are contacted and 

provided information about the FHWA, and to obtain the name and email of a dedicated 

resource to contact. The Corporate Recruitment team has participated in outreach to the 

disability employment organizations and outreach sources as well as conducting meetings 

with them to update resource information and to explore potential future partnerships. 
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In FY 21, FHWA attended ten recruitment events at colleges, universities, academic 

institutions, and professional associations that support populations of people with 

disabilities.

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) Yes 0 No X

b. New Hires for Permanent Workforce (PWTD) Yes 0 No X

Source: Table B-1-1. 

In FY 21, the new hire rate for FHWA PWD in the permanent workforce was 16.98%, a 

higher rate than the expected 12% benchmark, indicating no trigger.The new hire rate for 

FHWA PWTD in the permanent workforce is 3.14%, a higher rate than the expected 2% 

benchmark, indicating no trigger. 

2. Using the qualified applicant pool as the benchmark, do triggers exist for PWD and/or 

PWTD among the new hires for any mission-critical occupations (MCO)? If “yes”, 

please describe the triggers below. 

a. New Hires for MCO (PWD) Yes X No

b. New Hires for MCO (PWTD) Yes X No

Source: Table B6-P Applicant for New Hires Major Critical Occupations by 

Disability PWD new hire selections at a rate lower than the qualified external applicant 

pool within the Realty Specialist series indicating triggers. PWTD new hire selections at 

a lower rate than the qualified external applicant pool within the Community Planner, 

Environmental Specialist, and Transportation Specialist series indicating triggers. 

MCO

PWD Triggers PWTD Triggers

Table 

Qualified 

External 

Applicant 

Pool 

Table B6-

P New 

Hire

Selections

Yes/No

Table 

Qualified 

External 

Applicant 

Pool 

Table 

Qualified 

External 

Applicant 

Pool 

(0020) Community 

Planner 6.52% 10.00% No 2.90% 0.0% Yes

(0028) 

Environmental 

Specialist

10.39% 25.00% No 6.06% 0.0% Yes

(0501/0505) 

Financial Specialist 6.51% 25.00% No 2.68% 12.50% No

(0802) Engineering 

Technician 8.33% 60.00% No 7.29% 20.00% No
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MCO

PWD Triggers PWTD Triggers

Table 

Qualified 

External 

Applicant 

Pool 

Table B6-

P New 

Hire

Selections

Yes/No

Table 

Qualified 

External 

Applicant 

Pool 

Table 

Qualified 

External 

Applicant 

Pool 

(0810) Civil 

Engineering 1.87% 23.26% No 1.31% 2.33% No

(1170) Realty 

Specialist 8.82% 0.0% Yes 0.0% 0.0% No

(2101) 

Transportation 

Specialist

4.59% 14.29% No 2.04% 0.0% Yes

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. 

a. Qualified Applicants for MCO (PWD) Yes X No 0

b. Qualified Applicants for MCO (PWTD) Yes X No 0

Source: Table B6-P Applicants for Internal Competitive Promotions for Major 

Critical Occupations by Disability PWD qualified as applicants at a rate lower than 

the relevant applicant pool within the Environmental Specialists, Engineering 

Technicians, Realty Specialist, and Transportation Specialist series indicating triggers. 

PWTD qualified as applicants at a lower rate than the relevant applicant pool within the 

Community Planner, Engineering Technician, and Transportation Specialist series 

indicating triggers. 

MCO

PWD Triggers PWTD Triggers

Table 

Relevant 

Applicant 

Pool 

Table B6-P 

Qualified 

Internal 

Applicants 

Yes/No

Table 

Relevant 

Applicant 

Pool 

Table B6-P 

Qualified 

Internal 

Applicants 

Yes/No

(0020) 

Community 

Planner

8.93% 15.38% No 3.57% 0.0% Yes

(0028) 

Environmental 

Specialist

9.48% 3.28% Yes 0.86% 1.64% No

(0501/0505) 

Financial 

Specialist

11.25% 28.00% No 2.50% 28.00% No

(0802) 

Engineering 

Technician

11.25% 0.00% Yes 2.50% 0.0% Yes
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MCO

PWD Triggers PWTD Triggers

Table 

Relevant 

Applicant 

Pool 

Table B6-P 

Qualified 

Internal 

Applicants 

Yes/No

Table 

Relevant 

Applicant 

Pool 

Table B6-P 

Qualified 

Internal 

Applicants 

Yes/No

(0810) Civil 

Engineering 7.57% 9.73% No 1.45% 5.06% No

(1170) Realty 

Specialist 5.56% 0.0% Yes 0.00% 0.0% No

(2101) 

Transportation 

Specialist

8.31% 4.59% Yes 2.56% 2.04% Yes

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.

a. Promotions for MCO (PWD) Yes X No 0

b. Promotions for MCO (PWTD) Yes X No 0

Source: Table B6-P Selections for Internal Competitive Promotions for Major Critical 

Occupations by Disability. PWD were selected at a rate lower than the qualified internal 

applicant pool within the Community Planner, Environmental Specialists, and Financial 

Specialists series indicating triggers. PWTD were selected at a lower rate than the qualified 

internal applicant pool within the Environmental Specialist, Financial Specialist and Civil 

Engineering series indicating triggers. 

MCO

PWD Triggers PWTD Triggers

Table B6-P 

Qualified 

Internal 

Applicant 

Table

B6-P 

Selections

Yes/No

Table B6-P 

Qualified 

Internal 

Applicant 

Table

B6-P 

Qualified 

Internal 

Applicants 

Yes/No

(0020) 

Community 

Planner

15.38% 0.0% Yes 0.0% 0.0% No

(0028) 

Environmental 

Specialist

3.28% 0.0% Yes 1.64% 0.0% Yes

(0501/0505) 

Financial 

Specialist

28.0% 0.0% Yes 28.00% 0.0% Yes

(0802) 

Engineering 

Technician

0.00% 22.22% No 0.0% 0.0% No

(0810) Civil 

Engineering 9.73% 12.50% No 5.06% 0.0% Yes
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MCO

PWD Triggers PWTD Triggers

Table B6-P 

Qualified 

Internal 

Applicant 

Table

B6-P 

Selections

Yes/No

Table B6-P 

Qualified 

Internal 

Applicant 

Table

B6-P 

Qualified 

Internal 

Applicants 

Yes/No

(1170) Realty 

Specialist 0.00% 100.0% No 0.0% 0.0% No

(2101) 

Transportation 

Specialist

4.59% 18.18% No 2.04% 9.09% No

Section IV: 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 

1. Describe the agency’s plan to ensure PWD, including PWTD, have sufficient 

opportunities for advancement. 

FHWA employees, including PWD and PWTD, are provided equal access to career 

development opportunities for advancement. Promotion opportunities are posted on 

FHWA’s internal StaffNet site and USAJOBS, and emails are sent to all employees with 

a link to the vacancy announcement on USAJOBS. 

The opportunity for advancement is the same for all employees. Career ladders are 

established based on the position and the needs of the office. This reduces any negative 

impact on PWD and PWTD. 

B. Career Development Opportunities

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

employees.

FHWA encourages and provides training and career development opportunities for all 

employees, including PWD and PWTD. Within the Office of Human Resources, the 

Agency has staff dedicated to the development of a catalog of professional and leadership 

opportunities. FHWA institutes a number of career development programs that support 

and prepare our Agency’s employees for enhanced performance and career advancement. 

These programs target employees at all levels in a variety of venues. The programs are 

as follows: The Professional Development Program (PDP), FHWA 360 Degree 

Leadership Assessment, Discipline Support System, Is Supervision for Me?, Building the 

Foundation for Visionary Leadership, Career Advancement Webinar Series, Critical 
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Human Resources Skills, Formal Mentoring Program, Individual Development Plan 

Workshop, Launch Point-New Supervisory Residency Program, Leadership Competency 

Certificate Program, Leadership Development Academy (LDA), Management and 

Supervision Forum Webinar Series, and Organizational Facilitation. 

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

(%)

Internship 

Programs 101 101 8.9 8.9 2 2 

Fellowship 

Programs 0 0 0.0 0.0 0.0 0.0 

Mentoring 

Programs 64 52 15.6 9.6 3.1 1.9 

Coaching 

Programs 0 0 0.0 0.0 0.0 0.0 

Training 

Programs 309 274 7.1 6.5 1.29 1.09 

Detail 

Programs 8 7 12.5 14.2 0.0 0.0 

Other Career 

Development 

Programs

43 43 11.6 11.6 2.3 2.3 

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 

. 

a. Applicants (PWD) Yes X No 

b. Selections (PWD) Yes X No 

Using the % of PWD at the start of FY 21, 10.84% (Source: Table B1-1) as the relevant 

applicant pool: Applicant Triggers exist for the Internship and Training Programs. 

Selectee Triggers exist for the Internship, Mentoring, and Training programs. 

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

development programs identified? (The appropriate benchmarks are the relevant 

applicant pool for applicants and the applicant pool for selectees.) If “yes”, describe the 

trigger(s) in the text box. 

a. Applicants (PWTD) Yes X No 

b. Selections (PWTD) Yes X No 
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Using the % of PWTD at the start of FY 21, 2.75% (Source: Table B1-1) as the relevant 

applicant pool: Applicant Triggers exist for the Internship, Training, and Other Career 

Development Programs. Selectee Triggers exist for the Internship, Mentoring, Training, 

and Other Career Development Programs.

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) Yes X No 0 

b. Awards, Bonuses, & Incentives (PWTD) Yes 0 No X 

Source: Table B9 When analyzing award categories separately, Cash Awards indicated 

YES triggers for both PWD/PWTD when compared to their inclusion rates. 

Additionally, the Time-off Awards analysis indicated no trigger for PWTD. Note: 

This tables utilizes additional data to anlayze triggers. (See table below)

PY 21 

FHWA 

Awards

Persons without 

Disability 

(Pw/oD)

Inclusion Rate for 

PWD & PWTD 

Group

FHWA Total 

Permanent 

Workforce Inclusion 

Rate/Benchmark

Trigger

Formula

[Subtract the 

Total # of 

Persons with 

Disability 

(PWD) recipients 

from the Total # 

of Recipients]

Inclusion Rate

[Divide the Total # 

of PWD and 

Persons with 

Targeted 

Disabilities 

(PWTD) recipients 

by their total # in 

the permanent 

workforce] 

BenchmarkInclusion Rate

[Divide the Pw/oD # 

receiving awards into 

their respective # in 

permanent workforce]

[Triggers exist 

if Inclusion 

Rate for PWD 

or PWTD is 

less than 

Inclusion rate 

for Pw/oD]

PWD 

Cash 2233-266= 1967 

197/315= 62.54%

1967/2407= 81.72%

Yes

PWTD 

Cash 69/79= 87.34% No

PWD 

Time-Off 1892-211= 1681

155/315= 49.21%

1681/2407= 69.84%

Yes

PWTD 

Time-Off 56/79= 70.89% No

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) Yes X No 0 

b. Pay Increases (PWTD) Yes X No 0 
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Source: Table B9 When analyzing the quality step increase award category 

separately, there were triggers for both PWD and PWTD when compared to its 

inclusion rates. (See the table below)

PY 21 FHWA 

Awards

Persons 

without 

Disability 

(Pw/oD)

Inclusion Rate 

for PWD & 

PWTD Group 

FHWA Total 

Permanent 

Workforce 

Inclusion 

Rate/Benchmark

Trigger

PWD QSI

38-1=37

1/315= 0.32%

37/2407=1.54%

Yes

PWTD QSI 0/79= 0.00% Yes

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) Yes X No 0 N/A 0

b. Other Types of Recognition (PWTD) Yes 0 No X N/A 0

Source: Table B9 When analyzing the Honorary award category separately, there was no 

trigger indicated for PWD and PWTD when compared to their inclusion rate. There was 

no trigger for SES awards. Note: This tables utilizes additional data to analyze triggers. 

(See the table below)

PY 21 

FHWA 

Awards

Persons 

without 

Disability 

(Pw/oD)

Inclusion Rate 

for PWD & 

PWTD Group

FHWA Total Permanent 

Workforce Inclusion 

Rate/Benchmark

Trigger

PWD SES 45-3= 42 3/3= 100% 42/50=84.00% No

PWTD SES 0/0= N/A No

PWD 

Honorary 

Awards

145-19=126 19/315= 6.03% 126/2407= 5.23% No

PWTD 

Honorary 

Awards

5/79= 6.33% No

PWD All 

Awards

2665-300 = 

2365

300/315 = 

95.24% 2365/2407 = 98.25% Yes

PWTD All 

Awards 79/79 = 100% No

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 
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are the relevant applicant pool for qualified internal applicants and the qualified applicant 

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

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

a. SES

i. Qualified Internal Applicants (PWD) Yes X No 0

ii. Internal Selections (PWD) Yes X No 0

b. Grade GS-15 

i. Qualified Internal Applicants (PWD) Yes X No 0

ii. Internal Selections (PWD) Yes 0 No X

c. Grade GS-13/14 

i. Qualified Internal Applicants (PWD) Yes X No 0

ii. Internal Selections (PWD) Yes 0 No X

Source: Table B-7 INTERNAL SELECTIONS FOR SENIOR LEVEL (GS 13/14, 

GS 15, and SES) POSITIONS by PWD 

The Agency used Table B-7 to analyze the applicant flow of internal applicants and/or 

selections for promotions by grade and PWD to the senior level (analysis included grades 

13-15, SES). PWD applicants qualify at rates lower than they apply for the GS 13/14, GS 

15, and SES grade levels. Of those qualified, PWD are internally selected at rates lower 

than they are qualified for the SES indicating Internal Selection triggers. Analysis to 

identify triggers using Table B-7 are displayed below: 

Senior 

Grade Level

PWD

RELEVANT 

APPL 

POOL

QUAL 

INTERNAL 

APPL

Triggers 

Yes/No

INTERNAL 

SELECTION

Triggers 

Yes/No

GS-13/14 10.32% 7.05% Yes 11.21% No

GS-15 6.79% 0.67% Yes 30.00% No

SES 8.51% 4.55% Yes 0.00% Yes

2. Does your agency have a trigger involving PWTD among the qualified internal

applicants and/or selectees for promotions to the senior grade levels? (The appropriate 

benchmarks are the relevant applicant pool for qualified internal applicants and the 

qualified applicant pool for selectees.) For non-GS pay plans, please use the approximate 

senior grade levels. If “yes”, describe the trigger(s) in the text box. 

a. SES

i. Qualified Internal Applicants (PWTD) Yes 0 No X

ii. Internal Selections (PWTD) Yes X No 0

b. Grade GS-15 

i. Qualified Internal Applicants (PWTD) Yes X No 0

ii. Internal Selections (PWTD) Yes X No 0

c. Grade GS-13/14 

i. Qualified Internal Applicants (PWTD) Yes 0 No X 

ii. Internal Selections (PWTD) Yes X No 0
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Source: Table B-7 INTERNAL SELECTIONS FOR SENIOR LEVEL (GS 13/14, 

GS 15, and SES) POSITIONS by PWTD 

The Agency used Table B-7 to analyze the applicant flow of internal applicants and/or 

selections for promotions by grade and PWTD to the senior level (analysis included 

grades 13-15, SES). PWTD applicants qualify at rates lower than they apply at the GS13/14 and SES level. Analysis to identify triggers using Table B-7 are displayed below: 

Senior 

Grade 

Level

PWTD

RELEVANT 

APPL 

POOL

QUAL 

INTERNAL 

APPL 

Triggers 

Yes/No

INTERNAL 

SELECTIONS

Triggers 

Yes/No

GS-13/14 2.14% 3.48% No 3.34% Yes

GS-15 1.89% 0.67% Yes 0.00% Yes

SES 3.83% 4.55% No 0.00% Yes

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

involving PWD among the new hires to the senior grade levels? For non-GS pay plans, 

please use the approximate senior grade levels. If “yes”, describe the trigger(s) in the text 

box. 

a. New Hires to SES (PWD) Yes X No 0

b. New Hires to GS-15 (PWD) Yes X No 0

c. New Hires to GS-13/14(PWD) Yes 0 No X

Source: B7 New Hires for Senior Level (GS 13/14, GS 15, and SES Positions by 

Disability 

The Agency used a datamart table to analyze the applicant flow of qualified applicants 

and/or selections for promotions by grade and PWD to the senior level (analysis included 

grades 13-15, SES). Of those qualified, PWD are selected at rates lower than the rate of 

those qualified for the GS 15 and SES levels, indicating selection triggers. Analysis to 

identify triggers using Table are displayed below: 

Senior Grade Level PWD

QUAL APPL POOL SELECTIONS Triggers Yes/No

GS-13/14 5.39% 24.27% No

GS-15 5.77% 0.00% Yes

SES 4.79% 0.00% Yes

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

involving PWTD among the new hires to the senior grade levels? For non-GS pay plans, 

please use the approximate senior grade levels. If “yes”, describe the trigger(s) in the text 

box. 

a. New Hires to SES (PWTD) Yes X No 0

b. New Hires to GS-15 (PWTD) Yes X No 0

c. New Hires to GS-13/14(PWTD) Yes 0 No X
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Source: B7 New Hires for Senior level (GS 13/14, GS 15, and SES Position by 

Disability.

When analyzing the applicant flow of qualified applicants and/or selections for New 

Hires by grade and PWTD to the senior level (analysis included grades 13-15, SES). Of 

those qualified, PWTD are selected at rates lower than they are qualified at the SES and 

GS 15 level indicating a selection trigger. Analysis to identify triggers using Table are 

displayed below: 

Senior Grade Level PWTD

QUAL APPL POOL SELECTIONS Triggers Yes/No

GS-13/14 2.17% 2.94% No

GS-15 1.92% 0.00% Yes

SES 1.76% 0.00% Yes

5. Does your agency have a trigger involving PWD among the qualified internal applicants 

and/or selectees for promotions to supervisory positions? (The appropriate benchmarks 

are the relevant applicant pool for qualified internal applicants and the qualified applicant 

pool for selectees.) If “yes”, describe the trigger(s) in the text box. 

a. Executives

i. Qualified Internal Applicants (PWD) Yes X No 0

ii. Internal Selections (PWD) Yes X No 0 

b. Managers

i. Qualified Internal Applicants (PWD) Yes X No 0

ii. Internal Selections (PWD) Yes 0 No X 

c. Supervisors 

i. Qualified Internal Applicants (PWD) Yes X No 0

ii. Internal Selections (PWD) Yes 0 No X 

Source: Table B8. PWD were selected at rates lower than the qualified applicant pool 

within the Executive ranks indicating a trigger. 

Supervisory 

Positions 

PWD

RELEV 

APPL 

POOL

QUAL 

INTERNAL 

APPL

Triggers 

Yes/No

INTERNAL 

SELECTIONS

Triggers 

Yes/No

Executive 8.51% 4.55% Yes 0.00% Yes

Managers 6.79% 1.37% Yes 30.00% No

Supervisors 10.34% 9.22% Yes 16.67% No

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. 
EEOC FORM 

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a. Executives

i. Qualified Internal Applicants (PWTD) Yes 0 No X 

ii. Internal Selections (PWTD) Yes X No 0 

b. Managers

i. Qualified Internal Applicants (PWTD) Yes X No 0

ii. Internal Selections (PWTD) Yes X No 0 

c. Supervisors 

i. Qualified Internal Applicants (PWTD) Yes 0 No X 

ii. Internal Selections (PWTD) Yes X No 0

Source: Table B8 Internal Selections of New Supervisors by Positions by Disability

PWTD were selected at rates lower than the qualified applicant pool within all the ranks 

indicating a trigger. 

Supervisory 

Positions 

PWTD

RELEV 

APPL 

POOL

QUAL 

INTERNAL 

APPL

Triggers 

Yes/No

INTERNAL 

SELECTIONS

Triggers 

Yes/No

Executives 3.83% 4.55% No 0.00% Yes

Managers 1.89% 1.37% Yes 0.00% Yes

Supervisors 2.08% 3.55% No 0.00% Yes

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

involving PWD among the selectees for new hires to supervisory positions? If “yes”, 

describe the trigger(s) in the text box. 

a. New Hires for Executives (PWD) Yes X No 0 

b. New Hires for Managers (PWD) Yes X No 0 

c. New Hires for Supervisors (PWD) Yes X No 0

Source: Table B8 New Supervisors by Positions by Disability 

PWD were selected at rates lower than the qualified applicant pool within the Executive, 

Manager and Supervisor ranks indicating triggers. 

Supervisory 

Positions

PWTD

QUAL APPL POOL SELECTIONS Triggers Yes/No

Executives 4.79% 0.00% Yes

Managers 4.21% 0.00% Yes

Supervisors 5.58% 0.00% Yes

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

involving PWTD among the selectees for new hires to supervisory positions? If “yes”, 

describe the trigger(s) in the text box. 

a. New Hires for Executives (PWTD) Yes X No 0

b. New Hires for Managers (PWTD) Yes X No 0 

c. New Hires for Supervisors (PWTD) Yes X No 0 
EEOC FORM 

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FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 94 of 103 

Source: Table B8 New Supervisors by Positions by Disability 

PWTD were selected at rates lower than the qualified applicant pool within all the ranks 

indicating a trigger. 

Supervisory 

Positions

PWTD

QUAL APPL POOL SELECTIONS Triggers Yes/No

Executives 1.76% 0.00% Yes

Managers 1.05% 0.00% Yes

Supervisors 1.02% 0.00% Yes

Section V: Plan to Improve Retention of Persons with Disabilities 

To be a model employer for persons with disabilities, agencies must have policies and programs 

in place to retain employees with disabilities. In this section, agencies should: (1) analyze 

workforce separation data to identify barriers retaining employees with disabilities; (2) describe 

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

reasonable accommodation program and workplace personal assistance services.

A. Voluntary and Involuntary Separations 

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. 

Yes 0 No X N/A 0

All but one Schedule A employee was converted after 2 years of satisfactory service. 

The employee who was not converted had performance and conduct problems that were 

being addressed, so conversion was not appropriate. 

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) Yes 0 No X 

b. Involuntary Separations (PWD) Yes 0 No X 

Based on the inclusion rate, in FY 21, the voluntary separation rate for PWD (5.99%) was 

lower to that of employees without a disability (7.80%) for the total workforce. The 

PWD involuntary separation rate (0.0%) lower than the non-PWD involuntary separation 

rate (0.04%) in FY 21 for the total workforce. (Table B1-2) 
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FY21

Separations

Inclusion Rate for EEO

Group

FHWA Total

Permanent

Workforce 

Inclusion

Rate/Benchmark

Trigger

Formula

Inclusion Rate

[Divide the Total # of PWD 

or PWD separations by their 

total # in the FHWA 

permanent workforce]

BenchmarkInclusion Rate

[Divide the Pw/oD

separations into their 

respective # in Perm

Workforce]

Triggers exist if

Inclusion rate for

PWD is higher than

Inclusion rate for

Pw/oD]

PWD

Voluntary* 18/315 = 5.71% 184/2407 = 7.64% No

PWD

Involuntary 0/315 = 0.00% 1/2407 = 0.4% No

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) Yes 0 No X 

b. Involuntary Separations (PWTD) Yes 0 No X

Table B-1 - Separations by Type of Separation - Distribution by PWD - 

Permanent Workforce

Source: FHWA Datamart database 

The Agency used Table B-1 to analyze the Separations by Type (voluntary/involuntary) 

by distribution of PWTD. PWTD separated at a lower rate when compared to their

inclusion rate/benchmark for voluntary separations does not indicate a trigger.

Analysis to identify triggers using Table B-1 are displayed below:

FY 21 Inclusion Rate for EEO 

Group

FHWA Total Permanent 

Workforce Inclusion Trigger

Formula

Inclusion Rate

[Divide the Total # of 

PWTD separations by their 

total # in the FHWA

permanent workforce]

Benchmark-Inclusion Rate

[Divide the Pw/oTD separations

into their respective # in Perm

Workforce]

[Triggers exist if

Inclusion rate for

PWTD is higher than

Inclusion rate for

Pw/oTD]

PWTD

Voluntary 2/79 = 2.53% 184/2407 = 7.64% No

PWTD

Involuntary 0/79 = 0.00% 1/2407 = 0.04% No

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. 
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No trigger has been identified. 

B. Accessibility of Technology and Facilities

Pursuant to 29 C.F.R. § 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. 

The internet address on the FHWA’s public Website regarding Section 508 of the 

Rehabilitation Act of 1973, including a description of how to file a complaint is 

https://www.fhwa.dot.gov/508/ . 

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. 

The internet address on the FHWA’s public Website regarding Architectural Barriers Act 

is https://www.fhwa.dot.gov/accessibility/ . 

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

undertaking over the next fiscal year, designed to improve accessibility of agency 

facilities and/or technology. 

The FHWA has outlined for its employees an expectations memo in relation to 

Accessibility. This memo provides roles and responsibilities for staff to follow if they 

are hosting a virtual event. Also, FHWA has made modifications to the MS TEAMs 

Webconferencing format to allow for audio/bridge lines to ensure video relay services 

can connect into meetings.

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.) 
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In FY 21, FHWA’s average time to process requests is 65 days. 44% of the time FHWA 

processes reasonable accommodation requests in a timely manner as set forth by DOT 

Order 1101.1B. Requests are processed through the Department’s Reasonable 

Accommodations Online Tracking System (RAMS). 

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. 

During FY 21, FHWA developed its draft Reasonable Accommodation procedures to 

comply with DOT Order 1101.1B. In addition, FHWA has developed and revised several 

resources for employees and managers. These resources include the following: medical 

documentation template; closeout letter; and overview checklists for managers for 

reasonable accommodation responsibilities. In addition, the Disability Program Manager 

provided training at HR’s Manager and Supervisor’s Forum on the Reasonable 

Accommodation process. This training included links to related to COVID-19 guidance 

from EEOC and other internal resources. The Disability Program Manager was a panelist 

at the EEO Virtual Awareness Symposium for Agency employees. 

D. Personal Assistance Services Allowing Employees To Participate in the Workplace 

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

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

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

agency. 

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

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

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

and monitoring PAS requests for trends. 

This is handled at the Departmental level by the US Department of Transportation. 

Section VI: 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 government-wide average? 

Yes X No 0 N/A 0

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?

Yes 0 No X N/A 0
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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. 

Not applicable. 

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 governmentwide average? 

Yes X No 0 N/A 0

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?

Yes 0 No X N/A 0

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.

Not applicable.

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

planned activities.

As part of its planned activities, FHWA developed a draft Reasonable Accommodations 

Handbook; however, the latest DOT Reasonable Accommodation Order 1101.1B was 

signed in January 2021. Therefore, the Agency opted to develop Reasonable 

Accommodation procedures to be in compliance with the DOT Reasonable 

Accommodation Order 1101.1B. Once the FHWA Reasonable Accommodation 

procedures are approved, we will develop a managers and employees toolkit, which will 

consist of manager checklists, sample letters, and one-page summaries for managers and 

employees. 

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

activities toward eliminating the barrier(s).

Completed activities included the Reasonable Accommodations session at the 2021 

FHWA’s EEO Virtual Awareness Symposium and Managers and Supervisor’s Forum. 

The impact of these sessions was educational awareness for managers to communicate 

effectively with employees on accommodation needs. In addition, FHWA’s recruitment 

and outreach efforts that focus on the employment of persons with disabilities had an 

impact of developing and/or maintaining relationships with disability organizations and 

colleges with disability offices. This increased visibility of FHWA and broadened our 

outreach.
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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. 

FHWA will report out progress and updates for the upcoming FY 22 MD-715 report. 

Section VII: 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? 

Yes X No 0

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

Yes X No 0 N/A 0

3. Has barrier(s), objective(s), responsible official(s), planned activities, and, where 

applicable, accomplishments. 

Trigger 1 Individuals with targeted disabilities (PWTD) have a low participation rate in 

the FHWA workforce in grades GS13-SES.

Barrier(s) Recruitment Practices; FHWA focuses recruitment on distributing 

competitive vacancy announcements.

Reasonable Accommodation; FHWA needs to finalize and market its written 

procedures for Reasonable Accommodations for FHWA employees 

Objective(s)

Increase hiring managers’ and HR Specialists’ awareness and knowledge of 

how to use non-competitive hiring authorities for individuals with disabilities 

(Schedule A; “On-the-Spot”). Increased awareness of this hiring flexibility 

will assist the Agency in reaching the EEOC hiring goal that 2% of all new 

hires at GS 1-10 and GS 11-SES should be PWTD. 

The purpose of developing and implementing FHWA-specific reasonable 

accommodation procedures is to provide employees as well as supervisors 

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

Reasonable Accommodation process. These procedures outline the steps for 

requesting or responding to requests for Reasonable Accommodation at 

FHWA.

Responsible Official(s)

Performance Standards Address the 

Plan?

(Yes or No)

David Lewis, Director, Office of Human Resources YES

Tanya Emam, Operations Team Leader, Office of 

Civil Rights YES
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Sources of Data

Sources 

Reviewed?

(Yes or No)

Identify Information Collected

Workforce Data Tables YES

Complaint Data (Trends) YES

Grievance Data (Trends) NO

Findings from Decisions (e.g., EEO, 

Grievance, MSPB, Anti-Harassment 

Processes)

YES

Climate Assessment Survey (e.g., 

FEVS) YES

Exit Interview Data NO

Focus Groups NO

Interviews NO

Reports (e.g., Congress, EEOC, 

MSPB, GAO, OPM) YES

Other (Please Describe) YES Agency Recruitment Plan; Diversity 

Hiring Guide; & Merit Promotion Plan

Target Date 

(mm/dd/yyyy) Planned Activities

Sufficient 

Staffing & 

Funding

(Yes or No)

Modified 

Date

(mm/dd/yyyy) 

Completion 

Date

(mm/dd/yyyy) 

Ongoing 

Educate hiring managers 

and HR Specialists on 

available hiring flexibilities 

to include Schedule A 

through the revamped and 

user-friendly hiring tool kit. 

YES 9/30/2022 09/30/2021 

Ongoing 

The FHWA will analyze 

data regarding disability 

status reporting of 

preference eligible veterans 

to determine what, if any, 

outreach education should 

be developed to encourage 

identifying as a 

PWD/PWTD.

YES 9/30/2022 09/30/2021 
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Target Date 

(mm/dd/yyyy) Planned Activities

Sufficient 

Staffing & 

Funding

(Yes or No)

Modified 

Date

(mm/dd/yyyy) 

Completion 

Date

(mm/dd/yyyy) 

Ongoing 

Develop step by step 

procedures on the 

Reasonable 

Accommodations process 

in easy to use format for 

employees.

YES 9/30/2022 09/30/2021 

Fiscal Year Accomplishments

2018 FHWA will report out updates and accomplishments in the FY 19 and FY 20 

MD-715 report.

2019 

Draft Reasonable Accommodations handbook developed and reviewed. 

In 2019, FHWA conducted a two-part Webinar on Schedule A Hiring and 

Reasonable Accommodations within the Agency’s Management and 

Supervisory Forum Webinar Series. The Management & Supervision Forum 

is a monthly Webinar series providing learning opportunities for individuals 

who serve as supervisors, team leaders, and managers. It is part of the Office 

of Human Resources' ongoing effort to give all employees the tools and 

information to chart their own course for performance improvement, 

learning, career development, as well as personal growth. The session 

provided participants with information that was designed to help them to: 

• Understand how Schedule A works and the benefits of using this 

hiring authority. 

• Use available hiring tools to find qualified Schedule A candidates 

with disabilities.

• Cite manager’s responsibilities in engaging the Reasonable 

Accommodations process 

• Recall the steps in the Reasonable Accommodations process 

• Follow the right order and appropriate steps in the Reasonable 

Accommodations process. 

The FHWA also conducted biannual Workforce planning 

conversations. Workforce Planning conversations are scheduled meetings 

between servicing HR specialists and organizational unit leaders (Division 

Administrators), which focus on workforce planning at the unit level rather 

than agencywide. The conversations provided an opportunity to discuss 

anticipated vacancies, possible separations and retirements, and hiring 

flexibilities, especially those that align with the Strategic Workforce 

Assessment. These strategic conversations were used to educate and 

highlight the Schedule A hiring flexibility. 
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Fiscal Year Accomplishments

2020 

The Agency continued efforts to improve recruitment and hiring of PWTD 

by conducting Webinars in support of Schedule A Hiring and Reasonable 

Accommodations as part of the Agency’s Hot off the HR Desk series as well 

as the Management & Supervision Forums. The Agency established a 

Reasonable Accommodation Working Group to develop materials in support 

of the Reasonable Accommodations process. The draft documents were not 

finalized due to the anticipated revisions of the Departmental RA order. 

2021 The draft procedures are complete for Reasonable Accommodations. They 

are currently under internal review.

Trigger 2

Individuals with disabilities (PWD) and targeted disabilities (PWTD) have a 

lower participation rate in selection for FHWA leadership pipeline positions 

in grades GS13-SES.

Barrier(s)

Career Development, Internal Promotion, & New Hires: FHWA explores 

potential blocked pipelines in grade. The DOT has not identified the causes 

of the condition at the time of reporting. 

Reasonable Accommodation: FHWA explores reasonable accommodation 

and accessibility needs of applicants to address the lower participation rate 

for new hires in selection at higher grades (GS 15/SES). 

Objective(s)

New in FY 21: FHWA will continue to implement and explore leadership 

pipeline efforts within internal promotion practices for PWD and PWTD (i.e., 

interviewing, locational qualification considerations, performance 

reviews/awards, etc.). Align and jointly perform this effort with (Section I2- 

Identified Plan to Eliminate Barriers of the FY 21 MD 715 Report) 

Responsible Official(s) Performance Standards Address the Plan?

(Yes or No)

David Lewis, Director, Office of 

Human Resources YES

Tanya Emam, Operations Team 

Leader, Office of Civil Rights YES

Sources of Data Sources Reviewed?

(Yes or No)

Identify Information 

Collected

Workforce Data Tables YES

Complaint Data (Trends) YES

Grievance Data (Trends) NO

Findings from Decisions (e.g., EEO, 

Grievance, MSPB, Anti-Harassment 

Processes)

YES

Climate Assessment Survey (e.g., 

FEVS) NO

Exit Interview Data NO
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 103 of 103 

Sources of Data Sources Reviewed?

(Yes or No)

Identify Information 

Collected

Focus Groups NO

Interviews NO

Reports (e.g., Congress, EEOC, 

MSPB, GAO, OPM) YES

Other (Please Describe) YES

Agency Recruitment Plan; 

Diversity Hiring Guide; & 

Merit Promotion Plan

Target Date 

(mm/dd/yyyy) Planned Activities

Sufficient 

Staffing & 

Funding

(Yes or No)

Modified 

Date

(mm/dd/yyyy) 

Completion 

Date

(mm/dd/yyyy) 

New Deficiency

Fiscal Year Accomplishments

New Deficiency