EEOC FORM 

715-02 

PART A - D 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

PART A 

Department 

or Agency 

Identifying 

Information 

PART B 

Total 

Employment 

1. Agency 

1.a 2nd level reporting component 

2. Address 

3. City, State, Zip Code 

4. Agency Code 5. FIPS code(s) 4. TD04 

1. Enter total number of permanent full-time and part-time employees 

2. Enter total number of temporary employees 

3. TOTAL EMPLOYMENT [add lines B 1 through 2] 

PART C 

Agency Official(s) Responsible 

For Oversight of EEO 

Program(s) 

Title Type Name Title 

Head of Agency Nicole R. Nason Administrator 

Head of Agency Designee Mala K. Parker Deputy Administrator 

Head of Agency Designee Thomas Everett Executive Director 

Principal EEO Director/Official Irene Rico Associate Administrator for Civil 

Rights 

Affirmative Employment Program Manager Nikisha M. Pickett Internal EEO an d Special Emphasis 

Program Manager 

Complaint Processing Program Manager Nikisha M. Pickett Internal EEO an d Special Emphasis 

Program Manager 

1. DOT Federal Highway Administration 

2. 1200 New Jersey Avenue SE 

3. Washington , DC 20590 

5. 11001 

1. 

2. 

4. 

2678 

5 

2683 

Page 1 
EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART A - D EEO PROGRAM STATUS REPORT 

PART D 

List of Subordinate Components Covered in 

This Report 

For period covering October 1, 2018 to September 30, 2019 

Subordinate Component and Location Country Agency Code 

(City/State) 

DOT Federal Highway Administration United States TD04 

Montgomery , AL 

DOT Federal Highway Administration United States TD04 

Lakewood , CO 

DOT Federal Highway Administration United States TD04 

Glastonbury, CT 

DOT Federal Highway Administration United States TD04 

Albany, NY 

DOT Federal Highway Administration United States OTHER 

Providence , RI 

DOT Federal Highway Administration United States TD04 

Juneau, AK 

DOT Federal Highway Administration United States TD04 

Washington , DC 

DOT Federal Highway Administration United States TD04 

Atlanta, GA 

DOT Federal Highway Administration United States TD04 

Concord, NH 

DOT Federal Highway Administration United States TD04 

Raleigh, NC 

DOT Federal Highway Administration United States TD04 

Phoenix, AZ 

DOT Federal Highway Administration United States TD04 

Boise, ID 

DOT Federal Highway Administration United States TD04 

Springfield, IL 

DOT Federal Highway Administration United States TD04 

Baton Rouge, LA 

DOT Federal Highway Administration United States TD04 

Baltimore, MD 

DOT Federal Highway Administration United States TD04 

Cambridge, MA 

DOT Federal Highway Administration United States TD04 

West Trenton , NJ 

DOT Federal Highway Administration United States TD04 

Columbia , SC 

DOT Federal Highway Administration United States TD04 

Austin, TX 

DOT Federal Highway Administration United States TD04 

Bismarck , ND 

DOT Federal Highway Administration United States TD04 

Sacramento , CA 

DOT Federal Highway Administration United States TD04 

Dover, DE 

DOT Federal Highway Administration United States TD04 

Tallahassee, FL 

DOT Federal Highway Administration United States TD04 

Helena, MT 

DOT Federal Highway Administration United States TD04 

Lincoln, NE 

DOT Federal Highway Administration United States TD04 

Columbus, OH 

DOT Federal Highway Administration United States TD04 

Salem, OR 

Page 2 
EEOC FORM U.S. Equal Employment Opportunity Commission

715-02 FEDERAL AGENCY ANNUAL

PART A - D EEO PROGRAM STATUS REPORT 

For period covering October 1, 2018 to September 30, 2019 

Subordinate Component and Location Country Agency Code 

(City/State) 

DOT Federal Highway Administration United States TD04 

Austin , TX 

DOT Federal Highway Administration United States TD04 

Little Rock , AR 

DOT Federal Highway Administration United States TD04 

Lansing, MI 

DOT Federal Highway Administration United States TD04 

Carson City , NV 

DOT Federal Highway Administration United States TD04 

Oklahoma City, OK 

DOT Federal Highway Administration United States TD04 

Madison, WI 

DOT Federal Highway Administration United States TD04 

Honolulu, HI 

DOT Federal Highway Administration United States TD04 

Indianapolis , IN 

DOT Federal Highway Administration United States TD04 

Ames, IA 

DOT Federal Highway Administration United States TD04 

Jackson, MS 

DOT Federal Highway Administration United States TD04 

Jefferson City, MO 

DOT Federal Highway Administration United States TD04 

Harrisburg, PA 

DOT Federal Highway Administration United States TD04 

San Juan , PR 

DOT Federal Highway Administration United States TD04 

Nashville, TN 

DOT Federal Highway Administration United States TD04 

Cheyenne, WY 

DOT Federal Highway Administration United States TD04 

Sterling, VA 

DOT Federal Highway Administration United States TD04 

Topeka, KS 

DOT Federal Highway Administration United States TD04 

Frankfort, KY 

DOT Federal Highway Administration United States TD04 

Salt Lake City , UT 

DOT Federal Highway Administration United States TD04 

Olympia, WA 

DOT Federal Highway Administration United States TD04 

Pierre, SD 

DOT Federal Highway Administration United States OTHER 

Augusta, ME 

DOT Federal Highway Administration United States TD04 

St. Paul , MN 

DOT Federal Highway Administration United States TD04 

Santa Fe, NM 

DOT Federal Highway Administration United States TD04 

Montpelier, VT 

DOT Federal Highway Administration United States TD04 

Richmond, VA 

DOT Federal Highway Administration United States TD04 

Charleston, WV 

Page 3 
EEOC FORM 

715-02 

PART A - D 

EEOC FORMS and Documents 

Agency Strategic Plan 

Anti-Harassment Policy and 

Procedures 

Organization Chart 

EEO Policy Statement 

Reasonable Accommodation 

Procedure 

Personal Assistance Services 

Procedures 

Alternative Dispute Resolution 

Procedures 

Diversity Policy Statement 

Disabled Veterans Affirmative 

Action Program (DVAAP) Report 

Federal Equal Opportunity 

Recruitment Program (FEORP) 

Report 

EEO Strategic Plan 

Results from most recent Federal 

Employee Viewpoint Survey or 

Annual Employee Survey 

Human Capital Strategic Plan 

Required 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

N 

N 

N 

N 

N 

N 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

For period covering October 1, 2018 to September 30, 2019 

Uploaded 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

N 

Y 

N 

Page 4 
EEOC FORM 

715-02 

PART E.1 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

EXECUTIVE SUMMARY: MISSION 

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

Program Status Report for Fiscal Year 2019 (FY 19) 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 EEO Program. 

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, Tribal governments, FHWA is responsible for 

ensuring that America’s roads and highways continue to be among the safest and most technologically 

sound 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, District of Columbia, Headquarters, Office of 

Technical Services, 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.” 

Page 5 
EEOC FORM 

715-02 

PART E.2 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

Element A- Demonstrated Commitment from Agency Leadership 

The FHWA is committed to the principles of EEO and maintaining a successful EEO 

Program.  This commitment is demonstrated throughout the Agency’s hierarchy from 

senior executives, managers and supervisors to all employees.  Efforts to demonstrate 

this commitment include the following: 

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 April 22, 2019, Nicole R. Nason began her tenure as Administrator of the FHWA. In 

this role, she leads an Operating Administration within the DOT that is responsible for 

the Nation’s $49 billion Federal-aid highway program. 

On October 10, 2019, Mala K. Parker was named Deputy Administrator for the FHWA. 

Ms. Parker provides executive leadership and strategic direction within FHWA to 

advance the goals and priorities of the Department under Secretary Chao's leadership. 

The 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, setting expectations for the Anti-Harassment Program, and Special 

Emphasis programs. 

All Employee Survey Updates 

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

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

began conducting the Federal Employee View Point Survey (FEVS) on an annual basis 

the FHWA AES started to be conducted in the odd years while the OPM FEVS was 

conducted in the even years. 

The FHWA AES had 2,128 employees who shared their thoughts and provided 

feedback.  The division employees led the way with a 92% response rate overall; 34 

division offices had a response rate of 90% or above, and 17 of those offices reported at 

100%. The Office of the Administrator and the Directors of Field Services Office also 

reported 100% participation. The number of respondents and participation rates from 

primary groups in the Agency are shown below. 

Page 6 
EEOC FORM 

715-02 

PART E.2 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

FHWA Headquarters 627/866 72% 

Office of Technical Services 112/138 81% 

Federal-aid Division Offices 926/1008 92% 

Federal Lands Highway 463/638 73% 

The most recent survey results received an 80% response rate. The 2019 scores 

indicate a Climate Quotient score of 73%.  Employees are most satisfied with the 

following: 

• Work-life support (82.3%) 

• Agency’s customer focus (81.1%) 

• Interactions with immediate supervisor (79.4%) 

The highest rated items involve the following: 

• Work-life balance (86.1%) 

• Employees are treated with respect (84.8%) 

The lowest rated items were the following: 

• Career Satisfaction (69.1%) 

• Employee Engagement (70.6%) 

• Senior Leadership support (70.8%) 

The FHWA through a committee called the Human Resource Management Committee 

(HRMC), reviews the results of the survey and develops a 2-year action plan that helps 

to continue to improve FHWA as one of the best places to work.  

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

The FHWA Strategic Plan (2019-2022) outlines the goals and objectives of the FHWA 

and supersedes the previous FHWA Performance Year 2018/19 Strategic 

Implementation Plan.  This plan was developed to align FHWA efforts with the FY 

2018-2022 DOT Strategic Plan and reflects the priorities of Agency leadership.  In DOT 

Strategic Plan, one of the goals is Accountability, which has 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.” 

To improve the efficiency and effectiveness of the organization, DOT will 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.  The Agency conducted a wide number of programs and 

activities as outlined in the Unit Performance Plans during the reporting period that 

reflect leadership commitment: 

Page 6 
  

EEOC FORM 

715-02 

PART E.2 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

• 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 resurveyed the workforce resulting in an 

increased number of employees completing the revised Self-Identification of the 

Workforce Standard Form (SF-256 form).  All employees were encouraged to selfidentify or update their information using descriptions from OPM’s Self-Identification 

of Disability through their Employee Express system account.  The disability codes 

have been updated in the Human Resource information system therefore increasing 

the Agency’s (Persons with Disabilities (PWD) and (Persons with Targeted WTD) 

population. 

• Offices included Diversity and Inclusion (D & I) efforts within their Unit Performance 

Plans (UPP). 

• The FHWA implemented its pilot Anti-Harassment Process and worked concurrently 

in developing a permanent Anti-Harassment Process. 

• 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. 

• The FHWA 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 (PDP), Rotational Developmental Assignment Clearinghouse, and 

expanded Career Development programs 

Element C- Management and Program Accountability 

FHWA’s employees received and provided updated training on EEO and Reasonable 

Accommodations via the Departmental Office of Civil Rights.  FHWA’s Disability 

Program Manager continues to work with the Departmental Disability Resource Center 

to process and track reasonable accommodation requests and provide technical 

assistance and training to the Managers, Supervisors, and Team Leaders on the 

Reasonable Accommodations process. 

Reasonable Accommodations and Disability Program 

The Office of Civil Rights championed the National Disability Employment Awareness 

Month Observance in October 2018.  Haben Girma, Disability Rights Attorney and 

Activist provided keynote remarks, and former Deputy Administrator Brandye 

Hendrickson and Secretary Elaine Chao provided the welcome. More than 250 

employees attended the event.  It was livestreamed via YouTube with more than 200 

views by employees. 

Page 6 
EEOC FORM 

715-02 

PART E.2 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

The Office of Civil Rights and HR jointly sponsored a Webinar for FHWA managers/ 

supervisors on the Reasonable Accommodations programs and Schedule A hiring 

authorities in November 2018.  More than 100 managers/supervisors participated in the 

Webinar. 

The FHWA Disability Program Manager and the Internal EEO and Special Emphasis 

Program Manager conducted 3-hour on site EEO and Reasonable Accommodations 

training at the Iowa, Georgia, and California Division Offices in April, July, and August of 

2019. More than 80 employees in these field offices participated in the training. EEO and 

Reasonable Accommodations training and outreach continues through the end of FY 

2020. 

The FHWA along with other Operating Administrations sponsored mock interviews with 

undergraduate students who are deaf and hard of hearing from Gallaudet University in 

the Spring of 2019.  These mock interviews were an opportunity for students to meet 

with hiring officials and learn about the various job opportunities at FHWA /DOT. More 

than 80 students participated. 

Special Emphasis Programs 

The FHWA Office of Civil Rights utilizes Special Emphasis programs and engages with 

Employee Resource Groups to continue to raise employee awareness of the importance 

of diversity and to demonstrate the Agency’s commitment to a model EEO workplace.  A 

series of Webinars were held to educate the workforce about the different Employee 

Resource Groups within the Agency. 

In FY 19, FHWA took a champion role in the planning and delivery of the following DOT 

Special Emphasis Program events: 

• African American History Month 

• Asian and Pacific Islander Heritage Month 

• Hispanic Heritage Month 

• Women’s Program 

Reissuance of Standard Form 256 

FHWA distributed the SF 256-Self-Identification of Disability Form at new employee 

orientations, issued an all employee email explaining the reason employees may want to 

review and/or update their self-identified status, and provided talking points to hiring 

managers on the self-identification process for use at their all employee meetings. 

Targeted Recruitment and Outreach Efforts 

As a result of FY 2018 reporting, FHWA revamped its Corporate Recruitment effort to 

address the low participation rate of women, Hispanic women and individuals with 

disabilities. FHWA attended recruitment and outreach events designed to network and 

meet people with disabilities.  The events included: (1) EOP Career Expo for People 

with Disabilities and Wounded Warriors (2); Three U.S. Chamber of Commerce 

Foundation’s Hiring Our Heroes Career Fair for veterans, service members who are postPage 6 
EEOC FORM 

715-02 

PART E.2 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

transition, reservists, guardsmen, and military spouses; (3) Two DC Peace Corps Job 

Fairs for returned peace corps volunteers and other national service alumni; and the (4) 

Diversity Employment Day Career Fair. 

FHWA utilized a variety of recruitment resources, including online services; 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; and USAJOBS to attract people with 

disabilities for FHWA job opportunities.  FHWA vacancy announcements continue to be 

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

communities. 

Education/Outreach on Schedule A 

FHWA Office of Human Resources held one-on-one consultative sessions with hiring 

managers to discuss various staffing and recruitment initiatives which included different 

hiring authorities.  These hiring authorities (including Schedule A) help hiring managers 

decrease time-to-hire and ensure that plans of action that place qualified applicants in 

the Agency’s positions are followed, including mission critical occupations.  

Addressing Generational Diversity 

FHWA has established an advisory group called the Innovation Exchange (iExchange), 

a multi-generational forum focused on exchanging ideas, inspiring innovation, raising 

awareness of generational diversity, and creating an environment that embraces 

members of different generations.  Sponsored by the Knowledge Management (KM) 

unit, the iExchange expanded its membership to more than 240 employees.  The 

advisory group held another virtual speed networking event, several more crowdsource 

(brainstorm) sessions, and continued to work with FHWA offices, committees, and 

councils to provide ideas and a fresh perspective. 

Element D- Proactive Prevention of Unlawful Discrimination 

Anti-Harassment Process 

On June 21, 2019, the Department issued its Policy Framework for the Prevention of 

Harassment, which, among other things, required each mode to develop an AntiHarassment Process incorporating certain parameters, and submit that process for OST 

review within 90 days.  The FHWA pilot process already met most of the Framework’s 

requirements.  In response to the issuance of the Framework, on September 19, 2019, 

FHWA revised its pilot process to fully conform to the Framework’s requirements, and 

submitted the revised process to OST for review. 

Similar to the Pilot process, the revised FHWA Anti-Harassment Process addresses 

allegations of any type of harassment in or relating to the (FHWA) workplace.  Anyone 

may raise an allegation of harassment in this process, including but not limited to an 

FHWA or DOT employee, a contractor, an employee of FHWA partners (such as State 

DOT employees), or an applicant for employment.  An individual may bring the 

Page 6 
EEOC FORM 

715-02 

PART E.2 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

allegation concerning any FHWA employee, contractor, or FHWA partner (including 

employees of other DOT modes), no matter whether the individual is subordinate to, 

supervises, or is a peer or partner of the individual being accused.  The process, 

including the remedies available, vary based on differences in the employee status of 

the individual making the allegation and the employee status of the individual accused of 

harassment. 

Based on the Policy Framework FHWA submitted the updated procedures to OST for 

approval on September 19, 2019. 

Training 

FHWA secured a contract for FY 2020 Anti-Harassment training.  This contract will 

provide Anti-Harassment training to all FHWA employees. 

Diversity Management Committee 

In support of the Agency’s strategic initiative to increase the population of low 

representation, the, FHWA continued to utilize its 19-member Diversity Management 

Committee (DMC) to cultivate and advance several initiatives designed to improve 

organizational culture and raise awareness on the importance of having a diverse and 

inclusive organization. 

The committee selected and trained 22 new Diversity Champions to fill vacant slots for 

previous champions rotating off the program. With a goal to increase diversity, the DMC 

contributed a great deal to the Agency’s recruitment efforts this year. The committee 

supported HR with the development and updating of hiring and advancement policies 

and practices through Launch Point, Managers & Supervisors Forum and other 

avenues. In addition, the group helped identify resources and tips for diversity hiring. 

Furthermore, the committee collaborated with HR on the revamping of the corporate 

recruitment program and the development of a Diversity Hiring Guide for Hiring 

Managers. Based on the FY 2018 analysis that identified low participation rates in the 

mission critical occupations for the planning discipline, the DMC collaborated with the 

Planning Leadership Council, which is a committee of planning discipline employees, to 

develop a series of resources for assisting hiring officials in recruiting or hiring a 

community planner or transportation specialist with planning responsibilities. These 

resources were made available through the Planning Discipline SharePoint site and 

included a list of colleges, universities and associations with planning programs, 

planning focused interview questions, and a listing of seasoned FHWA Planners willing 

to assist in the hiring process. 

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

greater interaction among women 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 

Page 6 
EEOC FORM 

715-02 

PART E.2 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

challenges in the workplace - especially those impacting women. 

The committee produced and developed a diversity video to serve as an educational 

message on core principles of diversity and inclusion. The video will be aired and 

distributed in 2020. 

In an effort to address inclusion-related feedback gathered in employee surveys, the 

DMC partnered with HR to improve the Agency’s Telework Program. With many 

employees reporting unequal expectations between managers and themselves 

regarding telework, the DMC helped initiate a Webinar series not only to clarify the 

policy and guidance but also to provide an opportunity for questions to be answered by a 

panel of representatives including the Telework Program Manager. 

Furthermore, the DMC decided to build from last year’s effort to capture all of the 

Departmental Employee Resource Groups within a distribution list and hosted an 

agencywide Webinar that introduced all the affinity organizations to all employees. 

The DMC also continued its role in conducting diversity presentations at each requesting 

program offices and each of this year’s Discipline Support System Seminars. There 

have been 8 seminars held so far with attendee counts ranging from 60 to 230 

employees. 

Element E- Efficiency 

FHWA timely submitted to the EEOC the Annual Federal EEO Statistical Report of 

Discrimination Complaints (EEOC Form 462).  In addition, FHWA timely submitted to 

Congress 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 2018. 

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. 

Page 6 
EEOC FORM 

715-02 

PART E.2 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

Element F- Responsiveness and Legal Compliance 

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 and issues from prior fiscal years are further discussed 

in Part H of this report. 

Page 6 
EEOC FORM 

715-02 

PART E.3 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

EXECUTIVE SUMMARY: WORKFORCE ANALYSES 

As of September 30, 2019, FHWA onboard strength showed a total of 2,683 employees, of whom 2,678 

were permanent employees and 5 were temporary employees. 

FHWA is starting to see improvements in targeted areas. In FY19, FHWA exceeded its goal of 10% of 

hires of PWD and its 2% goal of PWTD onboard. In FY 19, approximately 16.52% of all new hires were 

PWD, and 4.35% were PWTD. Overall, PWTD comprise 3.05% of the total FHWA workforce. (This 

number includes hires from other DOT modes, and therefore is not demonstrated by the workforce tables). 

Veterans with 30% or more disability represent 5.7% of all hires and make up 6.5% of the total workforce. 

The FHWA reports out the following regarding the overall diversity of its workforce between FY 10 and FY 

19: 

(1) Hispanics in FHWA permanent workforce have increased from 8.48% to 8.95% 

(2) Black or African Americans in the permanent workforce had a slight increase from 15.01% to 15.06%; 

and 

(3) PWD increased from 9.88% to 10.78% of the FHWA permanent workforce. 

(4) PWTD increased from 2.88% to 3.05% of the FHWA permanent workforce. 

* this number is inclusive of hires from other DOT modes, and not accounted for in the workforce tables. 

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

White females and Hispanic females remain areas where FHWA needs to continue its efforts. These 

areas of improvement have been included in Part H and I of this report. (Page 17-19 of the PDF of this 

report highlights the tables for this section) 

Page 7 
EEOC FORM 

715-02 

PART E.4 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

EXECUTIVE SUMMARY: ACCOMPLISHMENTS 

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

of FHWA’s FY 19 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: 

• No findings of discrimination by the EEO Commission, the Merit Systems Protection 

Board, or the District Court were issued in FY 2019. 

• In FY 2019, FHWA increased the hiring of people with disabilities and people with 

targeted disabilities. FHWA hired a record 4.35% of people with targeted disabilities 

for the permanent workforce. This helped to significantly improve FHWA’s onboard 

percentage from 2.0% to 3.05%. 

• For the third year, FHWA surpassed the EEOC goal of 12% of hires being people 

with disabilities (targeted and non-targeted) by achieving 13.86% of FHWA’s 

permanent workforce. 

• In FY 2019, FHWA continued to grow the activities of its corporate Diversity 

Committee efforts. FHWA continued to expand the cadre of Diversity Champions 

throughout all its units around the country. 

• The FHWA has established an advisory group called the Innovation Exchange 

(iExchange), a multi-generational forum focused on exchanging ideas, inspiring 

innovation, raising awareness of generational diversity, and creating an environment 

that embraces members of different generations. Sponsored by the FHWA’s KM 

unit, the iExchange expanded its membership to more than 240 employees in FY 

2019. The advisory group held another virtual speed networking event, several more 

crowdsource (brainstorm) sessions, and continued to work with FHWA offices, 

committees, and councils to provide ideas and a fresh perspective. 

• In September 2019, FHWA submitted its revised anti-harassment process to OST for review in 

response to DOT’s Policy “Framework for the Prevention of Harassment and Unprofessional Conduct” 

. The purpose of the DOT policy is to provide a framework for preventing and addressing allegations 

of harassment and unprofessional behavior in the workplace and instructs the Operating 

Administrations and the Office of the Secretary to establish procedures for reporting and addressing 

such allegations. 

Page 8 
EEOC FORM 

715-02 

PART E.5 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

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 

• FHWA will continue to increase its technical assistance and training on EEO, Reasonable 

Accommodations and D & I at all Discipline Seminars including the development of a Reasonable 

Accommodations Handbook and EEO Awareness Day Program 

• FHWA will conduct a series of online and in-person training sessions related to the Anti-Harassment 

Process. FHWA has assembled a diverse Anti-Harassment group that represents both Headquarters 

and field facets of the Agency to guide the training development and content. 

• FHWA will continue to strengthen our formalized Anti-Harassment Process that was approved by the 

FHWA Administrator on 12/13/2019. FHWA will provide effective rollout training on processes, roles, 

responsibilities to all FHWA Agency Leaders and Management. 

• FHWA is looking to streamline our internal programs (EEO, Reasonable Accommodations, and AntiHarassment) outreach by establishing an Internal Programs Bootcamp. The internal programs boot 

camp would be a combination of training and program site visits to convey requirements. 

• FHWA EEO Awareness Day will be planned for a fiscal year 2021 rollout. It will be an all-day event 

and resource for FHWA employees to hear perspectives on internal Civil Rights programs. 

• FHWA will complete a Reasonable Accommodations Handbook that is a tool for Managers to 

understand their role and responsibilities. 

• FHWA plans to continue to revamp 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. 

• FHWA will continue create an inclusive organization 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 continue to develop 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 will 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. 

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

the DOT Disability Resource Center and how their services benefit FHWA’s workforce. 

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

Program for Diverse Groups (STIPDG) as well as the PDP amongst colleges and universities. 

• 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 nine mission critical occupations. 

• FHWA will continue to utilize and expand the DMC Diversity Champions program to reach the goal of 

having 100% representation across business units, including the support of Employee Resource 

groups through our Women’s Forum Webinar series. 

Page 9 
 

 

 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

 FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

C FORM 

715-01

U.S. Equal Employment Opportunity Commission

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. 

Digitally signed by IRENE RICO IRENE RICO Date: 2020.06.09 16:19:21 -04'00' 

Signature of Principal EEO Director/Official Date 

Certifies that this Federal Agency Annual EEO Program Status Report is in compliance with EEO MD-715. 

6/30/2020

Signature of Agency Head or Agency Head Designee Date 
EEOC FORM 

715-02 

PART G 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Essential Element: A Demonstrated Commitment From agency Leadership 

Compliance 

Indicator 

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

Measures 

Measure Has 

Been Met 

Yes No N/A 

For all unmet 

measures, provide 

a 

brief explanation 

in 

the space below or 

complete and 

attach 

an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

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, ll(A)] 

X The Departmental 

Office of Civil 

Rights issued the 

DOT EEO Policy 

statements on 

behalf of the 

Department on 

April 24, 2018. 

4/24/2018 

A.1.b. Does the EEO policy statement address all protected bases (age, color, disability, sex (including X 

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)] If the EEO policy statement covers 

any additional bases (e.g., marital status, veteran status and political affiliation), please list them in the 

comments column. 

Page 11 
 

 

 

 

 

 

 

 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or 

A.2. The agency has communicated EEO policies and procedures to all employees. complete and 

attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

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, ll(A)] X 

A.2.a.2. Reasonable accommodation procedures? [see 29 CFR § 1614.203(d)(3)] X FHWA uses the 

Department’s 

Reasonable 

Accommodation 

Policy 

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 X https:// 

Managers, and EEO Director? [see 29 C.F.R § 1614.102(b)(7)] www.fhwa.dot.gov/ 

civilrights/ 

A.2.b.2. Written materials concerning the EEO program, laws, policy statements, and the operation of the EEO X https:// 

complaint process? [see 29 CFR §1614.102(b)(5)] www.fhwa.dot.gov/ 

civilrights/ 

programs/eeo/ 

A.2.b.3. Reasonable accommodation procedures? [see 29 CFR § 1614.203(d)(3)(i)] If so, please provide the X https:// 

internet address in the comments column. www.transportation.gov/ 

civil-rights/civilrights-awarenessenforcement/ 

proceduresprocessingreasonableaccommodation 

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 X Annually 

how often and the means by which such training is delivered. 

A.2.c.2. ADR process? [see MD-110, Ch. 3(II)(C)] If “yes”, please provide how often. X Annually 

A.2.c.3. Reasonable accommodation program? [see 29 CFR § 1614.203(d)(7)(ii)(C)] If “yes”, please provide X Annually 

how often. 

A.2.c.4. Anti-harassment program? [see EEOC Enforcement Guidance on Vicarious Employer Liability for X Annually FHWA 

Unlawful Harassment by Supervisors (1999), § V.C.1] If “yes”, please provide how often. has an AntiHarassment 

program that was 

established 

October 10, 2017. 

https:// 

www.fhwa.dot.gov/ 

civilrights/ 

programs/antiharassment/ 

resources.cfm 

Page 12 
 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

A.2.c.5. Behaviors that are inappropriate in the workplace and could result in disciplinary action? [5 CFR X Annually via 

§2635.101(b)] If “yes”, please provide how often. mandatory 

harassment 

training. Also, 

continuously via 

the FHWA Table 

of Offenses and 

Penalties, which 

is posted on 

FHWA’s internal 

intranet site. http:// 

staffnet.fhwa.dot.gov/ 

hr/regulations/ 

handbook/ 

appendix_a.htm#d 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or 

A.3. The agency assesses and ensures EEO principles are part of its culture. complete and 

attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

A.3.a. Does the agency provide recognition to employees, supervisors, managers and units demonstrating X The Agency 

superior accomplishment in equal employment opportunity? [see 29 CFR § 1614.102(a)(9)] If “yes”, provide established a 

one or two examples in the comments section. . Diversity & 

Inclusion award 

in 2017 as a part 

of the 

Administrator’s 

Awards Program. 

The Department 

also has a 

Secretary’s 

Awards Program, 

which recognizes 

employees for 

accomplishments 

in EEO and the 

Agency has 

consistently 

nominated 

FHWA 

employees for 

those honors. 

A.3.b. Does the agency utilize the Federal Employee Viewpoint Survey or other climate assessment tools to X Annually for 

monitor the perception of EEO principles within the workforce? [see 5 CFR Part 250]' FEVS and Every 

2 years for 

FHWA’s All 

Employee Survey. 

Page 13 
 

 

 

 

 

EEOC FORM 

715-02 

PART G 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

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

Compliance Measure Has For all unmet 

Indicator Been Met measures, provide 

a 

brief explanation 

in 

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. Measures Yes No N/A 

the space below or 

complete and 

attach 

an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

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)] 

X The Associate 

Administrator for 

Civil Rights 

Reports to the 

Agency Executive 

Director who is 

the Agency’s top 

career employee. 

The Executive 

Director is 

responsible for all 

workforce matters 

in the Agency. 

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. 

X The Associate 

Administrator for 

Civil Rights 

reports to the 

Executive 

Director. The 

Executive 

Director is 

responsible for all 

workforce matters 

in the Agency. 

B.1.a.2. Does the agency’s organizational chart clearly define the reporting structure for the EEO office? [see 29 X 

CFR §1614.102(b)(4)] 

B.1.b. Does the EEO Director have a regular and effective means of advising the agency head and other senior X 

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] 

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. 

X The Associate 

Administrator 

presented to 

Agency 

leadership the 

“State of the 

Agency” briefing 

on March 29, 2019 

B.1.d. Does the EEO Director regularly participate in senior-level staff meetings concerning personnel, budget, X 

technology, and other workforce issues? [see MD-715, II(B)] 

Page 14 
 

 

 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or 

B.2. The EEO Director controls all aspects of the EEO program. complete and 

attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

B.2.a. Is the EEO Director responsible for the implementation of a continuing affirmative employment program X 

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)] If not, identify the office with this authority in the comments column. 

B.2.b. Is the EEO Director responsible for overseeing the completion of EEO counseling? [see 29 CFR X 

§1614.102(c)(4)] 

B.2.c. Is the EEO Director responsible for overseeing the fair and thorough investigation of EEO complaints? X Investigations are 

[see 29 CFR §1614.102(c)(5)] [This question may not be applicable for certain subordinate level components.] handled at the 

Departmental 

Office of Civil 

Rights. 

B.2.d. Is the EEO Director responsible for overseeing the timely issuance of final agency decisions? [see 29 X Issuance of final 

CFR §1614.102(c)(5)] [This question may not be applicable for certain subordinate level components.] Agency decisions 

occurs at the 

Departmental 

Office of Civil 

Rights. 

B.2.e. Is the EEO Director responsible for ensuring compliance with EEOC orders? [see 29 CFR §§ X 

1614.102(e); 1614.502]' 

B.2.f. Is the EEO Director responsible for periodically evaluating the entire EEO program and providing X 

recommendations for improvement to the agency head? [see 29 CFR §1614.102(c)(2)] 

B.2.g. If the agency has subordinate level components, does the EEO Director provide effective guidance and X This function is 

coordination for the components? [see 29 CFR §§ 1614.102(c)(2); (c)(3)] handled by the 

Departmental 

Office of Civil 

Rights. 

Page 15 
 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or B.3. The EEO Director and other EEO professional staff are involved in, and complete and consulted on, management/personnel actions. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

B.3.a. Do EEO program officials participate in agency meetings regarding workforce changes that might impact X 

EEO issues, including strategic planning, recruitment strategies, vacancy projections, succession planning, and 

selections for training/career development opportunities? [see MD-715, II(B)] 

B.3.b. Does the agency’s current strategic plan reference EEO / diversity and inclusion principles? [see X FHWA strategic 

MD-715, II(B)] If “yes”, please identify the EEO principles in the strategic plan in the comments column. 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 

INPUT 

performance 

tracking system. 

(This information 

is provided as 

supplemental 

documentation to 

this report) 

Page 16 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or B.4. The agency has sufficient budget and staffing to support the success of its complete and EEO program. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

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)] X 

B.4.a.10. to effectively manage its reasonable accommodation program? [see 29 CFR §1614.203(d)(4)(ii)] X 

B.4.a.11. to ensure timely and complete compliance with EEOC orders? [see MD-715, II(E)] X 

B.4.a.2. to enable the agency to conduct a thorough barrier analysis of its workforce? [see MD-715, II(B)] X 

B.4.a.3. to timely, thoroughly, and fairly process EEO complaints, including EEO counseling, investigations, X 

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)] 

B.4.a.4. to provide all supervisors and employees with training on the EEO program, including but not limited to X 

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. 

B.4.a.5. to conduct thorough, accurate, and effective field audits of the EEO programs in components and the X 

field offices, if applicable? [see 29 CFR §1614.102(c)(2)] 

B.4.a.6. to publish and distribute EEO materials (e.g. harassment policies, EEO posters, reasonable X 

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

B.4.a.7. to maintain accurate data collection and tracking systems for the following types of data: complaint X 

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. 

B.4.a.8. to effectively administer its special emphasis programs (such as, Federal Women’s Program, Hispanic X 

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] 

B.4.a.9. to effectively manage its anti-harassment program? [see MD-715 Instructions, Sec. I; EEOC X 

Enforcement Guidance on Vicarious Employer Liability for Unlawful Harassment by Supervisors (1999), § V.C. 

1] 

B.4.b. Does the EEO office have a budget that is separate from other offices within the agency? [see 29 CFR § X 

1614.102(a)(1)] 

B.4.c. Are the duties and responsibilities of EEO officials clearly defined? [see MD-110, Ch. 1(III)(A), 2(III), & X 

6(III)] 

B.4.d. Does the agency ensure that all new counselors and investigators, including contractors and collateral X Investigators are 

duty employees, receive the required 32 hours of training, pursuant to Ch. 2(II) (A) of MD-110? overseen at the 

Departmental 

level. 

B.4.e. Does the agency ensure that all experienced counselors and investigators, including contractors and X Investigators are 

collateral duty employees, receive the required 8 hours of annual refresher training, pursuant to Ch. 2(II)(C) of overseen at the 

MD-110? Departmental 

level. 

Page 17 
 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or B.5. The agency recruits, hires, develops, and retains supervisors and managers complete and who have effective managerial, communications, and interpersonal skills attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

B.5.a. Pursuant to 29 CFR §1614.102(a)(5), have all managers and supervisors received orientation, training, 

and advice on their responsibilities under the following areas under the agency EEO program: 

B.5.a.1. EEO complaint process? [see MD-715(II)(B)] X 

B.5.a.2. Reasonable Accommodation Procedures? [see 29 CFR § 1614.102(d)(3)] X 

B.5.a.3. Anti-harassment policy? [see MD-715(II)(B)] X FHWA’s efforts 

to train 

supervisors were 

put on hold in 

FY19 due to the 

Pilot AntiHarassment 

Process being 

converted to 

Permanent AntiHarassment 

Process. FHWA 

focused its 

resources in the 

development of 

the Permanent 

Anti-Harassment 

Process that 

aligns with 

DOT’s AntiHarassment 

Framework. 

FHWA then 

worked on 

developing a 

rollout of the new 

process (See page 

31 of PDF). 

B.5.a.4. Supervisory, managerial, communication and interpersonal skills in order to supervise most effectively X 

in a workplace with diverse employees and avoid disputes arising from ineffective communications? [see 

MD-715, II(B)] 

B.5.a.5. ADR, with emphasis on the federal government’s interest in encouraging mutual resolution of disputes X FHWA has begun 

and the benefits associated with utilizing ADR? [see MD-715(II)(E)] the training for all 

Managers but has 

not completed it. 

Page 18 
EEOC FORM 

715-02 

PART G 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Compliance 

Indicator 

B.6. The agency involves managers in the implementation of its EEO program. 

Measures 

Measure Has 

Been Met 

Yes No N/A 

For all unmet 

measures, provide 

a 

brief explanation 

in 

the space below or 

complete and 

attach 

an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

B.6.a. Are senior managers involved in the implementation of Special Emphasis Programs? [see MD-715 X 

Instructions, Sec. I] 

B.6.b. Do senior managers participate in the barrier analysis process? [see MD-715 Instructions, Sec. I] X 

B.6.c. When barriers are identified, do senior managers assist in developing agency EEO action plans (Part I, X 

Part J, or the Executive Summary)? [see MD-715 Instructions, Sec. I] 

B.6.d. Do senior managers successfully implement EEO Action Plans and incorporate the EEO Action Plan X 

Objectives into agency strategic plans? [29 CFR §1614.102(a)(5)] 

Page 19 
EEOC FORM 

715-02 

PART G 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Essential Element: C Management and Program Accountability 

Compliance 

Indicator 

C.1. The agency conducts regular internal audits of its component and field offices. 

Measures 

Measure Has 

Been Met 

Yes No N/A 

For all unmet 

measures, provide 

a 

brief explanation 

in 

the space below or 

complete and 

attach 

an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

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. 

X FHWA 

periodically on an 

annual basis 

accesses its field 

offices for 

possible EEO 

deficiencies. 

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. 

X FHWA annually 

conducts 

assessments on 

the Agency’s 

efforts to remove 

barriers from the 

workplace. 

C.1.c. Do the component and field offices make reasonable efforts to comply with the recommendations of the X 

field audit? [see MD-715, II(C)] 

Page 20 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or C.2. The agency has established procedures to prevent all forms of EEO complete and discrimination. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

C.2.a. Has the agency established comprehensive anti-harassment policy and procedures that comply with X FHWA AntiEEOC’s enforcement guidance? [see MD-715, II(C); Enforcement Guidance on Vicarious Employer Liability Harassment 

for Unlawful Harassment by Supervisors (Enforcement Guidance), EEOC No. 915.002, § V.C.1 (June 18, 1999)] policy and 

procedures have 

been updated 

C.2.a.1. Does the anti-harassment policy require corrective action to prevent or eliminate conduct before it rises X 

to the level of unlawful harassment? [see EEOC Enforcement Guidance on Vicarious Employer Liability for 

Unlawful Harassment by Supervisors (1999), § V.C.1] 

C.2.a.2. Has the agency established a firewall between the Anti-Harassment Coordinator and the EEO Director? X 

[see EEOC Report, Model EEO Program Must Have an Effective Anti-Harassment Program (2006)] 

C.2.a.3. Does the agency have a separate procedure (outside the EEO complaint process) to address harassment X 

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)] 

C.2.a.4. Does the agency ensure that the EEO office informs the anti-harassment program of all EEO counseling X Beginning in 

activity alleging harassment? [See Enforcement Guidance, V.C.] March 2019. 

C.2.a.5. Does the agency conduct a prompt inquiry (beginning within 10 days of notification) of all harassment X Beginning in 

allegations, including those initially raised in the EEO complaint process? [see Complainant v. Dep’t of March 2019. 

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. 

C.2.a.6. Do the agency’s training materials on its anti-harassment policy include examples of disability-based X 

harassment? [see 29 CFR §1614.203(d)(2)] 

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

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

Department’s RA 

procedures. 

C.2.b.1. Is there a designated agency official or other mechanism in place to coordinate or assist with processing X 

requests for disability accommodations throughout the agency? [see 29 CFR §1614.203(d)(3)(D)] 

C.2.b.2. Has the agency established a firewall between the Reasonable Accommodation Program Manager and X 

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

C.2.b.3. Does the agency ensure that job applicants can request and receive reasonable accommodations during X 

the application and placement processes? [see 29 CFR §1614.203(d)(1)(ii)(B)] 

C.2.b.4. Do the reasonable accommodation procedures clearly state that the agency should process the request X 

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)] 

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

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

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

column. 

C.2.c. Has the agency established procedures for processing requests for personal assistance services that X FHWA currently 

comply with EEOC’s regulations, enforcement guidance, and other applicable executive orders, guidance, and follows the 

standards? [see 29 CFR §1614.203(d)(6)] Department’s 

procedures. 

Page 21 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

C.2.c.1. Does the agency post its procedures for processing requests for Personal Assistance Services on its X https:// 

public website? [see 29 CFR §1614.203(d)(5)(v)] If “yes”, please provide the internet address in the comments www.transportation.gov/ 

column. drc/personalassistance-asreasonableaccommodation 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or C.3. The agency evaluates managers and supervisors on their efforts to ensure complete and equal employment opportunity. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

C.3.a. Pursuant to 29 CFR §1614.102(a)(5), do all managers and supervisors have an element in their X 

performance appraisal that evaluates their commitment to agency EEO policies and principles and their 

participation in the EEO program? 

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 X 

MD-110, Ch. 3.I] 

C.3.b.2. Ensure full cooperation of employees under his/her supervision with EEO officials, such as counselors X 

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

C.3.b.3. Ensure a workplace that is free from all forms of discrimination, including harassment and retaliation? X 

[see MD-715, II(C)] 

C.3.b.4. Ensure that subordinate supervisors have effective managerial, communication, and interpersonal skills X 

to supervise in a workplace with diverse employees? [see MD-715 Instructions, Sec. I] 

C.3.b.5. Provide religious accommodations when such accommodations do not cause an undue hardship? [see X 

29 CFR §1614.102(a)(7)] 

C.3.b.6. Provide disability accommodations when such accommodations do not cause an undue hardship? [ see X 

29 CFR §1614.102(a)(8)] 

C.3.b.7. Support the EEO program in identifying and removing barriers to equal opportunity?. [see MD-715, X 

II(C)] 

C.3.b.8. Support the anti-harassment program in investigating and correcting harassing conduct?. [see X 

Enforcement Guidance, V.C.2] 

C.3.b.9. Comply with settlement agreements and orders issued by the agency, EEOC, and EEO-related cases X 

from the Merit Systems Protection Board, labor arbitrators, and the Federal Labor Relations Authority? [see 

MD-715, II(C)] 

C.3.c. Does the EEO Director recommend to the agency head improvements or corrections, including remedial X Recommendations 

or disciplinary actions, for managers and supervisors who have failed in their EEO responsibilities? [see 29 CFR for corrections are 

§1614.102(c)(2)] handled at the 

Departmental 

Office of Civil 

Rights . 

C.3.d. When the EEO Director recommends remedial or disciplinary actions, are the recommendations regularly X This situation has 

implemented by the agency? [see 29 CFR §1614.102(c)(2)] not occurred. 

Page 22 
 

 

 

 

 

 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or C.4. The agency ensures effective coordination between its EEO program and complete and Human Resources (HR) program. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

C.4.a. Do the HR Director and the EEO Director meet regularly to assess whether personnel programs, policies, X 

and procedures conform to EEOC laws, instructions, and management directives? [see 29 CFR §1614.102(a)(2)] 

C.4.b. Has the agency established timetables/schedules to review at regular intervals its merit promotion X 

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] 

C.4.c. Does the EEO office have timely access to accurate and complete data (e.g., demographic data for the X 

workforce, applicants, training programs, etc.) required to prepare the MD-715 workforce data tables? [see 29 

CFR §1614.601(a)] 

C.4.d. Does the HR office timely provide the EEO office with access to other data (e.g., exit interview data, X 

climate assessment surveys, and grievance data), upon request? [see MD-715, II(C)] 

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); X 

MD-715, II(C)] 

C.4.e.2. Develop and/or conduct outreach and recruiting initiatives? [see MD-715, II(C)] X 

C.4.e.3. Develop and/or provide training for managers and employees? [see MD-715, II(C)] X 

C.4.e.4. Identify and remove barriers to equal opportunity in the workplace? [see MD-715, II(C)] X 

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

Page 23 
 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or C.5. Following a finding of discrimination, the agency explores whether it should complete and take a disciplinary action. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

C.5.a. Does the agency have a disciplinary policy and/or table of penalties that covers discriminatory conduct? X http:// 

[see 29 CFR §1614.102(a)(6); see also Douglas v. Veterans Administration, 5 MSPR 280 (1981)] staffnet.fhwa.dot.gov/ 

hr/regulations/ 

handbook/ 

appendix_a.htm 

C.5.b. When appropriate, does the agency discipline or sanction managers and employees for discriminatory X Although the 

conduct? [see 29 CFR §1614.102(a)(6)] If “yes”, please state the number of disciplined/sanctioned individuals Agency takes 

during this reporting period in the comments. appropriate 

action, there were 

no reported 

actions this year. 

C.5.c. If the agency has a finding of discrimination (or settles cases in which a finding was likely), does the X Information is 

agency inform managers and supervisors about the discriminatory conduct (e.g., post mortem to discuss lessons provided in 

learned)? [see MD-715, II(C)] appropriate cases. 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or 

C.6. The EEO office advises managers/supervisors on EEO matters. complete and 

attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

C.6.a. Does the EEO office provide management/supervisory officials with regular EEO updates on at least an X This is discussed 

annual basis, including EEO complaints, workforce demographics and data summaries, legal updates, barrier annually within 

analysis plans, and special emphasis updates? [see MD-715 Instructions, Sec. I] If “yes”, please identify the FHWA. 

frequency of the EEO updates in the comments column. 

C.6.b. Are EEO officials readily available to answer managers’ and supervisors’ questions or concerns? [see X 

MD-715 Instructions, Sec. I] 

Page 24 
EEOC FORM 

715-02 

PART G 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Essential Element: D Proactive Prevention 

Compliance 

Indicator 

Measures 

D.1. The agency conducts a reasonable assessment to monitor progress towards 

achieving equal employment opportunity throughout the year. 

Measure Has 

Been Met 

Yes No N/A 

For all unmet 

measures, provide 

a 

brief explanation 

in 

the space below or 

complete and 

attach 

an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

D.1.a. Does the agency have a process for identifying triggers in the workplace? [see MD-715 Instructions, Sec. X 

I] 

D.1.b. Does the agency regularly use the following sources of information for trigger identification: workforce X 

data; complaint/grievance data; exit surveys; employee climate surveys; focus groups; affinity groups; union; 

program evaluations; special emphasis programs; and/or external special interest groups? [see MD-715 

Instructions, Sec. I] 

D.1.c. Does the agency conduct exit interviews or surveys that include questions on how the agency could X 

improve the recruitment, hiring, inclusion, retention and advancement of individuals with disabilities? [see 29 

CFR §1614.203(d)(1)(iii)(C)] 

Compliance 

Indicator 

Measures 

D.2. The agency identifies areas where barriers may exclude EEO groups 

(reasonable basis to act.) 

Measure Has 

Been Met 

Yes No N/A 

For all unmet 

measures, provide 

a 

brief explanation 

in 

the space below or 

complete and 

attach 

an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

D.2.a. Does the agency have a process for analyzing the identified triggers to find possible barriers? [see X 

MD-715, (II)(B)] 

D.2.b. Does the agency regularly examine the impact of management/personnel policies, procedures, and X 

practices by race, national origin, sex, and disability? [see 29 CFR §1614.102(a)(3)] 

D.2.c. Does the agency consider whether any group of employees or applicants might be negatively impacted X 

prior to making human resource decisions, such as re-organizations and realignments? [see 29 CFR §1614.102(a) 

(3)] 

D.2.d. Does the agency regularly review the following sources of information to find barriers: complaint/ X Complaint/ 

grievance data, exit surveys, employee climate surveys, focus groups, affinity groups, union, program grievance data, 

evaluations, anti-harassment program, special emphasis programs, and/or external special interest groups? [see exit surveys, 

MD-715 Instructions, Sec. I]] If “yes”, please identify the data sources in the comments column. employee climate 

surveys, focus 

groups, affinity 

groups, AntiHarassment 

Program, special 

emphasis 

programs, and the 

Reasonable 

Accommodation 

Program. 

Page 25 
 

 

 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or 

D.3. The agency establishes appropriate action plans to remove identified barriers. complete and 

attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

D.3.a. Does the agency effectively tailor action plans to address the identified barriers, in particular policies, X 

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 X 

in Part I, including meeting the target dates for the planned activities? [see MD-715, II(D)] 

D.3.c. Does the agency periodically review the effectiveness of the plans? [see MD-715, II(D)] X 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or D.4. The agency has an affirmative action plan for people with disabilities, complete and including those with targeted disabilities. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

D.4.a. Does the agency post its affirmative action plan on its public website? [see 29 CFR §1614.203(d)(4)] If X https:// 

yes, please provide the internet address in the comments. www.fhwa.dot.gov/ 

civilrights 

D.4.b. Does the agency take specific steps to ensure qualified people with disabilities are aware of and X 

encouraged to apply for job vacancies? [see 29 CFR §1614.203(d)(1)(i)] 

D.4.c. Does the agency ensure that disability-related questions from members of the public are answered X 

promptly and correctly? [see 29 CFR §1614.203(d)(1)(ii)(A)] 

D.4.d. Has the agency taken specific steps that are reasonably designed to increase the number of persons with X 

disabilities or targeted disabilities employed at the agency until it meets the goals? [see 29 CFR §1614.203(d)(7) 

(ii)] 

Page 26 
EEOC FORM 

715-02 

PART G 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Essential Element: E Efficiency 

Page 27 
EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or E.1. The agency maintains an efficient, fair, and impartial complaint resolution complete and process. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

E.1.a. Does the agency timely provide EEO counseling, pursuant to 29 CFR §1614.105? X 

E.1.b. Does the agency provide written notification of rights and responsibilities in the EEO process during the X 

initial counseling session, pursuant to 29 CFR §1614.105(b)(1)? 

E.1.c. Does the agency issue acknowledgment letters immediately upon receipt of a formal complaint, pursuant X This function is 

to MD-110, Ch. 5(I)? handled by the 

Departmental 

Office of Civil 

Rights. 

E.1.d. Does the agency issue acceptance letters/dismissal decisions within a reasonable time (e.g., 60 days) after X This function is 

receipt of the written EEO Counselor report, pursuant to MD-110, Ch. 5(I)? If so, please provide the average handled by the 

processing time in the comments. Departmental 

Office of Civil 

Rights. 

E.1.e. Does the agency ensure that all employees fully cooperate with EEO counselors and EEO personnel in the X 

EEO process, including granting routine access to personnel records related to an investigation, pursuant to 29 

CFR §1614.102(b)(6)? 

E.1.f. Does the agency timely complete investigations, pursuant to 29 CFR §1614.108? X This function is 

handled by the 

Departmental 

Office of Civil 

Rights. 

E.1.g. If the agency does not timely complete investigations, does the agency notify complainants of the date by X This function is 

which the investigation will be completed and of their right to request a hearing or file a lawsuit, pursuant to 29 handled by the 

CFR §1614.108(g)? Departmental 

Office of Civil 

Rights. 

E.1.h. When the complainant did not request a hearing, does the agency timely issue the final agency decision, X This function is 

pursuant to 29 CFR §1614.110(b)? handled by the 

Departmental 

Office of Civil 

Rights. 

E.1.i. Does the agency timely issue final actions following receipt of the hearing file and the administrative X This function is 

judge’s decision, pursuant to 29 CFR §1614.110(a)? handled by the 

Departmental 

Office of Civil 

Rights. 

Page 28 
 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission

715-02 FEDERAL AGENCY ANNUAL

PART G EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

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. 

X FHWA does not 

use contractors 

for its stages of 

the EEO process. 

To the extent 

contractors are 

used, this is 

handled by the 

Departmental 

Office of Civil 

Rights. 

E.1.k. If the agency uses employees to implement any stage of the EEO complaint process, does the agency hold X 

them accountable for poor work product and/or delays during performance review? [See MD-110, Ch. 5(V)(A)] 

E.1.l. Does the agency submit complaint files and other documents in the proper format to EEOC through the X This function is 

Federal Sector EEO Portal (FedSEP)? [See 29 CFR § 1614.403(g)] handled by the 

Departmental 

Office of Civil 

Rights. 

Page 29 
EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or 

E.2. The agency has a neutral EEO process. complete and 

attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

E.2.a. Has the agency established a clear separation between its EEO complaint program and its defensive X There is a clear 

function? [see MD-110, Ch. 1(IV)(D)] If “yes”, please explain. distinction 

between 

leadership of the 

Office of Civil 

Rights and the 

Office of Chief 

Counsel in 

managing the 

complaint 

programs and 

defensive 

functions. 

E.2.b. When seeking legal sufficiency reviews, does the EEO office have access to sufficient legal resources X Legal sufficiency 

separate from the agency representative? [see MD-110, Ch. 1(IV)(D)] If “yes”, please identify the source/ reviews are 

location of the attorney who conducts the legal sufficiency review in the comments column. handled at the 

Departmental 

level. 

E.2.c. If the EEO office relies on the agency’s defensive function to conduct the legal sufficiency review, is X Legal sufficiency 

there a firewall between the reviewing attorney and the agency representative? [see MD-110, Ch. 1(IV)(D)] reviews are 

handled at the 

Departmental 

level. 

E.2.d. Does the agency ensure that its agency representative does not intrude upon EEO counseling, X 

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

E.2.e. If applicable, are processing time frames incorporated for the legal counsel’s sufficiency review for timely X Legal sufficiency 

processing of complaints? [see EEOC Report, Attaining a Model Agency Program: Efficiency (Dec. 1, 2004)] reviews are 

handled at the 

Departmental 

level. 

Page 30 
EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or E.3. The agency has established and encouraged the widespread use of a fair complete and alternative dispute resolution (ADR) program. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

E.3.a. Has the agency established an ADR program for use during both the pre-complaint and formal complaint X 

stages of the EEO process? [see 29 CFR §1614.102(b)(2)] 

E.3.b. Does the agency require managers and supervisors to participate in ADR once it has been offered? [see X Mandatory 

MD-715, II(A)(1)] participation is 

required of 

managers and 

supervisors once 

offered and 

Aggrieved Person 

elects. 

E.3.c. Does the Agency encourage all employees to use ADR, where ADR is appropriate? [See MD-110, Ch. X 

3(IV)(C)] 

E.3.d. Does the agency ensure a management official with settlement authority is accessible during the dispute X 

resolution process? [see MD-110, Ch. 3(III)(A)(9)] 

E.3.e. Does the agency prohibit the responsible management official named in the dispute from having X 

settlement authority? [see MD-110, Ch. 3(I)] 

E.3.f. Does the agency annually evaluate the effectiveness of its ADR program? [see MD-110, Ch. 3(II)(D)] X This assessment 

is handled at the 

Departmental 

level. 

Page 31 
 

 

 

 

 

 

 

 

EEOC FORM 

715-02 

PART G 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Compliance 

Indicator 

Measures 

E.4. The agency has effective and accurate data collection systems in place to 

evaluate its EEO program. 

Measure Has 

Been Met 

Yes No N/A 

For all unmet 

measures, provide 

a 

brief explanation 

in 

the space below or 

complete and 

attach 

an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

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)] 

X 

E.4.a.2. The race, national origin, sex, and disability status of agency employees? [see 29 CFR §1614.601(a)] X 

E.4.a.3. Recruitment activities? [see MD-715, II(E)] X 

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)] 

X 

E.4.a.5. The processing of requests for reasonable accommodation? [29 CFR §1614.203(d)(4)] X 

E.4.a.6. The processing of complaints for the anti-harassment program? [see EEOC Enforcement Guidance on 

Vicarious Employer Liability for Unlawful Harassment by Supervisors (1999), § V.C.2] 

X 

E.4.b. Does the agency have a system in place to re-survey the workforce on a regular basis? [MD-715 

Instructions, Sec. I] 

X 

Page 32 
EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or E.5. The agency identifies and disseminates significant trends and best practices in complete and its EEO program. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

E.5.a. Does the agency monitor trends in its EEO program to determine whether the agency is meeting its X Reviews Annual 

obligations under the statutes EEOC enforces? [see MD-715, II(E)] If “yes”, provide an example in the Federal Equal 

comments. Employment 

Opportunity 

Statistical Report 

of Discrimination 

Complaints 

(EEOC Form 

462) to develop 

and provide 

training in EEO 

areas. 

E.5.b. Does the agency review other agencies’ best practices and adopt them, where appropriate, to improve the X Adopted a best 

effectiveness of its EEO program? [see MD-715, II(E)] If “yes”, provide an example in the comments. practice from 

GSA. EEO 

counselors 

provide initial 

contact form to 

Aggrieved 

Persons to review 

for accuracy of 

EEO allegations. 

E.5.c. Does the agency compare its performance in the EEO process to other federal agencies of similar size? X 

[see MD-715, II(E)] 

Page 33 
EEOC FORM 

715-02 

PART G 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Essential Element: F Responsiveness and Legal Compliance 

Compliance 

Indicator 

Measures 

F.1. The agency has processes in place to ensure timely and full compliance with 

EEOC orders and settlement agreements. 

Measure Has 

Been Met 

Yes No N/A 

For all unmet 

measures, provide 

a 

brief explanation 

in 

the space below or 

complete and 

attach 

an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

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)] 

X 

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)] 

X 

F.1.c. Are there procedures in place to ensure the timely and predictable processing of ordered monetary relief? 

[see MD-715, II(F)] 

X 

F.1.d. Are procedures in place to process other forms of ordered relief promptly? [see MD-715, II(F)] X 

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)] 

X Compliance 

Officer is at the 

Departmental 

Level. 

Page 34 
EEOC FORM 

715-02 

PART G 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Agency Self-Assessment Checklist 

Compliance 

Indicator 

Measures 

F.2. The agency complies with the law, including EEOC regulations, management 

directives, orders, and other written instructions. 

Measure Has 

Been Met 

Yes No N/A 

For all unmet 

measures, provide 

a 

brief explanation 

in 

the space below or 

complete and 

attach 

an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

F.2.a. Does the agency timely respond and fully comply with EEOC orders? [see 29 CFR §1614.502; MD-715, 

II(E)] 

X 

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)] 

X This function is 

handled by the 

Departmental 

Office of Civil 

Rights. 

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] 

X FHWA notes, 

however, that 

there have not 

been any such 

findings in recent 

years. 

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)] 

X This function is 

handled by the 

Departmental 

Office of Civil 

Rights. 

F.2.a.4. Pursuant to 29 CFR §1614.502, does the agency promptly provide EEOC with the required 

documentation for completing compliance? 

X This function is 

handled by the 

Departmental 

Office of Civil 

Rights. 

Compliance 

Indicator 

F.3. The agency reports to EEOC its program efforts and accomplishments. 

Measures 

Measure Has 

Been Met 

Yes No N/A 

For all unmet 

measures, provide 

a 

brief explanation 

in 

the space below or 

complete and 

attach 

an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

F.3.a. Does the agency timely submit to EEOC an accurate and complete No FEAR Act report? [Public Law X 

107-174 (May 15, 2002), §203(a)] 

F.3.b. Does the agency timely post on its public webpage its quarterly No FEAR Act data? [see 29 CFR X 

§1614.703(d)] 

Essential Element: O Other 

Page 35 
EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART H EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Plan to Attain Essential Elements 

PART H.1

 STATEMENT of

 MODEL PROGRAM B.5.a.3. Anti-harassment policy? [see MD-715(II)(B)] ESSENTIAL ELEMENT

 DEFICIENCY: 

The Agency has not trained all employees (supervisory and non-supervisory) on DOT’s anti-harassment policies 

OBJECTIVE: 

Responsible Official 

PlannedActivities 

Report of Accomplishments 

and Modifications to 

Objective 

Date Objective Initiated: Target Date For Completion Of Initiative: 

Dec 1, 2016 Dec 1, 2016 

To ensure that all managers/supervisors are trained on anti-harassment policies. 

Irene Rico 

Target Date Planned Activity 

Sep 30, 2017 12:00 Identify available training module and/or develop and implement a training module 

AM for anti-harassment policies 

Sep 30, 2017 12:00 Present webinars, in person training and/ or web-based sessions to be delivered and/ 

AM or offered to managers, supervisors and employees 

The mandatory training began in FY 18 and will continue each FY that follows, via a series of 

Webinars and in person sessions. Proactive prevention is the best tool to prevent harassment in the 

workplace. Therefore, FHWA’s training focuses on prevention and employee involvement in creating 

a civil and inclusive culture within the workplace. 

On June 21, 2019, the Department issued its Policy Framework for the Prevention of Harassment, 

which, among other things, requires each mode to develop an anti-harassment process incorporating 

certain parameters, and submit that process for OST review within 90 days. The FHWA pilot process 

already met many of the Framework’s requirements but did not meet others. Since the issuance of 

the Framework, the workgroup has been working to revise the FHWA pilot process to conform to the 

Framework’s requirements. Similar to the Pilot process, the proposed FHWA Anti-Harassment 

Process addresses allegations of any type of harassment in or relating to the FHWA workplace. 

Based on the Policy Framework FHWA submitted the updated procedures to OST for approval on 

September 19, 2019. On November 19, 2019, FHWA received final approval for its process. The 

FHWA communicated the approval and the new process to all employees on December 18, 2019, via 

email. Training FHWA secured a contract for FY 2020 Anti-Harassment Training. This contract will 

provide anti-harassment training to all FHWA employees. 

Training FY2020 Anti-Harassment Training of Managers/Supervisors (Agency Leaders, Headquarters 

Management, and Field Management) is in process in FY 2020. Over seven in-person and virtual 

sessions for the Prevention of Harassment are being scheduled. In addition, FHWA developed and 

released the Anti-Harassment Toolkit for Managers that is a comprehensive resource to managers to 

understand their roles and responsibilities. 

Page 36 
EEOC FORM 

715-02 

PART H 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration 

Pla

For period covering October 1, 2018 to September 30, 2019 

n to Attain Essential Elements 

Date Objective Initiated: Target Date For Completion Of Initiative: 

Sep 30, 2017 Sep 30, 2017 

Identify available training module and/or develop and implement a training module for anti-harassment policies 

OBJECTIVE: 

Responsible Official Irene Rico 

PlannedActivities 

Report of Accomplishments 

and Modifications to 

Objective 

Target Date Planned Activity 

Sep 30, 2017 12:00 Identify available training module and/or develop and implement a training module 

AM for anti-harassment policies 

Sep 30, 2017 12:00 Present webinars, in person training and/ or web-based sessions to be delivered and/ 

AM or offered to managers, supervisors and employees 

The mandatory training began in FY 18 and will continue each FY that follows, via a series of 

Webinars and in person sessions. Proactive prevention is the best tool to prevent harassment in the 

workplace. Therefore, FHWA’s training focuses on prevention and employee involvement in creating 

a civil and inclusive culture within the workplace. 

On June 21, 2019, the Department issued its Policy Framework for the Prevention of Harassment, 

which, among other things, requires each mode to develop an anti-harassment process incorporating 

certain parameters, and submit that process for OST review within 90 days. The FHWA pilot process 

already met many of the Framework’s requirements but did not meet others. Since the issuance of 

the Framework, the workgroup has been working to revise the FHWA pilot process to conform to the 

Framework’s requirements. Similar to the Pilot process, the proposed FHWA Anti-Harassment 

Process addresses allegations of any type of harassment in or relating to the FHWA workplace. 

Based on the Policy Framework FHWA submitted the updated procedures to OST for approval on 

September 19, 2019. On November 19, 2019, FHWA received final approval for its process. The 

FHWA communicated the approval and the new process to all employees on December 18, 2019, via 

email. Training FHWA secured a contract for FY 2020 Anti-Harassment Training. This contract will 

provide anti-harassment training to all FHWA employees. 

Training FY2020 Anti-Harassment Training of Managers/Supervisors (Agency Leaders, Headquarters 

Management, and Field Management) is in process in FY 2020. Over seven in-person and virtual 

sessions for the Prevention of Harassment are being scheduled. In addition, FHWA developed and 

released the Anti-Harassment Toolkit for Managers that is a comprehensive resource to managers to 

understand their roles and responsibilities. 

PART H.2

 STATEMENT of

 MODEL PROGRAM

 ESSENTIAL ELEMENT

B.1.a. Is the agency head the immedi

[see 29 CFR §1614.102(b)(4)] 

ate supervisor of the person (“EEO Director”) who has day-to-day control over the EEO office? 

DEFICIENCY: 

The Associate Administrator for Civil Rights Reports to the Agency Executive Director who is the Agency’s top career employee. The Executive Director is 

responsible for all workforce matters in the Agency. 

Page 37 
EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART H EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Plan to Attain Essential Elements 

PART H.3

 STATEMENT of D.1.b. Does the agency regularly use the following sources of information for trigger identification: workforce data; complaint/ MODEL PROGRAM grievance data; exit surveys; employee climate surveys; focus groups; affinity groups; union; program evaluations; special emphasis ESSENTIAL ELEMENT programs; and/or external special interest groups? [see MD-715 Instructions, Sec. I] DEFICIENCY: 

The FHWA has not completed a 3-year trend analyses for the workforce compensation and reward system by race, national origin, sex, and disability. 

Date Objective Initiated: Target Date For Completion Of Initiative: 

Dec 15, 2005 Sep 30, 2017 

To conduct trend analyses for workforce compensation and reward system by race, national origin, sex, and disability. 

OBJECTIVE: 

Responsible Official David Lewis

PlannedActivities 

Report of Accomplishments 

and Modifications to 

Objective 

Target Date Planned Activity 

Sep 17, 2017 12:00 HCR in continued partnership with HR will conduct annual barrier analyses by race, 

AM national origin and sex on workforce compensation and awards for the last 3 to 5 

years. 

Sep 30, 2017 12:00 HCR in continued partnership with HR will conduct annual trend analyses by 

AM disability on workforce compensation and awards for the last 3 to 5 years. 

The FHWA continues to examine and review its recruitment trends in an effort to bolster the Agency’s 

corporate recruitment plan. It will be utilizing 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-plus 

page recruitment plan 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 was developed. 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 2020. 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. 

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. 

Page 38 
EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART H EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Plan to Attain Essential Elements 

PART H.4

 STATEMENT of

 MODEL PROGRAM

 ESSENTIAL ELEMENT OTHER. OTHER 

DEFICIENCY: 

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: 

Responsible Official 

PlannedActivities 

Report of Accomplishments 

and Modifications to 

Objective 

Date Objective Initiated: Target Date For Completion Of Initiative: 

Dec 15, 2011 Sep 17, 2017 

To track and analyze the effectiveness of our targeted recruitment outreach efforts to determine whether FHWA is yielding a 

sufficient number of applications from the targeted recruitment activities conducted throughout the year 

David Lewis 

Target Date Planned Activity 

Sep 30, 2017 12:00 Analyze Data. 

AM 

Sep 30, 2020 12:00 FHWA will work to identify the best approach to gathering and tracking data on 

AM recruitment resources. 

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. 

The FHWA continues to examine and review its recruitment trends. It will be utilizing the Data 

Visualization Center to continue to identify ways to improve its recruitment and onboarding efforts. 

This will be an ongoing effort for FY 2020. 

Page 39 
EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART H EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Plan to Attain Essential Elements 

PART H.5

 STATEMENT of

 MODEL PROGRAM

 ESSENTIAL ELEMENT OTHER. OTHER 

DEFICIENCY: 

The FHWA did not have Anti-Harassment procedures to complement its current Anti-Harassment policy. The FHWA developed procedures to address this 

deficiency in FY 19 and Agency Leadership signed the procedures in FY 20. Implementation is currently underway. 

OBJECTIVE: 

Responsible Official 

PlannedActivities 

Report of Accomplishments 

and Modifications to 

Objective 

OBJECTIVE: 

Responsible Official 

PlannedActivities 

Report of Accomplishments 

and Modifications to 

Objective 

Date Objective Initiated: Target Date For Completion Of Initiative: 

Jan 1, 2019 Sep 30, 2020 

Revise current Anti-Harassment policy statement to bring it in compliance with EEOC requirements. 

Irene Rico 

Target Date Planned Activity 

Sep 30, 2019 12:00 The FHWA pilots an Anti-Harassment Training Program including the coordination 

AM process. As part of the roll out of that pilot program, FHWA issued an antiharassment policy statement in October 2017. 

The FHWA delivered training and technical assistance on the Anti-Harassment Coordination 

Program. On October 10, 2017, FHWA Acting Administrator signed the Anti-Harassment policy 

statement. This statement was distributed to all employees outlining the process for filing harassment 

complaints. A brochure was also developed and made available to employees via the Website https:// 

www.fhwa.dot.gov/civilrights/programs/docs/antiharass_pilot_brochure.pdf FHWA completed all 

objectives and developed policies and procedures addressing the deficiency in the EEO Program. 

FHWA continues to revise the policy 

On June 21, 2019, the Department issued its Policy Framework for the Prevention of Harassment, 

which, among other things, requires each mode to develop an anti-harassment process incorporating 

certain parameters, and submit that process for OST review within 90 days. The FHWA pilot process 

already met many of the Framework’s requirements but did not meet others. Since the issuance of 

the Framework, the workgroup has been working to revise the FHWA pilot process to conform to the 

Framework’s requirements. Similar to the pilot process, the proposed FHWA Anti-Harassment 

Process addresses allegations of any type of harassment in or relating to (FHWA) workplace. The 

process identifies the management official responsible for deciding whether or not harassment has 

occurred. Based on the Policy Framework, FHWA submitted the updated procedures to OST for 

approval on September 19, 2019. The procedures were approved by OST and signed by the 

Administrator on December 13, 2019. The Executive Director issued the Anti-Harassment Process 

electronically on December 18, 2019. 

Date Objective Initiated: Target Date For Completion Of Initiative: 

Mar 30, 2018 Sep 30, 2019 

Develop step-by-step procedures and identify responsible management official for deciding whether or not harassment has occurred. 

Irene Rico 

Target Date Planned Activity 

Sep 30, 2019 12:00 The FHWA pilots an Anti-Harassment Training Program including the coordination 

AM process. As part of the roll out of that pilot program, FHWA issued an antiharassment policy statement in October 2017. 

On June 21, 2019, the Department issued its Policy Framework for the Prevention of Harassment, 

which, among other things, requires each mode to develop an anti-harassment process incorporating 

certain parameters, and submit that process for OST review within 90 days. The FHWA pilot process 

already met many of the Framework’s requirements but did not meet others. Since the issuance of 

the Framework, the workgroup has been working to revise the FHWA pilot process to conform to the 

Framework’s requirements. Similar to the pilot process, the proposed FHWA Anti-Harassment 

Process addresses allegations of any type of harassment in or relating to (FHWA) workplace. The 

process identifies the management official responsible for deciding whether or not harassment has 

occurred. 

Page 40 
EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART I EEO PROGRAM STATUS REPORT 

DOT Federal Highway Administration For period covering October 1, 2018 to September 30, 2019 

Plan to Eliminate Identified Barriers 

STATEMENT OF CONDITION THAT WAS A TRIGGER FOR 

A POTENTIAL BARRIER: 

Provide a brief narrative describing the condition at issue. 

How was the condition recognized as a potential barrier? 

STATEMENT OF BARRIER GROUPS: 

PART I.1 

White Females Hispanic Females, American Indian or Alaska Native 

Females Native Hawaiian or Other Pacific Islander Females, Two or 

More Races Males Persons with Disabilities Persons with Targeted 

Disabilities 

Barrier Group 

BARRIER ANALYSIS: 

Provide a description of the steps taken and data analyzed to 

determine cause of the condition. 

STATEMENT OF IDENTIFIED BARRIER: 

Provide a succinct statement of the agency policy, procedure 

or practice that has been determined to be the barrier of the 

undesired condition. 

Objective 

Responsible Officials 

Planned Activities Toward Completion of Objective 

Report of Accomplishments and Modifications to Objective 

Hispanic or Latino Females 

White Females 

Native Hawaiian or Other Pacific Islander Females 

American Indian or Alaska Native Females 

Two or More Races Males 

FHWA has a low participation rate for the groups identified below as compared with the 

FY 10 Civilian Labor Workforce. • Women • Hispanic Females • White Females • Native 

Hawaiian or Other Pacific Islander Females • American Indian or Alaska Native Males • 

American Indian or Alaska Native Females • Two or More Races Males • Persons with 

Disabilities at the GS 12-SES • Persons with Targeted Disabilities at the GS 13/14 and SES 

levels 

FHWA will continue to implement its focus outreach efforts to recruit qualified female 

applicants and applicants from groups with lower than expected participation rates. 

FHWA will leverage its resources to increase recruitment efforts, through the 2019-2022 

Strategic Plan. 

Date Objective Mar 30, 2018

Initiated 

Target Date For Sep 30, 2020 

Completion Of 

Objective 

Irene Rico Associate Administrator for Civil Rights 

David Lewis Director of Human Resources 

Planned Activity Target Date 

FHWA will continue to implement its focus outreach efforts to Mar 30, 2018 

recruit qualified female applicants and applicants from groups 

with lower than expected participation rates. FHWA will 

leverage its resources to increase recruitment efforts, through 

the 2019-2022 Strategic Plan. 

FHWA will report on its accomplishments for this in FY 2020. 

Page 41 
ppppppp 

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 affirmative action plan will improve the 

recruitment, hiring, advancement, and retention of applicants and employees with 

disabilities. 

Section I: Efforts to Reach Regulatory Goals 

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

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

1. Using the goal of 12% as the benchmark, does your agency have a trigger involving PWD by grade level cluster in the permanent workforce? If “yes”, 

describe the trigger(s) in the text box. 

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

b.Cluster GS-11 to SES (PWD) Answer Yes 

Source: Table B1: In FY19, PWD in GS 1-10 Cluster of the permanent 

workforce participate at 22.71%, a higher rate than the expected 12% 

benchmark, indicating no trigger. PWD in the GS 11 to SES Cluster participate 

at 9.46%, a lower rate than the expected 12% benchmark, indicating a trigger. 

(Source: Table B-4-1) 

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

(7). For all other pay plans, please use the approximate grade clusters that are above or below GS-11 Step 1 in the 

Washington, DC metropolitan region. 

2. Using the goal of 2% as the benchmark, does your agency have a trigger involving PWTD by grade level cluster in the permanent workforce? If “yes”, 

describe the trigger(s) in the text box. 

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

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

Table B1: In FY19, PWTD in GS 1-10 Cluster of the permanent workforce 

participate at 8.42%, a higher rate than the expected 2% benchmark, indicating 

no trigger. PWTD in the GS 11 to SES Cluster participate at 2.0%, a rate equal 

to the expected 2% benchmark, indicating no trigger. (Table B-4-1) 

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

Through FY19, the Agency’s numerical goals for hiring person with disabilities 

was shared via the Agency’s quarterly Leadership Team Dashboard. This was 

specifically 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. 

Answer Yes 

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

official. 

Page 42 
Page 43 

# of FTE Staff By Employment Status 

Disability Program Task Full Time Part Time Collateral Duty 

Responsible Official (Name, Title, 

Office Email) 

Processing applications from PWD and PWTD 1 0 0 Marlo Moises 

Lead Human Resources Specialist 

Answering questions from the public about 

hiring authorities that take disability into 

account 

1 0 0 Marlo Moises 

Lead Human Resources Specilaist 

Processing reasonable accommodation requests 

from applicants and employees 

1 0 0 Kirsten Poston 

Disability Program Manager 

Section 508 Compliance 1 0 0 Michelle Cribbs 

Transportation Specialist 

Architectural Barriers Act Compliance 1 0 0 Jeffrey Baxter 

Associate Director of Facilities 

Special Emphasis Program for PWD and PWTD 1 0 0 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. 

Answer Yes 

All Human Resources Specialists and hiring managers are required to 

complete the Veteran Employment Training for Human Resource Professionals 

which also includes information on the use of Schedule A hiring authorities. 

This information is tracked via the DOT’s Learning Management System. 

B. PLAN TO ENSURE SUFFICIENT FUNDING FOR THE DISABILITY PROGRAM 

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

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

sufficient funding and other resources 

Answer Yes 

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 APPLICATIONS 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 FY19, FHWA 

participated in 53 recruitment events in 24 States. Of those seven 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 sites to be more visible. FHWA is 

using Handshake and Simplicity to post job opportunities. • The FHWA has 

launched a new 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 the number of hiring 

fairs targeting applicants with disabilities nationally. • 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 

database; State and local vocational rehabilitation agencies and employment 

offices; the U.S. 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 

FHWA utilizes appointing authorities to include Schedule A, Excepted Service, 

Veterans Recruitment Appointment and 30% or more Disabled Veterans. 

FHWA continues to work with the DOT Office of the Secretary on the 

establishment of the Warriors to the DOT program. FHWA was one of a just a 

few agencies within DOT to make a selection in support of this program. 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 Disability Resource Manager 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. 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. 

Answer Yes 

Page 44 
In FY19, the FHWA Office of Human Resources conducted Webinars on hiring 

veterans, disabled veterans and persons with disabilities for the HR Community 

as well as for the hiring managers. The FHWA Selective Placement Program 

Coordinator advised the HR Specialists on the Goals for FY19, as well as 

addressing workforce/succession planning needs. As positions become vacant, 

HR Specialists discussed the hiring flexibilities and options with hiring 

managers to reinforce the Agency's commitment for employing a diverse 

workforce. 

B.  PLAN TO ESTABLISH CONTACTS WITH DISABILITY EMPLOYMENT ORGANIZATIONS 

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

in securing and maintaining employment. 

The FHWA launched a new ROAD Team 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 FHWA, as well as the name and email of a dedicated 

resource to contact. The ROAD 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. In FY19, FHWA attended seven recruitment 

events at colleges, universities, academic institutions, and professional 

associations that support populations of diverse recruitment candidates. 

C.  PROGRESSION TOWARDS GOALS (RECRUITMENT AND HIRING) 

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

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

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

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

In FY19, the new hire rate for FHWA PWD in the permanent workforce was 

16.52%, a higher rate than the expected 12% benchmark, indicating no trigger. 

The new hire rate for FHWA PWTD in the permanent workforce is 4.35%, 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 of the mission-critical 

occupations (MCO)? If “yes”, please describe the triggers below. Select “n/a” if the applicant data is not available for your agency, and describe your plan 

to provide the data in the text box. 

a. New Hires for MCO (PWD) Answer Yes 

b. New Hires for MCO (PWTD) Answer Yes 

See Table on page 64 of the PDF version of the report. 

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

mission-critical occupations (MCO)? If “yes”, please describe the triggers below. Select “n/a” if the applicant data is not available for your agency, and 

describe your plan to provide the data in the text box. 

a. Qualified Applicants for MCO (PWD) Answer Yes 

b. Qualified Applicants for MCO (PWTD) Answer Yes 

See Page 65 of the PDF version of the report. 

4.  Using the qualified applicant pool as the benchmark, do triggers exist for PWD and/or PWTD among employees promoted to any of the missioncritical occupations (MCO)? If “yes”, please describe the triggers below. Select “n/a” if the applicant data is not available for your agency, and describe 

your plan to provide the data in the text box. 

a. Promotions for MCO (PWD) Answer Yes 

b. Promotions for MCO (PWTD) Answer Yes 

Please see page 65 of the PDF of the report. 

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 

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

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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, 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 OPPORTUNITES 

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

The 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. There is a focus on the 

leadership pipeline, however opportunities are provided for employees at all 

grade levels and across all job series. FY 2019 Webinars and trainings focused 

on the development of the Individual Developmental Plans to help employees 

take ownership of their personal development while understanding how their 

supervisors and assist them in reaching their goals. The FHWA also 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 ways. The 

programs are as follows: PDP, FHWA 360 Degree Leadership Assessment, 

Discipline Support System, Is Supervision for Me?, Building the Foundation for 

Visionary Leadership, Career Advancement Webinar Series, DMC Women’s 

Forum Webinar Series, Critical Human Resources Skills, Formal Mentoring 

Program, Individual Development Plan Workshop, Launch Point, Leadership 

Competency Certificate Program, Leadership Development Academy, 

Management and Supervision Forum Webinar Series, Organizational 

Facilitation, Transportation Operations Academy Senior Management Program, 

and the Freight Academy Program. 

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 49 31 10.2 16.1 4.1 6.5 

Fellowship Programs 5 1 20.0 100.0 20.0 100.0 

Mentoring Programs 48 48 10.4 10.4 2.1 2.1 

Coaching Programs 2 2 0.0 0.0 0.0 0.0 

Training Programs 25 12 12.0 16.7 0.0 0.0 

Detail Programs 6 5 16.7 0.0 0.0 0.0 

Other Career Development 

Programs 

432 389 9.3 10.0 3.0 3.1 

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

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

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

a. Applicants (PWD) Answer No 

b. Selections (PWD) Answer Yes 

PWD were selected for training programs at a lower rate than they applied for 

Detail Programs, indicating a trigger. Of the six employees who applied for a 

detail assignment, one applicant was a person with a disability. The individual 

was not among those selected which indicates a trigger. The trigger resulting 

from the non-selection of one employee presents a questionable level of 

significance. For all other career development programs, PWD’s were selected 

at the same or higher rate indicating no trigger. 

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

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

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

a. Applicants (PWTD) Answer No 

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b. Selections (PWTD) Answer No 

For all career development programs, PWTD’s were selected at the same or 

higher rate indicating no trigger. 

C.  AWARDS 

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

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

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

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

Please see page 68 of the reports PDF to see the table that explains this 

category. 

2.  Using the inclusion rate as the benchmark, does your agency have a trigger involving PWD and/or PWTD for quality step increases or performancebased pay increases? If “yes”, please describe the trigger(s) in the text box. 

a. Pay Increases (PWD) Answer Yes 

b. Pay Increases (PWTD) Answer No 

Please see page 69 of the PDF of the report for the table explaining this 

category. 

3.  If the agency has other types of employee recognition programs, are PWD and/or PWTD recognized disproportionately less than employees without 

disabilities? (The appropriate benchmark is the inclusion rate.) If “yes”, describe the employee recognition program and relevant data in the text box. 

a. Other Types of Recognition (PWD) Answer Yes 

b. Other Types of Recognition (PWTD) Answer Yes 

Please see page 69 of the PDF version of the report for explanation of this 

category. 

D.  PROMOTIONS 

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

(The appropriate benchmarks are the relevant applicant pool for qualified internal applicants and the qualified applicant pool for selectees.) For non-GS 

pay plans, please use the approximate senior grade levels. If “yes”, describe the trigger(s) in the text box. Select “n/a” if the applicant data is not available 

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

a.  SES 

i. Qualified Internal Applicants (PWD) Answer Yes 

ii. Internal Selections (PWD) Answer Yes 

b. Grade GS-15 

i. Qualified Internal Applicants (PWD) Answer No 

ii. Internal Selections (PWD) Answer No 

c.  Grade GS-14 

i. Qualified Internal Applicants (PWD) Answer Yes 

ii. Internal Selections (PWD) Answer Yes 

d.  Grade GS-13 

i. Qualified Internal Applicants (PWD) Answer Yes 

ii. Internal Selections (PWD) Answer Yes 

See page 70-71 of the PDF version of the report for the table that explains this 

category. 

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

(The appropriate benchmarks are the relevant applicant pool for qualified internal applicants and the qualified applicant pool for selectees.) For non-GS 

pay plans, please use the approximate senior grade levels. If “yes”, describe the trigger(s) in the text box. Select “n/a” if the applicant data is not available 

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

a.  SES 

i. Qualified Internal Applicants (PWTD) Answer No 

ii. Internal Selections (PWTD) Answer Yes 

b. Grade GS-15 

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i. Qualified Internal Applicants (PWTD) Answer No 

ii. Internal Selections (PWTD) Answer Yes 

c.  Grade GS-14 

i. Qualified Internal Applicants (PWTD) Answer Yes 

ii. Internal Selections (PWTD) Answer Yes 

d.  Grade GS-13 

i. Qualified Internal Applicants (PWTD) Answer Yes 

ii. Internal Selections (PWTD) Answer Yes 

Please see page 71 of the PDF of the report for the table supporting these 

answers. 

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

For non-GS pay plans, please use the approximate senior grade levels. If “yes”, describe the trigger(s) in the text box. Select “n/a” if the applicant data is 

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

a. New Hires to SES (PWD) Answer Yes 

b. New Hires to GS-15 (PWD) Answer Yes 

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

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

See page 72 of the PDF of the report to see the table reflected for this category. 

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

levels? For non-GS pay plans, please use the approximate senior grade levels. If “yes”, describe the trigger(s) in the text box. Select “n/a” if the applicant 

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

a. New Hires to SES (PWTD) Answer Yes 

b. New Hires to GS-15 (PWTD) Answer Yes 

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

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

Please see page 73 of the PDF for this category 

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

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

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

text box. 

a.  Executives 

i. Qualified Internal Applicants (PWD) Answer Yes 

ii. Internal Selections (PWD) Answer Yes 

b.  Managers 

i. Qualified Internal Applicants (PWD) Answer No 

ii. Internal Selections (PWD) Answer Yes 

c. Supervisors 

i. Qualified Internal Applicants (PWD) Answer Yes 

ii. Internal Selections (PWD) Answer Yes 

See page 73 on the PDF version of the report for explanation of this category. 

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

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

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

text box. 

a.  Executives 

i. Qualified Internal Applicants (PWTD) Answer No 

ii. Internal Selections (PWTD) Answer Yes 

b.  Managers 

i. Qualified Internal Applicants (PWTD) Answer No 

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ii. Internal Selections (PWTD) Answer Yes 

c. Supervisors 

i. Qualified Internal Applicants (PWTD) Answer Yes 

ii. Internal Selections (PWTD) Answer No 

See page 74 of the PDF for the table that explains this category. 

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

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

plan to provide the data in the text box. 

a. New Hires for Executives (PWD) Answer Yes 

b. New Hires for Managers (PWD) Answer Yes 

c. New Hires for Supervisors (PWD) Answer Yes 

See table on page 75 of the PDF for the table that explains this category. 

8.  Using the qualified applicant pool as the benchmark, does your agency have a trigger involving PWTD among the selectees for new hires to 

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

plan to provide the data in the text box. 

a. New Hires for Executives (PWTD) Answer Yes 

b. New Hires for Managers (PWTD) Answer Yes 

c. New Hires for Supervisors (PWTD) Answer Yes 

See page 75 of the PDF showing the table that explains this category. 

Section V: Plan to Improve Retention of Persons with Disabilities 

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

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

retaining employees with disabilities; (2) describe efforts to ensure accessibility of technology and facilities; and (3) 

provide information on the reasonable accommodation program and workplace assistance services. 

A.  VOLUNTARY AND INVOLUNTARY SEPARATIONS 

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

satisfactory service (5 CFR § 213.3102(u)(6)(i))? If “no”, please explain why the agency did not convert all eligible Schedule A employees. 

Answer No 

All but one Schedule A employee was converted after 2 years of satisfactory 

service. Conversion is still being considered for the remaining employee, but 

has been delayed in an effort to resolve conduct and performance concerns 

prior to conversion. 

2. Using the inclusion rate as the benchmark, did the percentage of PWD among voluntary and involuntary separations exceed that of persons without 

disabilities? If “yes”, describe the trigger below. 

a.Voluntary Separations (PWD) Answer Yes 

b.Involuntary Separations (PWD) Answer Yes 

See page 77 of the PDF for the table that explains this category. 

3. Using the inclusion rate as the benchmark, did the percentage of PWTD among voluntary and involuntary separations exceed that of persons without 

targeted disabilities? If “yes”, describe the trigger below. 

a.Voluntary Separations (PWTD) Answer Yes 

b.Involuntary Separations (PWTD) Answer No 

See page 77 of the PDF for the table that explains this category. 

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. 

In analyzing the exit interview results and other data sources, the large majority 

of reasons why PWD and/or PWTD left the Agency was for family reasons, 

health reasons including medical hardships, and career promotional 

opportunities. A good number of employees also left the Agency due to 

retirement. 

B.  ACCESSIBILITY OF TECHNOLOGY AND FACILITIES 

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

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

technology, and the Architectural Barriers Act of 1968 (42 U.S.C. § 4151-4157), concerning the accessibility of 

agency facilities. In addition, agencies are required to inform individuals where to file complaints if other agencies are 

responsible for a violation. 

1. Please provide the internet address on the agency’s public website for its notice explaining employees’ and applicants’ rights under Section 508 of the 

Rehabilitation Act, including a description of how to file a complaint. 

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The internet address on the Agency’s public Website regarding Section 508 of 

the Rehabilitation Act of 1973, including a description of how to file a complaint 

is www.transportation.gov/accessibility. 

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 Agency’s public Website regarding Architectural 

Barriers Act is www.access-board.gov/guidelines-and-standerds/buildings-andsites/about-the-aba-standards. 

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. 

Not Applicable. 

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.) 

The Agency complies with the policy of processing requests within the 25-

business day policy as set forth by the Department’s Order 1101.1A. FHWA 

processes reasonable accommodations requests within this time frame unless 

extenuating circumstances prevent it from doing so. Requests are processed 

through the Department’s Reasonable Accommodations Online Tracking 

System. 

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 19 the Agency worked with the Departmental Office of Civil Rights to 

revise and update DOT Order 1011.1B. The Department hosted several 

sessions of training on Reasonable Accommodations during FY 19. The 

Agency Disability Program Manager provided a training overview of the 

Reasonable Accommodations process to FHWA Leadership, and to several 

division offices. The Agency has completed a draft of the Reasonable 

Accommodations Handbook which is currently under internal review and 

expects to submit to EEOC in the later part of FY 20 for review and approval 

after the Department receives approval on their updated version of the DOT 

Order on Reasonable Accommodations. 

D. PERSONAL ASSISTANCE SERVICES ALLOWING EMPLOYEES TO PARTICIPATE IN THE 

WORKPLACE 

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

personal assistance services (PAS) to employees who need them because of a targeted disability, unless doing so 

would impose an undue hardship on the agency. 

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

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

training for managers and supervisors, and monitoring PAS requests for trends. 

This is handled at the Departmental level. 

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? 

Answer Yes 

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

agreement? 

Answer Yes 

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. 

Page 50 
FHWA had no findings of discrimination in FY 19. FHWA settled cases 

involving, among other claims, those of harassment based on disability status. 

These cases were not considered to be ones where there was a substantial 

risk of an adverse finding on the harassment issue, and the cases were 

resolved without any admission of liability. Accordingly, no corrective measures 

were required on these claims. 

B.  EEO COMPLAINT DATA INVOLVING REASONABLE ACCOMMODATION 

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

compared to the government-wide average? 

Answer Yes 

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

agreement? 

Answer Yes 

3. If the agency had one or more findings of discrimination involving the failure to provide a reasonable accommodation during the last fiscal year, please 

describe the corrective measures taken by the agency. 

FHWA had no findings of discrimination in FY 19. FHWA settled cases 

involving, among other claims, those of reasonable accommodation. These 

cases were not considered to be ones where there was a substantial risk of an 

adverse finding on the reasonable accommodation issue, and the cases were 

resolved without any admission of liability. Accordingly, no corrective measures 

were required on the reasonable accommodation claims. 

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? 

Answer Yes 

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

Answer Yes 

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

where applicable, accomplishments 

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

FHWA is targeting a 09/30/2020 as a completion date for the objectives listed 

above. 

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

FHWA will report out progress and updates for the upcoming FY 20 MD-715 

Report. 

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 20 MD-715 

Report. 

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